PRIVACY POLICY

Information our AGENCY Collect

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

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

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our websites, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your 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 were trying 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 in the moment they occur, that they have occurred, or what the nature of the error is.

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 personally identify individual persons.

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

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider 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 that is given a higher level of protection. Examples of sensitive information can include but 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” to be materials (text, image and/or video content) voluntarily supplied to us by our CLIENT for the purpose of 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 the purpose of 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 not limited to payments records, stored files, user profiles, analytics data and other metrics, as well as 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 when we have a legitimate reason for doing so. In which 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 on any similar technologies
• When CLIENT mention 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 clients platform’s core features and services
• to enable the CLIENT to customize or personalize 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, including to send to CLIENT promotional information about our products and services and information about third parties that we consider may be of interest to CLIENT
• to consider employments 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/or 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 to operate and improve 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 when we have a legitimate reason for doing so. In which 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 own 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 time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an 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 for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy

We do not aim any of our WORK or services directly at children under the age of 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 for the purpose of enabling 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/or 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, in the event you fail to pay for goods or services we have provided to you
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order 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 includes but not limited to:

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

International Transfers of Personal Information

The personal information we collect is stored and/or processed in Bulgaria, or where we or 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 in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with 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 in accordance with this privacy policy. CLIENT do not have to provide personal information to us, however, if the CLIENT do not, it may affect your use of our website or the products and/or 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 have previously agreed to us using your personal / company information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

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

Correction: If you believe that any information we hold about CLIENT is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact 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/or 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 in respect of any data breach.

Complaints: If CLIENT believe that AGENCY have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide AGENCY with full details of the alleged breach. AGENCY will promptly investigate your complaint and respond to you, in writing, 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 in relation to 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 from you 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 AGENCY Cookie Policy for more information.

Business Transfers

If AGENCY or our assets are acquired, or in the unlikely event that AGENCY go out of business or enter bankruptcy, AGENCY would include data, including CLIENT personal information, among the assets transferred to any parties who acquire us. CLIENT acknowledge that such transfers may occur, and that any parties who acquire AGENCY may, to the extent permitted by applicable law, continue to use CLIENT 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 are not operated by AGENCY. 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 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 give CLIENT the opportunity 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 own 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/or Processor with respect to the personal information CLIENT provide to 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 which case, AGENCY will collect and use CLIENT personal information lawfully, fairly, and in a transparent manner. We seek CLIENT consent to process CLIENT personal information.

AGENCY lawful bases depend on the services and WORK, CLIENT use and hire us and how CLIENT use them. This means AGENCY only collect and use CLIENT information on the following grounds:

Consent From CLIENT

Where CLIENT give us consent to collect and use CLIENT personal information for a specific purpose. CLIENT may withdraw their consent at any time using the facilities AGENCY provide; however this will not affect any use of your information that has already taken place. CLIENT may consent to providing CLIENT name and contact details for the purpose of entering 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 CLIENT have any further enquiries about how to withdraw his/her/company consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where CLIENT have entered into a contract or transaction with us, or in order to take preparatory steps prior to AGENCY entering into a contract or transaction with CLIENT. For example, if CLIENT purchase a product, service, WORK, or goods from us, AGENCY may need to use CLIENT personal and payment information in order to process and deliver the order.

Our Legitimate Interests

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

Compliance with Law

In some cases, AGENCY may have a legal obligation to use or keep CLIENT personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If CLIENT have any further enquiries about how AGENCY retain personal information in order to comply with the law, please feel free to enquire 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 from countries 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

Restrict:

CLIENT have the right to request that AGENCY restrict the processing of CLIENT personal information if (i) CLIENT are concerned about the accuracy of your personal information; (ii) CLIENT believe the personal information has been unlawfully processed; (iii) CLIENT need AGENCY to maintain the personal information solely for the purpose of a legal claim; or (iv) AGENCY is in the process of considering CLIENT objection in relation to processing on the basis of legitimate interests.

Objecting to processing:

CLIENT have the right to object to processing of his/her personal information that is based on our legitimate interests or public interest. If this is done, AGENCY must provide compelling legitimate grounds for the processing which overrides CLIENT interests, rights, and freedoms, in order to proceed with the processing of CLIENT personal information.

Data portability:

CLIENT may have the right to request a copy of the personal information we hold about him/her. Where possible, AGENCY will provide this information in CSV format or other easily readable machine format. CLIENT may also have the right to request that AGENCY transfer this personal information to a third party.

Deletion:

CLIENT may have a right to request that AGENCY delete the personal information we hold about him/her at any time, and AGENCY will take reasonable steps to delete CLIENT personal information from AGENCY current records. If CLIENT ask our AGENCY to delete his/her personal information, AGENCY will let CLIENT know how the deletion affects CLIENT 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 terminate or delete his/her account or stop working with AGENCY, AGENCY will delete CLIENT personal information within 60 days. Please be aware that search engines and similar third parties may still retain copies of CLIENT personal information that has been made public at least once, like certain profile information and public comments, even after CLIENT have deleted the information from AGENCY services.

Cookies and Pixels

At all times, cookies may be declined from AGENCY’S sites if browser permits. Most browsers allows 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

In accordance with the CLIENT right to non-discrimination, we may offer 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 personal information, and AGENCY will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires CLIENT prior opt-in consent, which the CLIENT may revoke at any time.

California Notice of Collection

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

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

For more information on information AGENCY collect, review the “Information We Collect” section. AGENCY collect and use 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, CLIENT have rights to delete his/her personal information AGENCY collected and know certain information about our data practices in the preceding 12 months. In particular, CLIENT have the right to request the following from us:

• The categories of personal information AGENCY have 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
• The specific pieces of personal information AGENCY have collected about CLIENT.

To exercise any of these rights, please contact 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 have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own 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 the privacy, CLIENT may contact AGENCY using the following details:

AdwayCreative, Bulgaria, 1 Vitosha Blvd. , fl. 3, email: talk@adwaycreative.com

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 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 don’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 of 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 lifespan of the cookie itself.

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 to personalize your content (e.g. advertising, language).

Cookies set by the website you are visiting are usually referred to as 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 use essential cookies to enable certain functions on AGENCY’S websites.

Performance cookies

Performance cookies tracks the websites 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 by third-party services. They do not collect personal information.

AGENCY use 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). With this information, websites can provide customized, enhanced, or optimized content and services. These cookies may be set by the website (first-party) or by third-party services.

AGENCY use functionality cookies for selected features.

Targeting/advertising cookies

Targeting/advertising cookies help determine what promotional content is most relevant and appropriate according to the interests. Websites may use them to deliver targeted advertising or limit the number of times for advertisement to show. This helps companies improve the effectiveness of their campaigns and the quality of content presented. 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 on other websites that use the same third-party service.

AGENCY use targeting/advertising cookies occasionally.