The latest edition as of March 19, 2024 (authorized version)



PRIVACY AND CONFIDENTIALITY POLICY
OF "Adslab OÜ" (hereinafter referred as the "Privacy and Confidentiality Policy")

This Privacy and Confidentiality Policy is created in compliance with European regulations, particularly the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679), and other relevant data protection legislation. These laws oversee the legal aspects concerning the gathering, handling, and retention of personal information, and uphold individuals' rights to privacy and autonomy.


1. DEFINITIONS

1.1. In this Privacy and Confidentiality Policy, the following definitions are used:

1.1.1. "Adslab OÜ" or "Adslab" means a company registered under the law of Estonia with registered address at 8 Juhkentali Street, Tallinn city, Estonia; registration number: 16126173, and its associated entities, provides access to the Services.

1.1.2. "Services" means any products, mobile applications, including games and other platforms operated by Adslab.

1.1.3. "Personal Data" means any personal data regarding the User enabling direct identification (such as the User's email address) or indirect identification (such as User activity on the relevant website or Services) in accordance with hereby Privacy and Confidentiality Policy.

1.1.4. "Processing of Personal Data" means any action (operation) or a set of actions (operations) carried out with the Personal Data, whether automated or not, including: collection, recording, organization, accumulation, storage, adaptation (updating, modification), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, erasure, or destruction of the User's Personal Data.

1.1.5. "User" means a natural person who can be directly or indirectly identified, in particular by an identifier such as a name, identification number, location data, online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. The User is also an individual who receives access to the Services Adslab website.

1.1.6. "Cookie" means a small piece of data fragment dispatched by a web server and retained on the User's Devices. It is transmitted by a web client or browser to the web server in an HTTP request every time a page of the related website is accessed or when the User utilizes the Services.

1.1.7. "IP address" means a unique network address of a node in a computer network built on the IP protocol.

1.1.8. "Devices" or "Device" means computers, phones, or any other equipment through which the User accesses the Services or Adslab website.


2. SUBJECT OF PRIVACY AND CONFIDENTIALITY POLICY

2.1. By using the Service or interacting with the Adslab any way, the User confirms that they consent to the collection and processing of Personal Data by the Adslab, as well as authorized individuals of the Adslab.

2.2. The User gives in accordance with clause 2.1. of Privacy and Confidentiality Policy their consent to the Adslab for the processing of the information received, including collection, organization, accumulation, storage, clarification (updating, correction), use, dissemination, depersonalization, blocking, destruction of personal data for the purpose of creating a database of participants, compiling statistical reports, conducting marketing research, and interacting with the User, including through telecommunications networks, including sending SMS messages and emails, until such consent is withdrawn.

2.3. The User confirms their consent for the Adslab to interact through direct contacts using various means of communication, including but not limited to: postal mailings, email, the Internet, and others.

2.4. By accepting this Privacy and Confidentiality Policy the User give consent for processing and collection the Personal Data include, but are not limited to, the following information:

2.4.1. the User data:
- name and/or surname;
- email address;
- phone number;
- links to the individual on social media;
- IP address.

2.4.2. Financial data:
- information about payment from the User.
- information about the bank account and credit or debit card, invoice information, payment methods.

2.4.3. Contact information:
- information or records created as a result of contact with the Adslab. For example, this may include a phone conversation, online contact, contact via email, physical mail, or messengers such as Viber, Telegram, WhatsApp, and others.

2.4.4. Technical data:
- the IP address, date and time of the request, request content, access status/HTTP status code, the website that sends the request, operating system and its interface, language, and browser software version.

- the type of the Device is using;
- the User's Device operating system and version;
- the User's Device identifiers, like MAC address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
- the User's browser type;
- the User's browser and/or Device language;
- referring and exit pages and URLs;
- the number of clicks by the User on a certain page or feature;
- domain names;
- landing pages;
- pages viewed by the User and the order of those pages;
- the amount of time spent by the User on particular pages;
- in-Services activity, including the date and time of activity.

2.5. The Adslab may connect outlined above information with the User's social network ID and/or User ID.

2.6. The Adslab may use Google Analytics, Facebook Audience Insights, and/or other technologies that collect information about the User's behaviour and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners.


3. COOKIE POLICY

3.1. The Adslab collects information about the User's using the Services for the purpose of obtaining statistics on visits and their effectiveness, creating a personalized approach, and adapting to the interests of the User. Adslab do this using various technologies, one of which is cookie files. These are data that can be sent to the User's Device, and they will be stored on the Device for future identification by its.

3.2. The Cookies are employed to assess the efficiency of websites or mobile applications, including the Services as gauging visitor numbers and duration of the Service usage by the User. They help identify popular topics and pages or the Services, facilitating user-friendly navigation and usage of the website or Services, all while refraining from gathering the Personal Data. Additionally, cookies can personalize the User experience based on past interactions with the Adslab and preferences, leading to an enhanced experience over time.

3.3. The User will be informed about the use of cookie files during their first access to the Adslab Services and/or first visiting of the Adslab website. If the User is against the collection of information using cookie files, they can configure their preferences at any time through the Cookie Settings Centre on their Device.

3.4. The Device provides to the Users with the ability to manage cookie files in accordance with their preferences. The User can manage and/or delete, restrict, or block cookie files at any time by modifying their browsers or the Device configuration. If the User does not wish to use cookie files, they should first disable cookie files in their browser or the Device. Disabling cookies could lead to the inability to access the Services.

3.5. The Adslab may collect or acquire User information from alternative origins, such as third-party applications like app stores, third-party login services, and social networks where the User has access to the Services. This data may be utilized by the Adslab in conjunction with information directly provided by the User to the Adslab for various purposes outlined in this Privacy and Confidentiality Policy, such as facilitating connections between the User and their friends or delivering personalized advertising based on the User interests and so on.


4. COLLECTION AND PROCESSING OF PERSONAL DATA

4.1. The Adslab collects the Personal Data in the following cases:
- when the User visits the Adslab website or has access to the Services;
- when the User subscribed to newsletters of the Adslab;
- when the User contacts the Adslab with the Devices, including through messengers, email, website chat, or social media;
- the Adslab may obtain the Personal Data when the User interacts with the official Adslab pages on social media platforms by clicking buttons such as "like", "follow", or through other means of interaction.


5. DATA COLLECTION AND PROCESSING PURPOSES OF PERSONAL DATA

5.1. The Adslab processing the User's Personal Data for the following purposes:

5.1.1. Contractual purposes:
- to enter into contracts, contractual information about the individual, namely: name and surname, phone number, email, and delivery address;
- to perform, manage, and ensure the fulfillment of the Services, including any related contracts, additional documents such as appendices, amendments, etc.;
- to share the Personal Data with partners to provide access to the Services or the Adslab website;
- to manage payments or fees and charges;
- to inform the User about changes/additions to all Services or products offered or sold by the Adslab, as well as the Privacy and Confidentiality Policy.

5.1.2. Legal purposes:
- for statistics, market analysis, and research;
- to analyze and improve the products and the Services of Adslab;
- to notify the User's Personal Data to authorized state authorities in accordance with the legislation;
- to support the business processes of the Adslab;
- to monitor, check, and record communication between the User and the Adslab;
- from time to time, to send the User marketing information, useful information, newsletters, new offers, working hours of the Adslab;
- to inform the User of the results of claims consideration (if applicable);
- to inform about the contact person of the Adslab who will communicate with the User;
- for the purpose of enabling the conduct of various promotions, programs, loyalty systems, etc., including registering the User in its own database of persons participating in such promotions, programs, loyalty systems, etc.;
- for the purpose of enabling the User to join various policies, rules, regulations, instructions, etc., regulating the conduct of the Adslab promotions, programs, loyalty systems, etc.;
- for the purpose of informing the User about the procedure for conducting promotions, programs, loyalty systems, etc., organized by the Adslab, as well as informing about changes to policies, rules, regulations, instructions, etc., regulating the conduct of the Adslab promotions, programs, loyalty systems, etc;
- when the Adslab have to disclose the information in response to lawful requests by public authorities;
- to comply with other legal obligations.

5.2. The Adslab shares some of the User's Personal Data with User's friends and other users that the User is interacting with to facilitate Your in-Services interactions.

5.3. The Adslab provides that any third party with whom the Adslab share User's Personal data shall provide the same or equal protection of User's Personal Data as stated in this Privacy and Confidentiality Policy.

5.4. In connection with provision of the Services, the User's Personal Data may be disclosed to external entities, including in particular the payment operators, service providers and vendors responsible for maintenance of IT systems, banks, entities providing accounting services and entities related to the Adslab, including companies from its group. The Adslab may also share the Personal Data with any other corporate entities within the same corporate group (including parent company and subsidiaries) if it is necessary to provide the Services.

5.5. Also, upon User's consent, the Adslab may use and share the User's Personal Data with our partners to tailor the ads to the User's interests.

5.6. In addition, the Adslab may share the Personal Data with other third parties or allow them to collect the User's information from the Services or Adslab websites in some ways not specifically described in this Privacy and Confidentiality Policy if the Adslab have User's consent to do so.

5.7. The Adslab Services encourage the User's to interact with other users. If the User has access to the Services through a social network or connects to a social network (like Facebook), User's friends who also have access to the Services will see name, photo, user profile and descriptions of User's in-Service activity.

5.8. Besides outlined above, in the Adslab Services other users (not being User's friends) will be able to see the User's profile; view descriptions of User's in-Service activity; communicate with the User within Adslab Services and send to the Users certain requests or friend requests through the Services.


6. USER'S RIGHTS

6.1. The User, regarding their Personal Data provided for collection, accumulation, processing, storage, and usage by the Adslab based on the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679) and other data protection law, has the following rights:

- to know the sources of data collection, the location of their Personal Data, the purpose of its processing, and location;
- to receive information about the terms of access to the Personal Data;
- the right to access their Personal Data;
- the right to receive confirmation from the Adslab about the processing of their Personal Data;
- to receive information regarding whether their Personal Data is being processed;
- to make a reasoned request to the Adslab to object to the processing of their Personal Data;
- the right to send a request to the Adslab for the correction or deletion of the Personal Data, or to restrict the processing of the Personal Data about the User and to object to such processing;
- to protect their Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as protection from the provision of information that is inaccurate or harms the honor, dignity, and business reputation of an individual;
- to lodge complaints regarding the processing of their Personal Data with the supervisory authority;
- if the Personal Data is transferred to a third country or an international organization, the data subject (the User) shall have the right to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR regarding data transfers;
- to apply legal remedies in case of violation of the Personal Data protection legislation;
- to make reservations regarding the restriction of the right to process their Personal Data when giving consent;
- to withdraw consent for the processing of the Personal Data;
- to know the mechanism of automated processing of the Personal Data;
- the right to make changes to incomplete or inaccurate the Personal Data;
- the right to delete the Personal Data if the person has successfully exercised their right to object to data processing;
- the right to withdraw consent to the processing of the Personal Data at any time;
- the right to object to the use or processing of the Personal Data by Adslab if the person believes it affects their rights and freedoms.

6.2. To exercise the rights described above, it is necessary to contact Adslab at the email address: dev@adslab.media. If the Adslab receives a request from the User to exercise any of the rights mentioned above, the Adslab may request the User to confirm their identity before taking action on the request. This is necessary to ensure the protection and security of the Personal Data.


7. TRANSFER AND DISCLOSURE OF USER'S PERSONAL DATA

7.1. The Adslab does not transfer or disclose any Personal Data about the User without their consent, except for the purposes mentioned in this Privacy and Confidentiality Policy, or when required by law.

7.2. The Adslab may use third-party services to provide access to the Services with the User. All processors acting on behalf of Adslab process the User data only in accordance with the Adslab instructions and strictly adhere to this Privacy and Confidentiality Policy, cookie files and European Union legislation.

7.3. The Adslab may transfer the User's Personal Data outside the European Union in accordance with the obligations of this Privacy and Confidentiality Policy and the law, in the following cases:

- the European Commission or another authorized authority has determined that the destination country ensures an adequate level of personal data protection;
- the Service provider, in accordance with this Privacy and Confidentiality Policy, is bound by specific and appropriate contractual obligations required by applicable data protection laws.


8. U.S. RESIDENTS SUPPLEMENT

8.1. The Adslab treats all Users the same. This section, however, specifically provides additional information on how the Adslab collects, use, disclose and otherwise process the Personal Data of Users who are individual residents of the United States of America.

8.2. Terms in this section mean the same as they are defined elsewhere in this Privacy and Confidentiality Policy.

8.3. The Adslab Services may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User ("personal information") as specified below.

8.4. The Personal Data does not include publicly available information, or deidentified or aggregated the User information.

8.5. The Adslab DOES NOT (i) sell Personal Data; (ii) knowingly collect, sell or share personal information of Users under 13 years of age; (iii) collect, sell, disclose or share sensitive personal information. By sensitive personal information means data on race or ethnic origin, religious beliefs, genetic data, biometric data, health data, sexual orientation, philosophical beliefs and the contents of a consumer's (User's) mail, email, text messages that are not directed to us, and Personal Data from a known child under 13 years of age.

8.6. The Adslab may collect the following categories of information about the User:

- identifiers, for example: real name, alias, postal address, unique personal identifier, online or advertising identifier (ex. device numbers, ADFA, GAAID etc.), IP address, device or WiFi location;
- the User records, for example: mailing address and telephone number;
- protected classifications, for example: age, gender;
- commercial or transaction information, for example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, for example browsing history, search history, and information regarding the User's interaction with an Internet website, application, or advertisement;
- geolocation data, for example IP address.

8.7. The Adslab obtains the categories of the Personal Data listed above from the following categories of sources:
- directly from the User, for example, from User's completed form or products and the Services User purchase;
- indirectly from the User, for example, from the User's access to the Services;
- third parties, for example the Adslab payment provider or social media.

8.8. The Adslab uses the Personal Data collected above for the following business purposes:
- providing access to the Services, including improvements and support;
- complying with the laws (tax and accounting obligations with respect to the Services);
- protecting the safety and security of the Services;
- protecting the Adslab rights and property in connection with the Services, to enforce the terms of the Services;
- preventing fraud or potentially illegal activities;
- managing and delivering marketing activities and some advertising activities;
- research and development of the Services (including game and feature development, improvement, optimization and refinement).

8.9. The Adslab may share the User's Personal Data by disclosing it to a third party for a business purpose. The Adslab only makes these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Data confidential, and prohibit using the disclosed information for any purpose except performing the contract.

8.10. The Adslab may share the Personal Data for a business purpose to the following categories of recipients:

- entities within the Adslab group;
- specific professional services providers such as cloud-based software providers, storage providers, security providers, legal advisors;
- payment processors/payments services providers;
- advertising and marketing partners;
- as required by law.

8.11. The Adslab does not sell the Personal Data of U.S. Users to third parties, regardless of the User's age.

8.12. The User as a U.S. resident, just as all other users of the Services, have certain rights regarding User's Personal Data.

8.13. The User's right to Opt-out of "Sale"/"Sharing" of the Personal Data. The Adslab does not currently consider the ways the Adslab shared the Users' Personal Data in the past 12 months to comprise the "sale" of the Personal Data.

8.14. Right to limit use of sensitive Personal Data. The Adslab does not collect sensitive Personal Data nor do the Adslab use sensitive Personal Data for the purpose of inferring characteristics about an individual, therefore Adslab does not offer a path to exercise this right.

8.15. The User have the right to opt out of the processing of the User's Personal Data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.

8.16. Right to appeal any decision or indecision related to the exercise of any right granted to the User under the applicable law. Instructions for how to submit the User appeal will be included in our response explaining why the Adslab denied the User's request.

8.17. Right to access. The User have the right to confirm whether the Adslab ais processing the User Personal Data and access such Personal Data.

8.18. Right to not be discriminate. The right to not be discriminated against for exercising these rights. Of course, if User does exercise any of its rights, the Adslab will not treat the User any differently.

8.19. Users who are residents of California may request:

- a list of the categories of the Personal Data disclosed by the Adslab to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes;
- a list of the categories of third parties to whom the Adslab disclosed such information.

8.20. How to exercise the User's rights. Please see section 6 above for a detailed description of how to contact Adslab.


9. DATA SECURITY

9.1. The Adslab complies with international security standards and store the Personal Data on secure servers. All Personal Data shall be treated as confidential information by those who have access to it. In addition, the Adslab restricts access to the Personal Data to only those persons who should have such access. On an ongoing basis, it conducts audits and internal controls to ensure that the measures in place are adequate and ensure compliance with international security standards and internal procedures.

9.2. Where the Adslab uses security features such as a password (or where the User uses such an option) to access any Services, the User shall keep such password confidential and shall not disclose it to any third party.

9.3. Unfortunately, the transmission of information via Internet links is not completely secure. Thus, although the Adslab takes the utmost care to protect the User's Personal Data, it cannot guarantee the security of the Personal Data transmitted via our websites, the Devices, mobile apps or the Services – any such transmission is at the User's risk. When receiving information from User, the Adslab makes every effort to ensure compliance with procedures and the application of safeguards against unauthorized access.


10.PROTECTION MEASURES FOR USER'S PERSONAL DATA

10.1. The Adslab takes measures to ensure the protection and security of the the User's Personal Data at all stages of processing, including through organizational and technical measures.

10.2. The Adslab takes all necessary measures to prevent accidental loss, use, or unauthorized access, alteration, or disclosure of the User's Personal Data.

10.3. The Adslab implements a process for addressing security breaches of the Personal Data or incidents and will inform the User and any relevant regulatory authority of a suspected breach or incident if the Adslab is required to do so by law.

10.4. If the Adslab implements a process for addressing security breaches of the Personal Data or incidents and will inform the User and any relevant regulatory authority of a suspected breach or incident if the Adslab is required to do so by law.

10.5. During transferring of the User's Personal Data, the Adslab" will require third parties to take measures to protect the Personal Data. The Adslab does not grant any rights to third parties to use the Personal Data for their own purposes. The third party may use the User's Personal Data for specific purposes and in accordance with the Adslab instructions.


11.ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA

11.1. The Adslab is not obligated to provide the User's Personal Data to third parties without the User's consent, except for the purposes mentioned in this Privacy and Confidentiality Policy or when required by law.

11.2. The Adslab retain the Personal Data only for as long as necessary. When retaining the Personal Data, the Adslab takes into account the following:
- the duration of the purposes for which the Adslab collect the Personal Data and the duration during which the Adslab is required to provide services or sell products;
- ensuring and managing the relationship between the Adslab and the User;
- the Adslab also retain the User's Personal Data to comply with regulatory requirements, accounting requirements, reporting and legal requirements, or instructions.

11.3. Processing is lawful only if the data subject (the User) has given consent to the processing of their Personal Data for one or more specific purposes. According to Article 8 (1) of the GDPR, the processing of the Personal Data of a child is lawful if the child is at least 16 years old. If the child is under the age of 16, such processing is only lawful if consent is given by the child's parents or by the person who holds parental responsibility for the child.

11.4. The Adslab Services and websites may contain links to other websites. However, if the User uses these links, the User should be aware that the Adslab does not control these websites. Therefore, the Adslab is not responsible for the protection and confidentiality of any information the User provides while visiting such websites, and these websites are not governed by this Privacy and Confidentiality Policy. The User should exercise caution and review the policy applicable to the respective website.


12. ADDITIONAL TERMS

12.1. The Adslab reserves the right to make changes to the Privacy and Confidentiality Policy without the User's consent by notifying the User at least 30 (thirty) calendar days before the changes take effect. Changes to the Privacy and Confidentiality Policy are made by posting the new current version of the Privacy and Confidentiality Policy at the following link: https://adslab.media/privacy-policy. The current and effective version of the Privacy and Confidentiality Policy can always be found at the same link.

12.2. The new Privacy and Confidentiality Policy comes into effect from the moment it is posted on the Adslab website, unless otherwise specified in the new version of the Privacy and Confidentiality Policy.

12.3. In the event of changes that significantly affect the User's privacy rights, the Adslab will send additional notice to the User by email. If the User does not agree with the changes to this Privacy and Confidentiality Policy, it is necessary to contact the Adslab at the email address: dev@adslab.media.

12.4. In case of disagreement with any changes made to the Privacy and Confidentiality Policy, the User should cease using the Services or the Adslab website and has the right to request that the Adslab delete their Personal Data. If the Adslab has not received a refusal from the User regarding the new version of the Privacy and Confidentiality Policy, this means that the User has agreed to the new version of the Privacy and Confidentiality Policy.

12.5. The User (for citizens of the European Union) may file a complaint about violations by the Adslab under the General Data Protection Regulation, GDPR; Regulation (EU) 2016/679 with the court or with the European Data Protection Supervisor. The contact details of the aforementioned supervisor can be found at the following link: https://edps.europa.eu/about-edps/contact_en.