This Privacy Policy specifies how AdSpawn, registered as AdSpawn s. r. o., ID no. 55 825 061, VAT ID SK2122114093, with its registered office in Bratislava, Slovak Republic, registered in the Commercial Register of the Municipal Court Bratislava III, Section Sro, File no. 173916/B (“we”, “us”, “our”, “Company”, “Controller”), processes personal data, provided in connection with the use of our website https://adspawn.io (“Platform”) and the services our Company provides (“Services”).

We respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you, including your personal data, and we aim to process it lawfully, fairly, and in a transparent manner in accordance with the applicable law, in particular with the General Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data, and repealing Directive 95/46/EC (“GDPR”), Act no. 18/2018 Coll. on the Protection of Personal Data and the Amendment and Supplementation of Certain Laws, as amended, and Act no. 452/2021 Coll. on the Electronic Communications, as amended. This information on the processing of personal data is provided in accordance with Articles 13 and 14 of GDPR.

This Privacy Policy supplements the Terms of Services governing the use of our Platform and the Services we provide (“Terms”). Any terms used and not defined herein shall have the meaning assigned to them in the Terms.

Personal data processed

When using our Platform or Services, primarily when registering and opening the Account, you may voluntarily provide us with personal data that is further processed by our Company, such as your name, e-mail address, IP address and user agent.

Users who communicate the personal data of a third party will have to confirm that they hold the consent of this third party regarding the exploitation by the Platform, the publication, and/or the diffusion on the Platform of these data.

Purpose of the personal data processing

The personal data are processed by our Company for the following purposes:

• Registration (opening of the Account) and user authentication;
• Provision of the Services offered by our Company;
• Analysis of the Account to provide personalized and satisfactory Services, ensuring the customer relationship, setting up surveys of satisfaction and/or evaluation of the Services;
• Provision of support tools adapted to meet the needs of users;
• Ensuring the security of the platform, detect and prevent fraud, and protect against unauthorized access or use of user accounts.
• Improvement of the quality of the Platform, the Services, and the functionality of the Services;
• Platform management, user operations, user rights requests (right of access, rectification, deletion, opposition, limitation, and portability), litigation and litigation related to the use of the Platform and the Services;
• Performing technical operations for commercial purposes relating to prospecting and solicitation, user selection to perform prospecting and loyalty actions, enrich user data;
• Development of trade statistics and organization of promotional operations;
• Interaction with social networks;
• Broadcast of newsletters and communications for commercial purposes;
• Collection of opinions and comments of users;
• Marketing, advertising, and promotion of the Company, internal and external communication of the Company.

In addition, AdSpawn.io may also likely use the data collected to meet its legal and/or regulatory obligations.

Legal basis of the personal data processing

The legal basis for processing the personal data is the performance of the Agreement concluded with our Company that you entered into under the Terms by using our Platform and Services. In some cases, the processing of personal data may be necessary for compliance with a legal obligation to which our Company is subject or for the purposes of the legitimate interests pursued by our Company, for instance, fraud prevention, analytics, and security of our Platform.

In the case of processing of personal data on the legal basis under Article 6(1)(b) GDPR (performance of a contract), the provision of personal data and their processing by the Controller is necessary for the performance of the contract (if you do not provide the personal data, the Controller will not be able to perform the contract).

In the case of processing of personal data on the legal basis under Article 6(1)(c) GDPR (compliance with a legal obligation), the processing of personal data by the Controller is necessary for compliance with a legal obligation of the controller arising from generally applicable law.

In the case of processing of personal data on the legal basis under Article 6(1)(f) GDPR (legitimate interests), you are not obliged to provide your personal data and you are entitled to object to the processing of your personal data (in the event that you exercise your right to object to the processing of your personal data, the Controller will no longer process your personal data unless there is a compelling legitimate grounds for continuing to do so).

In the case of processing of personal data on the legal basis under Article 6(1)(a) of the GDPR (consent), you are not obliged to provide your personal data and, if you have given your consent to the processing of your personal data, you are entitled to withdraw your consent at any time.

Personal data recipients

Exclusively in justified cases and to the extent necessary your personal data are provided to the following recipients:

• Administrator of the Platform and our IT infrastructure;
• Providers of accounting, tax, auditing, legal, or telecommunication services;
• Other service providers mentioned in the Third Parties (e.g. Stripe);
• Public authorities, law enforcement authorities, and courts.

Personal data transfer

Please note that your personal data is not primarily transferred to third countries, such transfers may only occur when using cookies, software, and other solutions from providers located outside the European Economic Area. Therefore, for the purposes of providing you with the Services, we may transfer some of your personal data to third parties, some of which are located outside the European Union or the European Economic Area. In that case, we make sure that they are located in a country considered adequate by the European Union for the protection of personal data. If this is not the case, we require them to commit to implementing equivalent measures to ensure the protection of your personal data.

Our company does not share any of your data with external third parties for the purpose of training AI models.

Third parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Data collection and processing is handled by Hetzner Online GmbH, a hosting company that provides our server infrastructure. The servers are located in Germany, ensuring that all data is stored and processed within the European Union. For more details about the server data policy, please consult Hetzner's Privacy Policy here.

When using any of our paid Services, our third-party payment processor Stripe, Inc. collects and processes your payment-related information, such as your name, e-mail, billing address, credit/debit card or banking information, or other financial information. You may review Stripe's privacy policy either during the checkout process or directly on this link.

For analytical and performance purposes your limited personal information may be processed by Google, Inc. Google handles anonymized and aggregated personal information (such as anonymized tracking identifier and browser information), and it is not combined it with any personally identifiable information. You can learn more about how Google processes data specifically in connection with Google Analytics by visiting this page. You can also opt-out of Google Analytics if you do not wish your website activity to be available to Google Analytics by using the Google Analytics opt-out browser add-on, available at this link.

Users' rights

As a data subject, you have the following rights:

• Right to access your personal data under Article 15 of GDPR;
• Right to rectify your personal data under Article 16 of GDPR;
• Right to erasure of your personal data (the right to be forgotten) under Article 17 of GDPR;
• Right to obtain the restriction of processing of your personal data under Article 18 of GDPR;
• Right to portability of your personal data under Article 20 of GDPR;
• Right to object to the processing of your personal data under Article 21 of GDPR;
• Right to object to automated individual decision-making, including profiling, and the right not to be subject to the respective decision, in case our Company processes the personal data exclusively by automated decision-making, including profiling, under Article 22 of GDPR;
• Right to lodge a complaint with a supervisory authority under Article 77 of GDPR and Section 100 of the Act, it being the Office for Personal Data Protection, ID no. 36 064 220, with its registered office at Hraničná 12, 820 07 Bratislava, Slovak Republic.

You acknowledge that when the personal data breach is likely to result in a high risk to your rights and freedoms, we shall communicate the personal data breach to you without undue delay under Article 34 of GDPR.

Users wishing to assert any of their rights may send their request by e-mail to the following e-mail address: legal@adspawn.io

Upon exercise of any of these rights, you may need to provide us with all elements necessary to your identification, such as your name, e-mail, connection identifier, and possibly mailing address. For security reasons, if you're asking to delete your data, a confirmation e-mail will be sent to the e-mail associated with your Account. Please reply to this e-mail to confirm the deletion process.

In addition to those procedures for deleting stored data, users can also revoke the Service's access to their data via the Google security settings page here.

Contact us

For any questions concerning the processing of your personal data or any remark, request, or complaint concerning your privacy, please contact us:

• by sending an e-mail to legal@adspawn.io; or
• in writing to the address of our Company’s registered office.