PRIVACY AND COOKIE POLICY

PRIVACY POLICY

The information our AGENCY Collect

Information AGENCY collect falls into two categories: “voluntarily provided” information and “automatically collected” information. 

“Voluntarily provided” refers to any information you knowingly and actively provide us when using or participating in our services, WORK, and promotions. 

“Automatically collected” information refers to any information automatically sent by your devices while accessing our products and services. 

Log Data

When you visit our websites, our servers may automatically log the standard data your web browser provides. It may include your device’s Internet Protocol (IP) address, browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit. 

Additionally, if you encounter certain errors while using the sites, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you tried to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even when they occur, that they have occurred, or the nature of the error. 

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to identify individual persons personally. 

Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

• Device Type
• Operating System
• Unique device identifiers
• Device settings
• Geo-location data

The data we collect can depend on the individual settings of your device and software. We recommend checking your device manufacturer’s or software provider’s policies to learn what information they make available to us.

Personal Information

We may ask for personal information — for example, when you subscribe to our newsletter or when you contact us – which may include one or more of the following:

• Name
• Email
• Phone/mobile number

Sensitive Information

“Sensitive information” or “special categories of data” is a subset of personal information given higher protection. Examples of sensitive information can inc, lude but are limited to, information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information, or biometric information.

The types of sensitive information that we may collect about you include:

We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorized by law.

User-Generated Content

We consider “user-generated content” materials (text, image, and video) voluntarily supplied by our CLIENT for publication, processing, or usage on WORK. All user-generated content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.

Transaction Data

Transaction data refers to data that accumulates over the normal course of operation on our services and WORK. This may include but is not limited to payment records, stored files, user profiles, analytics data, other metrics, and other types of information created or generated as users interact with our services.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information for a legitimate reason. In this instance, we only collect personal information that is reasonably necessary to provide our WORK to you.

Collection and Use of Information

We may collect personal information from CLIENT when you do any of the following on our website:

• Register for an account
• Enter any of our competitions, contests, sweepstakes, and surveys
• Sign up to receive updates from us via email or social media channels
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or any similar technologies
• When the CLIENT mentions us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide CLIENT with our client’s platform’s core features and services
• to enable the CLIENT to customize or personalize the experience of our websites
• To contact and communicate with you
• for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
• For advertising and marketing, we include sending CLIENT promotional information about our products and services and information about third parties that we consider of interest to CLIENT.
• to consider employment application
• to enable CLIENT to access and use our website, associated applications, and platforms
• for internal record-keeping and administrative purposes
• To run competitions sweepstakes and offer additional benefits to the CLIENT
• To comply with our legal obligations and resolve any disputes that we may have
• To attribute any content (e.g., posts and comments) you submit that we publish
• For security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
• For technical assessment, including operating and improving our WORK, associated applications, and associated marketing platforms

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you provide us with your location, we may combine this with general information about currency and language to provide CLIENT with an enhanced experience of our sites, services, and WORK.

Security of CLIENT Personal Information

We only collect and use your personal information for a legitimate reason. In this instance, we only collect personal information that is reasonably necessary to provide our WORK to the CLIENT.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long AGENCY Keep CLIENT Personal Information

We keep CLIENT personal information only for as long as we need to. This period may depend on what we use your information for by this privacy policy. For example, if you have provided us with personal information as part of creating a client account, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information to comply with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, historical research, or statistical purposes.

Children’s Privacy

We do not aim any of our WORK or services directly at children under 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary, or affiliate of our company
• third-party service providers to enable them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
• our employees, contractors, and related entities
• our existing or potential agents or business partners
• Sponsors or promoters of any competition, sweepstakes, or promotion we run
• Credit reporting agencies, courts, tribunals, and regulatory authorities if you fail to pay for goods or services we have provided you.
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings or to establish, exercise, or defend our legal rights
• Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
• third parties to collect and process data
• An entity that buys or to which we transfer all or substantially all of our assets and business

Third parties we currently use include but are not limited to:

• Google Analytics
• Microsoft Clarity
• Kreston BulMar
• PlayBook
• Gmail

International Transfers of Personal Information

The personal information we collect is stored and processed in Bulgaria, where our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) We will perform those transfers according to the requirements of applicable law, and (ii) We will protect the transferred personal information by this privacy policy.

Your Rights and Controlling Your Personal Information

CLIENT choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information by this privacy policy. CLIENT does not have to provide personal information to us; however, if the CLIENT does not, it may affect your use of our website or the products and WORK offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission: If the CLIENT has previously agreed to use your personal / company information for direct marketing purposes, you may change your mind by contacting us using the details below.

Access: You may request details of the personal information we hold about you.

Correction: If you believe that any information we hold about CLIENT is inaccurate, out of date, incomplete, irrelevant, or misleading, don’t hesitate to get in touch with us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against CLIENT for exercising any of the CLIENT’S rights over your personal information. Unless your personal information is required to provide you with a particular WORK or offer (for example, processing transaction data), we will not deny you goods or services and charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties, or provide you with a different level or quality of goods or WORK.

Notification of data breaches: We will comply with laws applicable to AGENCY regarding data breaches.

Complaints: If CLIENT believes that AGENCY has breached a relevant data protection law and wishes to make a complaint, please get in touch with us using the details below and provide AGENCY with full details of the alleged breach. AGENCY will promptly investigate your complaint and write to you, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority about your complaint.

Unsubscribe: To unsubscribe from our email database or opt out of communications (including marketing communications), please contact AGENCY using the details provided in this privacy policy or opt-out using the opt-out facilities provided in the communication. AGENCY may need to request specific information to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about CLIENT and all website VISITORS and activity across our sites. A cookie is a small piece of data that our website stores on your computer and accesses each time you visit so AGENCY can understand how you use our sites. This helps AGENCY serve CLIENT content based on preferences you have specified.

Please refer to the AGENCY Cookie Policy for more information.

Business Transfers

If AGENCY or our assets are acquired, or in the unlikely event that AGENCY goes out of business or enters bankruptcy, AGENCY would include data, including CLIENT personal information, among the assets transferred to any parties who acquire us. CLIENT acknowledges that such transfers may occur and that any parties who acquire AGENCY may, to the extent permitted by applicable law, continue to use CLIENT’s personal Information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such Information.

Limits of Our Policy

Our websites and WORK may link to external sites that AGENCY does not operate. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At AGENCY’s discretion, we may change our privacy policy to reflect updates to AGENCY business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which CLIENT is accessing this privacy policy.

If the changes are significant, or if required by applicable law, AGENCY will contact CLIENT (based on CLIENT selected preferences for communications from us), and all AGENCY registered users with the new details and links to the updated or changed policy.

If required by law, we will get CLIENT permission or allow CLIENT to opt in to or opt out of, as applicable, any new uses of your personal Information.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal Information for their purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, the AGENCY, located at the address provided in our Contact Us section, are a Data Controller and Processor concerning the personal information CLIENT provides us.

Legal Bases for Processing CLIENT Personal Information

AGENCY will only collect and use CLIENT personal information when we have a legal right to do so. In this case, AGENCY will collect and use the CLIENT’s personal Information lawfully, fairly, and transparently. We seek CLIENT’s consent to process CLIENT’s personal Information.

AGENCY’s lawful bases depend on the services and WORK that CLIENT uses and hires us and how CLIENT uses them. This means AGENCY only collects and uses CLIENT information on the following grounds:

Consent From CLIENT

Where CLIENT gives us consent to collect and use CLIENT’s personal Information for a specific purpose, CLIENT may withdraw their consent at any time using the facilities AGENCY provides; however, this will not affect any use of your Information that has already taken place. CLIENT may consent to provide CLIENT’s name and contact details to enter a giveaway or promotion. While CLIENT may withdraw his/her/company entry at any time, this will not affect any selection or judging that has already taken place. If the CLIENT has any further inquiries about how to withdraw his/her/company consent, please ask using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where CLIENT has entered into a contract or transaction with us, or to take preparatory steps before AGENCY enters into a contract or transaction with CLIENT. For example, if CLIENT purchases a product, service, WORK, or goods from us, AGENCY may need to use CLIENT’s personal and payment Information and deliver the order.

Our Legitimate Interests

Where AGENCY assesses it is necessary for AGENCY’s legitimate interests, such as for AGENCY to provide, operate, improve, and communicate AGENCY’S services. AGENCY considers our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures to operate our services efficiently, marketing analysis, and measures to protect AGENCY’s legal rights and interests.

Compliance with Law

In some cases, the AGENCY may legally be obligated to use or keep the CLIENT’s personal Information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If the CLIENT has any further inquiries about how AGENCY retains personal Information by law, please ask using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

AGENCY will ensure that any transfer of personal information in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example, by using standard data protection clauses approved by the European Commission or the use of binding corporate rules or other legally accepted means.

CLIENT rights in controlling the Personal Information

CLIENT has the right to request that AGENCY restrict the processing of CLIENT’s personal Information if

1. CLIENT is concerned about the accuracy of your information and believes the Personal Information was unlawfully processed;
2. CLIENT needs AGENCY to maintain the personal information a legal claim or
3. AGENCY is considering CLIENT’s objection to processing based on legitimate interests.

Objecting to processing: 

CLIENT has the right to object to processing his/her Information regarding our legitimate interests or public interest. If this is done, AGENCY must provide compelling, legitimate grounds for the processing that override CLIENT’s interests, rights, and freedoms to proceed with processing CLIENT’s personal Information.

Data portability: 

CLIENT may have the right to request a copy of the personal informant information about them. AGENCY will provide this Information in other easily readable machine formats. CLIENT may also have the right to request that AGENCY transfer this personal information party.

Deletion: 

CLIENT may have a right to request that AGENCY delete the personal Information about him/her at any time, and AGENCY will take reasonable steps to delete CLIENT’s personal Information from AGENCY’s current records. If the CLIENT asks our AGENCY to delete his/her Information, Information will let the CLIENT know how the deletion affects the CLIENT’s use of our website or products and WORK. There may be exceptions to this right for specific legal reasons which, if applicable, AGENCY will set out for CLIENT in response to his/her request. If CLIENT terminates or deletes his/her account or stops working with AGENCY, AGENCY will delete CLIENT’s personal Information within 60 days. Please be aware that search engines and similar third parties may retain copies of CLIENT’s personal Information that has been made public at least once, like certain profile information and public comments, even after CLIENT has deleted the information services.

Cookies and Pixels

At all times, cookies may be declined from AGENCY’S sites if the browser permits. Most browsers allow activation of settings to refuse all or some cookies. Accordingly, the ability to limit cookies is based only on the browser’s capabilities. Please refer to the Cookies section of this privacy policy for more Information.

CCPA-permitted financial incentives

By the CLIENT’s right to non-discrimination, we may offer the CLIENT certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the WORK we provide.

Any CCPA-permitted financial incentive AGENCY offer will reasonably relate to the value of CLIENT’s personal information, and AGENCY will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires the CLIENT’s prior opt-in consent, which the CLIENT may revoke at any time.

California Notice of Collection

In the past 12 months, AGENCY has collected the following categories of personal information enumerated in the California Consumer Privacy Act:

• Identifiers include name, email address, phone number, account name, IP address, and an ID or number assigned to the CLIENT account.
• Customer records, such as billing and shipping address.
• Geolocation data.

Review the “Information the We Collect” section on AGENCY collect. AGENCY collects and uses these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our WORK.

Right to Know and Delete

If the CLIENT is a California resident, the CLIENT has the right to delete the personal information AGENCY collected and know certain information about our data practices in the preceding 12 months. In particular, the CLIENT has the right to request the following from us:

• The categories of personal information AGENCY has collected about CLIENT;
• The categories of sources from which the personal information was collected;
• The categories of third parties to whom the personal information was disclosed;
• The business or commercial purpose for collecting or selling the personal information; and
• AGENCY has collected specific pieces of personal information about the CLIENT.

To exercise any of these rights, please get in touch with us using the details provided in this privacy policy.

Shine the Light

If the CLIENT is a California resident, in addition to the rights discussed above, CLIENT has the right to request information from us regarding how we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Contact Us

For any questions or concerns regarding privacy, CLIENT may contact AGENCY using the following details:

AdwayCreative, Bulgaria, 1 Vitosha Blvd., fl. 3, email: [email protected]

COOKIE POLICY

We use cookies to help improve your experience of our website. This cookie policy is part of AdwayCreative privacy policy. It covers the use of cookies between the CLIENT device and our sites.

We also provide basic information on third-party services AGENCY may use, who may also use cookies as part of their service. This policy does not cover their cookies.

If CLIENT doesn’t wish to accept cookies from us, CLIENT should instruct their browser to refuse cookies from clients.adwaycreative.com, adwaycreative.com, and adwaycreative.eu, adwaycreative. Bg. In such a case, AGENCY may be unable to provide CLIENT with some desired content and WORK.

What is a cookie?

A cookie is a small piece of data that a website stores on your device when you visit. It typically contains information about the website itself, a unique 

identifier that allows the site to recognize your web browser when you return, additional data that serves the cookie’s purpose, and the cookie’s lifespan.

Cookies are used to enable certain features (e.g., logging in), track site usage (e.g., analytics), store your user settings (e.g., time zone, notification preferences), and personalize your content (e.g., advertising, language).

Cookies set by the website you visit are usually called first-party cookies. They typically only track your activity on that particular site.

Cookies set by other sites and companies (i.e., third parties) are called third-party cookies. They can be used to track you on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing.

AGENCY uses essential cookies to enable certain functions on AGENCY’S websites.

Performance cookies

Performance cookies track the website usage during your visit. Typically, this information is anonymous and aggregated, with information tracked across all site users. They help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or third-party services. They do not collect personal information.

AGENCY uses performance cookies on AGENCY’S sites.

Functionality cookies

Functionality cookies are used to collect information about the device and any settings. CLIENT may configure on the websites (like language and time zone settings). This information lets websites provide customized, enhanced, or optimized content and services. These cookies may be set by the website (first-party) or by third-party services.

AGENCY uses functionality cookies for selected features.

Targeting/advertising cookies

Targeting/advertising cookies help determine the most relevant and appropriate promotional content according to the interests. Websites may use them to deliver targeted advertising or limit the number of times for advertisements to show. This helps companies improve their campaigns’ effectiveness and content quality. These cookies may be set by the website (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track other websites that use the same third-party service.

AGENCY uses targeting/advertising cookies occasionally.