PRIVACY POLICY
Last updated: 03.12.2024
This Privacy Notice is developed by KLIM spółka z ograniczoną odpowiedzialnością, a legal entity registered under the laws of Poland, with the regon: 525782192, NIP: 1231536540 registered address: Ul. Kościuszki, Nr 10, Lok. 1, Miejsc. Piaseczno, Kod 05-500, Poczta Piaseczno, Kraj Polska.
Adpay https://adpay.cards/ ("AdPay", "Service", "we" or "us") is committed to protecting the privacy of our customers, and we take our data protection responsibilities very seriously.
This Privacy Notice explains how personal data is collected, processed, used, and disclosed when you use the AdPay Service https://adpay.cards/.
This Privacy Notice is an addition to Our Terms and Conditions and should be read in conjunction with the Terms and Conditions.
1. GENERAL PROVISIONS
1.1. Personal data is data that identifies or relates to an identifiable person. This includes information that you provide to us, information that is collected about you automatically, and information that we receive from third parties.
2. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA
2.1. The processing of the user's data is carried out in accordance with the requirements of the General Data Protection Regulation (GDPR), California Consumer Privacy Act, The Personal Information Protection and Electronic Documents Act (PIPEDA), Lei Geral de Proteção de Dados (LGPD), Australian Privacy Act 1988 and other data protection regulations.
2.2. We collect your personal data directly from you unless it is unreasonable or impracticable to do so. We will not collect more data than it is necessary for us to provide our services and comply with applicable laws. We may collect this information when you:
access or use our website;
register an account on our website;
use our products and services;
contact us directly via any media including SMS, MMS, instant messaging, email, social media platforms, postal mail and telephone;
2.3. We are not responsible for the procedure for obtaining, storing, processing, using, and disclosing the User's Personal Data by third-party enterprises, organizations, and services that are not related to us, and individuals who are not our employees, even if the user has accessed the websites, software, goods or services of these persons through the Service.
2.4. The purpose of obtaining, storing, processing, and using the User's Personal and other data is to protect the interests of the user and the Service, as well as to provide the user with the services, identify the user, and contact the user.
2.5 We retain your personal information for as long as necessary to provide Our services, comply with legal requirements, and for Our legitimate business purposes.
3. THE DATA WE COLLECT AND STORE
3.1. When using the Service, the user shall indicate the username, e-mail address and username in the Telegram messenger. This data is considered the User's Personal Data.
3.2. By giving the Consent to the processing of personal data, the user grants us the right to obtain, store, process and use the information specified in clause 3.1.
3.3. We have the right to store the User's Personal and other data to the extent and for the periods necessary to ensure the appropriate provision of our services to the user, or for the periods established by the current international law, or the legislation of the country of residence or stay of the user, or until the user deletes this data. We may also retain anonymized or aggregated data for statistical or research purposes.
3.4. We do not request additional documents or information from the user, except in the case of compliance with the requirements of anti-money laundering and terrorist financing legislation, at the request of the legal authorities and other third parties parties, when required by law. In this case, we request the following information from the user:
- information on the origin of funds;
- information about the shipping service;
- information about the purpose of the payment;
- screenshots of the output from the sending service interface;
- full names of the parties to the transaction;
- any other information about the transaction and its participants that we or the user believe may be useful.
In this case, the user is obliged to provide us with this information. The Service does not store this information but receives it solely for the purpose of transferring merchandise.
3.5. To the extent permitted by applicable law, we may collect certain types of information automatically, for example, whenever you interact with us or use the services. This information helps us to resolve customer support issues, improve the performance of our sites and services, maintain and/or enhance the user experience, and protect your account from fraud by detecting unauthorized access.
3.6. We may also collect the information from your device, including your Internet Service Provider (IP) address, location, login information, browser type and settings, time zone, operating system, type of device you are using, unique device identifier, screen size, mobile network information, mobile operating system and type of mobile browser you are using, and the date, time and duration of your visit.
3.7. We may receive information from payment systems, payment service providers, card systems, card program managers, public authorities, and law enforcement agencies, as well as from publicly available sources. We will store such information in an appropriate and compliant manner to ensure its security and confidentiality
4. ACCESS TO INFORMATION
4.1 We undertake not to provide Personal Data to third parties for commercial purposes without the consent of the user to whom this data belongs. The transfer of Personal Data to third parties is allowed in the following cases:
- after obtaining the consent of the user to whom this information belongs;
- if it is necessary to transfer Personal Data in order to fulfill the user's request;
- at the reasonable request of legal authorities to receive such data.
4.2. The user agrees, and we have the right to distribute personal data to third parties who fulfill their obligations to provide services on the Service, as well as merchandise in accordance with clause 3.4. of this Privacy Notice. Owners, managers of personal data, and third parties are obliged to ensure the protection of this data from accidental loss or destruction, as well as from unlawful processing.
4.3. The user agrees that the confidentiality of the data transmitted via the Internet is not guaranteed and in the event that access to this data is obtained by third parties outside the area of technical means of communication under our control, we shall not be liable for any damage caused by such access.
4.4. The user has the right to request, change, or delete his/her Personal Data that is in our access unless otherwise provided by law.
5. RIGHTS OF THE PERSONAL DATA SUBJECT
5.1. The user, as a subject of personal data, has the following rights:
to know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give a corresponding order to obtain this information to persons authorized by him/her, except in cases established by law;
to receive information on the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;
access to their personal data;
to receive a response on whether his/her personal data is processed no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, and to receive the content of such personal data;
to submit a request to the personal data controller with an objection to the processing of their personal data;
to submit a reasoned request to change or remove their personal data, in full or in part, by any owner and manager of personal data;
to protect their personal data from unlawful processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity, and business reputation of an individual;
to file complaints against the processing of their personal data with the Commissioner or the court;
to apply legal remedies in case of violation of the applicable legislation on personal data protection;
to make reservations regarding the restriction of the right to process their personal data when giving consent;
to withdraw consent to the processing of personal data;
to know the mechanism of automatic processing of personal data;
to be protected against an automated decision that has legal consequences for him/her.
6. PROTECTION OF PERSONAL DATA
6.1. We use generally accepted standards of technological and operational protection of information and personal data against loss, misuse, alteration, or destruction. However, despite our best efforts, we cannot guarantee absolute protection against any threats arising outside our control.
6.2. We ensure the application of all relevant confidentiality obligations, as well as technical and organizational security measures to prevent unauthorized or unlawful disclosure or processing of such information and data, their accidental loss, destruction, or damage.
6.3. Dissemination of personal data without the consent of the personal data subject or his/her authorized person is allowed in cases determined by law and only (if necessary) in the interests of national security, economic welfare, and human rights.
6.4. The User's Personal data is not encrypted, encryption is applied only to the password on the Service platform.
6.5. In the case of a data breach, the Service will take all necessary measures to minimize the damages that could be caused by it.
6.6. In the case of a data breach, which will be a threat to users' rights and freedoms, the Service will shortly notify the users of such a breach.
7. DATA RETENTION
7.1. The information specified in clause 3.1. is stored securely in our cloud storage.
7.2. The information specified in clause 3.1. is stored during the validity of contractual relations (until account closure).
7.3. The information specified in clause 3.1. is also stored within one month after deactivation of the user’s account.
8. COOKIES
8.1. The Service does not use its own cookies or other tracking technologies to collect personal data. However, third-party providers (e.g., Google Ads) integrated into our platform may use cookies to gather non-personalized analytics or advertising-related information. These cookies operate independently of the Service and are governed by the privacy policies of the respective providers.
8.2. Before any cookies are activated, users are provided with clear information about their purpose and are asked for explicit consent, in line with the data protection requirements. Users can also manage or withdraw their consent at any time via the Cookie Settings.
8.3. For more details on the cookies used by third parties and their privacy policies, please refer to:
Google Ads: https://policies.google.com/privacy
9. ADDITIONAL CONDITIONS
9.1. The Service has the right to make changes to its Privacy Notice. All important changes made to the Notice will be displayed in the new version of this Privacy Notice. All changes to the Notice shall take effect from the moment they are published on the Service. By using the Service, the user confirms acceptance of the new terms of the Notice in the version in force at the time of the user's use of the Service.
10. DATA PROTECTION SPECIALIST
10.1. A Data Protection Officer (DPO) is responsible for ensuring that a company complies with data protection laws and regulations. The DPO operates independently and focuses on protecting personal data and upholding individuals’ privacy rights.
10.2 When the Company learns of a suspected or actual personal data breach, The Data Protection Officer must perform an internal investigation and take appropriate remedial measures in a timely manner.
10.3 The Data Protection Officer can be contacted by e-mail at [email protected]