Effective Date: April 1, 2025

Version: 1.0

1. Scope

This Privacy Notice applies exclusively to the use of our website. As our company, Adwise Ukraine LLC, primarily operates in a B2B environment, certain personal data processing activities may also be governed by contractual agreements. This notice does not apply to any other data collection activities conducted as part of our business operations outside the website. Please note that certain data collection and processing activities related to business transactions and payments are governed by specific contracts, including Data Processing Agreements (DPA), and do not fall under the scope of this Privacy Notice.

Controller: Adwise Ukraine LLC

Address: Ukraine, 02094, Kyiv, Verkhovnoi Rady Boulevard, building 22

Contact Email: [email protected]

2. Personal Data We Collect

We collect the following personal data when you use a contact form on our website:

• Name
• Email address
• Message content (which may or may not contain personal data)

We do not collect cookies beyond essential cookies necessary for the website’s functionality.

3. How We Use Personal Data

We process personal data (name, email address, message content) based on our legitimate interest to respond to inquiries, facilitate communication with potential business partners, notify regarding significant changes in privacy notice. This interest includes addressing questions, providing information about our services, and maintaining business relationships. If the data provided relates to a business entity and does not identify an individual, it may not be considered personal data under applicable laws. The data submitted is used solely for communication purposes.

All personal data is obtained directly from the data subject..

4. Data Sharing

We do not share the collected name, email address or message content with third parties.

5. Data Retention

We retain personal data collected through the contact form for no longer than one month after the last communication with the user unless a longer retention period is required for legal or contractual reasons.

6. User Rights

Users whose personal data is processed under this Privacy Notice have the following rights:

• Right to Access – You have the right to request a copy of your personal data that we hold.
• Right to Rectification – You may request correction of any inaccurate or incomplete personal data.
• Right to Erasure – You can request the deletion of your personal data, subject to certain conditions.
• Right to Restrict Processing – You have the right to request that we limit the processing of your personal data.
• Right to Object – You may object to the processing of your personal data at any time.
• Right to Lodge a Complaint – You have the right to file a complaint with the relevant data protection authority.

If you wish to exercise any of these rights, please contact us at [email protected] or through the contact form. We will review and address your request in accordance with applicable laws.

7. User Choices and Control

As we do not use non-essential cookies, no additional consent or opt-out mechanism is required for cookies.

8. Exercising Your Rights

If you wish to exercise any of your rights under applicable data protection laws, including the right to access, rectify, erase, restrict processing, or object to the processing of your personal data, you may do so by:

• Contacting us via email at [email protected]
• Submitting a request through the contact form
• Indicating their request during ongoing communication

9. Automated Decision-Making

We do not conduct any automated processing or profiling of personal data.

10. Children’s Information

We do not knowingly collect personal information from children under the age of 18, as our services are not intended for children. Due to the lack of technical means to verify the age of users (as we do not collect unnecessary information in accordance with the data minimization principle), we cannot ensure that no personal information from children is collected. However, if we become aware that such data has been collected, it will be deleted immediately.

11. Notice Updates and Notifications

We may update this Privacy Notice from time to time. The latest version will always be available on our website with the last updated date clearly stated. If any significant changes are made, we will notify users who have previously provided their email via direct email communication.

For any questions regarding this Privacy Notice, please contact us at [email protected]

Our Privacy Practices

This overview outlines our privacy practices specifically related to our product. It explains how we collect, process, and protect personal data within our digital marketing and advertising services. Unlike the website-specific privacy notice provided above, this overview focuses on data processing in the context of our partnerships with publishers and advertisers. We clarify our roles in data handling, the legal basis for processing, and our compliance with applicable regulations, including the General Data Protection Regulation (GDPR). Our commitment is to ensure responsible and lawful data use across all business activities.

We collaborate with publishers and advertisers to provide digital marketing and advertising services. As part of these services, we may collect, process, and share data for various purposes related to advertising campaigns, targeting, and user engagement. Our involvement in the collection and processing of personal data depends on the specific context of each partnership and the roles of the parties involved.

This overview provides a clear overview of how we process data in different contexts, ensuring that we comply with all relevant data protection regulations. We clarify the roles of data controllers, data processors, and other entities involved, specifying when we act in each role and outlining the responsibilities of the different parties.

1. General Information

Our business operations include collaborating with publishers and advertisers to provide digital marketing and advertising solutions. In many cases, publishers collect and manage personal data directly via their websites or digital platforms. They are responsible for gathering and processing such data, which may include data collected through cookies or other tracking technologies.

Once this data is transferred to us, we may process it in different roles depending on the specific relationship and context. In the majority of cases, we act as a data processor, as we process personal data based on the instructions of the advertiser, who acts as the data controller. However, in certain cases, we may also act as a data controller or joint controller, depending on the specific business arrangement.

We ensure that any data we receive from publishers has been collected and processed in accordance with applicable laws, including GDPR.

2. Data Processing and Legal Basis

The legal basis for processing personal data may vary depending on the specific processing activities and roles of each party. In each individual case, the appropriate legal basis may differ, and in many instances, it is determined not by us, but by the publisher. In each individual case, the appropriate legal basis may differ, and in many instances, it is determined not by us, but by the publisher. In cases where publishers collect data and pass it to us, they typically determine the legal basis for the collection and transfer of this data.

The legal basis for data processing may include, but is not limited to:

• Consent – where the data subject has given explicit consent for processing their personal data.
  
• Legitimate Interests – where the processing is necessary for our legitimate business interests or those of a third party and where the interests or fundamental rights and freedoms of the data subject do not override these interests.
  

Once we receive data from publishers, we ensure that it is processed in accordance with the initial purpose for which it was collected, whether based on consent, legitimate interest, or another legal basis.

We work closely with publishers to verify that they are collecting and processing personal data lawfully and that they have the necessary consent and legal grounds to share this data with us.

We also work closely with advertisers, ensuring that, throughout our collaboration, they are processing personal data lawfully and have the necessary legal grounds for doing so. While we do not directly receive personal data from advertisers, we follow their instructions as part of our contractual obligations. During the course of our work, we continuously check and verify their compliance with all relevant legal and regulatory standards, ensuring that all roles and responsibilities in data processing are clearly defined and upheld.

3. Roles in Data Processing

Our company may be involved in data processing in various capacities, depending on the specific business operation. We may act as:

• Data Controllers – when we determine the purposes and means of processing personal data.
  
• Data Processors – when we process personal data on behalf of another organization (e.g. advertisers).
  
• Joint Controllers – when we jointly control the processing of personal data with another organization, typically with advertisers or publishers.
  

While we play an active role in ensuring that data is processed in compliance with applicable laws (including GDPR), publishers are primarily responsible for collecting and managing personal data. This includes ensuring that proper consent is obtained, privacy notices are provided, and other relevant requirements are met.

4. Roles in Data Processing

We and our publishers may collect various types of personal data, including but not limited to:

• Identifiers – such as IP addresses, unique device identifiers, and cookie IDs.
• Contact Information – such as email addresses and phone numbers (if provided by users with consent).
• Behavioral Data – including browsing history, interaction with advertisements, and time spent on websites.
• Technical Data – including device type, operating system, and browser type.
• Advertising Preferences – such as interests, preferences, and engagement with digital content.

We ensure that all collected data is processed in accordance with applicable laws and regulations.

5. Data Transfer and International Data Processing

In our business operations, data may be transferred across borders, including to countries outside the EU/EEA. We ensure that such transfers comply with applicable laws requirements (including GDPR). When transferring personal data to third countries, we implement appropriate safeguards, such as Standard Contractual Clauses (SCC), to protect the data and ensure compliance with applicable laws standards.

6. Data Retention

The retention period for personal data depends on how we obtain the data:

• If we collect personal data directly from the data subject, we specify the retention period at the point of collection.
• If we receive personal data from third parties (e.g., publishers or advertisers), the retention period is typically determined by those third parties. However, we also assess whether the retention periods set by third parties are appropriate and compliant with applicable laws.

We ensure that personal data is not stored longer than necessary for the purposes for which it was collected and processed, in compliance with legal and regulatory obligations.

7. Data Subject Rights

Individuals whose personal data we process have certain rights, which include:

• Right to Access – the right to request access to personal data we hold about them.
• Right to Rectification – the right to correct inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten) – the right to request deletion of personal data under certain conditions.
• Right to Restrict Processing – the right to request a limitation on the processing of personal data under specific circumstances.
• Right to Object – the right to object to the processing of personal data on the basis of legitimate interest or for direct marketing purposes.
• Right to Data Portability – the right to request the transfer of personal data to another data controller.
• Right to Withdraw Consent – the right to withdraw consent where it is the legal basis for processing.

If a data subject believes our data processing does not comply with applicable law, they may contact us to exercise their rights.

8. Additional Key Information

• We do not share cross-client data. Clients using licensed technologies retain ownership of the data collected from campaigns, and licensed tech vendors can only use aggregated data for system improvements.
• We do not sell user data.
• We have agreements in place with any partner publishers or data providers who share targeting data, ensuring they include an opt-out option for users who do not wish to be uniquely tracked or targeted by advertisers.
• We do not perform cookie matching between different third parties through ads served on Google Display Network (GDN) or Owned & Operated (O&O) inventory.
• All of our or our partner`s cookie lifetimes do not exceed 2 years, unless it’s an opt-out cookie.
• On this website, we do not collect cookies, except for those that are strictly necessary for the functioning of the site. However, on other sites (or on our partner sites), cookies may be collected in accordance with applicable privacy laws. Users always have the option to opt out of non-essential cookies at any time.
• We utilize technology or require our partners (including publishers) to scan and disable malware to protect user data.

9. Contact Us Regarding Data Processing

If you have any questions or concerns about how we process your personal data or wish to exercise any of your rights, please contact us at:

• Email: [email protected]
  
• Contact Form on our website.
  

10. Updates to This Overview

We may update this overview from time to time. Any changes will be published on our website. We encourage you to review this overview regularly to stay informed of any updates.