Privacy Policy
Last modified: [02/05/2024]
Introduction
Adsession Ltd. (“Adsession” or “We”) respects your privacy and commits to protecting it through our compliance with the practices described in this policy. Adsession is the controller of the information collected or provided through the Website.
This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit www.adsession.com (our “Website”). This policy applies to the personal data collected through our Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections might allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this policy. We may change this policy on one or more occasions (see Changes to Our Privacy Policy). Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the policy periodically for updates.
Data We May Collect About You
We collect and use different types of data from and about you depending on whether you choose to create an account with us including:
● Personal data that we could reasonably use to directly or indirectly identify you, including your name, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, date of birth, billing and account information, country of residence, and any other identifier we may use to contact you online or offline (“personal data”). We do not collect or process your credit or debit card information. If you purchase services provided by us on the Website, the information that is necessary to make payment will be collected and processed by the third-party service provider (the payment processor) with which we work. The payment processor may share with us your email address, name, and billing address.
● Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, including demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
● Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
● Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.
How We Collect Data About You
We use different methods to collect data from and about you including through:
● Direct interactions. You may give us information about you by filling in forms or by corresponding with us by email or otherwise. This includes information you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our Website, and when you report a problem with our Website.
● Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies).
● Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.
Cookies and Automatic Data Collection Technologies
Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:
● Estimate our audience size and usage patterns.
● Store your preferences so we may customize our Website according to your individual interests.
● Speed up your searches.
● Recognize you when you return to our Website.
Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit www.allaboutdnt.com.
You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.
Our Website pages may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics including recording Website content popularity or verifying system and server integrity.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Personal Data Use Choices.
How We Use Your Personal Data
We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or conduct other business operations, including using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:
● Present our Website and provide you with the information, products, services, and support that you request from us.
● Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
● Fulfill the purposes for which you provided the data or that were described when it was collected.
● Notify you about changes to our Website, products, or services.
● Ensure that we present our Website content in the most effective manner for you and for your computer.
● Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
● Improve our Website, products or services, marketing, or customer relationships and experiences.
● Enable your participation in our Website’s interactive, social media, or other similar features.
● Protect our Website, employees, or operations.
● Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
● Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
● For any other purpose with your consent.
We may use non-personal data for any business purpose.
Disclosure of Your Personal Data
We may share your personal data with:
● Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
● Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
● To fulfill the purpose for which you provide it.
● For any other purposes that we disclose in writing when you provide the data.
● With your consent.
We may also disclose your personal data to third parties:
● In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
● To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
● To comply with any court order, law, or legal process, including responding to any government or regulatory request.
● To enforce or apply our terms of service and other agreements.
● To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
We may share non-personal data without restriction.
Transferring Your Personal Data
We are based in Cyprus. We may transfer personal data that we collect or that you provide as described in this policy to contractors, service providers, and other nonparties we use to support our business (including analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal data with the same standards set out in this policy.
We may process, store, and transfer your personal data in and to a foreign country, with different privacy laws that might or might not be as comprehensive as Cyprus law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country might be able to obtain access to your personal data through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and the GDPR.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Cyprus.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
Your Personal Data Use Choices
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. You can opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Our Website may, on one or more occasions, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
Accessing and Correcting Your Personal Data
If you have created an account on our Website, you can access, review, and change your personal data by logging into the Website and visiting your account profile page.
If you nave not created an account on our Website or you cannot access, review, or change your personal data on your account profile page, you may send us an email at [privacy@adsession.com] to request access to, correct, or delete any personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We might not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Law might allow or require us to refuse to provide you with access to some or all the personal data that we hold about you, or we might have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response or would like to correct the information provided, you may contact us at [privacy@adsession.com].
Jurisdiction Specific Rights
European Economic Area and United Kingdom
If you live in the European Economic Area or the United Kingdom, the following terms apply to you.
Legal Basis for Processing
We may process your personal data (1) because you have given us permission to do so (for example, by sending data through our Website’s contact or signup forms), (2) because the processing is in our legitimate interests and it is not overridden by your rights, or (3) because we need to process your personal data to perform a contract with you or comply with the law.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:
● Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your erasure request for specific legal reasons that will be notified to you, if applicable, at the time of your request.
● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
● Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy; (2) where our use of the data is unlawful, but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (4) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at [privacy@adsession.com].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it might take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.
United States
US state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
● Confirm whether we process their personal information.
● Access and delete certain personal information.
● Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
● Data portability.
● Opt-out of personal data processing for:
o targeted advertising (excluding Iowa);
o sales; or
o profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
● Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights might vary by state. To exercise any of these rights please email [privacy@adsession.com]. To appeal a decision regarding a consumer rights request please email [privacy@adsession.com].
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: [privacy@adsession.com]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Data Security
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections. We encrypt any payment transactions using SSL technology.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
Data Retention
Except as otherwise permitted or required by law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We may use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Children’s Online Privacy
We do not direct our Website to minors and we do not knowingly collect personal data from individuals under 18 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at [privacy@adsession.com].
Changes to Our Privacy Policy
We will post any changes we might make to our privacy policy on this page. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy policy.
Contact Information
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:
[26 Othellou, Strovolos, Nicosia, 2018, Cyprus]
[privacy@adsession.com]
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal data, our compliance with this policy, and with privacy laws. To discuss our compliance with this policy, please contact us using the contact information listed above.