Our Privacy Policy

PRIVACY POLICY

With this Privacy Policy, AdScout LTD, registered in the Commercial Register at the Registry Agency with UIC 206172724, having its registered office and address of management at city of Sofia, 22, Chavdar Mutafov str., ent. 5, ap. 542, aims to provide you with detailed information about the processing of your personal data when visiting the adscout.io and scoutefy.com website.

1. DEFINITIONS

   Personal data is any information relating to an identified natural person, or an identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

   Processing of Personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

   The Regulation – 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 (General Data Protection Regulation).

2. INFORMATION ABOUT THE DATA CONTROLLER

   For the purposes of providing services through adscout.io and scoutefy.com, the Controller of your personal data is AdScout Ltd., registered in the Commercial Register at the Registry Agency with UIC 206172724, having its registered office and address of management at city of Sofia, 22, Chavdar Mutafov str., ent. 5, ap. 542.

3. TYPES OF PERSONAL DATA WE PROCESS
   1. By signing up to use AdScout's services, you agree that we may collect the following information about you:
      • if you sign up using your Google profile: we collect your name, surname, and email address;
      • if you sign up using your Facebook profile: we collect your name, surname, as they are displayed in your Facebook profile. In case you have granted permission to Facebook using the privacy option in the application (which is shown right before you register on our Platform),we may collect information about your gender, age, email address, depending on the permissions granted by you;
   2. Personal data processed in order to issue accounting/financial documents to implement taxation and social security control includes:
      • Your name
      • Personal No.
      • Address
      • Data on insurable base
      • Details about the bank account of Promoters in order to make payments
   3. When you access our Platform or use AdScout's services, we automatically collect the following information about you:
      • Information about the device – we collect specific information about the device, such as operating system, version, unique identifiers. For example, the name of the mobile network you use. We link the unique identifiers to your profile.
      • Location information – depending on the permissions on your device, we automatically collect and process information about your actual location. We use various technologies to determine your location, including IP address, GPS, Wi-Fi hotspots, and mobile hotspots. In the event that we need data on your location, first you will be shown a pop-up window allowing you to permit or deny us access to your location. If you refuse to give us access to your location data, you will have an option to use the Services, but with limited functionality. If you permit us to have access to your location data, you can change your preferences using the settings on the website or in the application and discontinue providing you location data.
      • Data bout the user and sign-in data – technical details, including the IP address of your device, time zone, and operating system. We will also store your sign-in data in the Platform (registration date, date of last password change, date of last successful sign-in),your browser's type and version.
      • Data generated by users when browsing webpages – we collect information about your activity on our platform, which includes the sites from which you access our Platform, date and time of each visit, your searches, ads or ad banners you have clicked on, your interaction with such ads or announcements in the course of your visit, and the order in which you visit content on our Platform.
      • Cookies and similar technologies – we use "cookies" to manage user sessions, to store your set of preferences regarding the used language, and to serve you suitable ads. "Cookies" are small text files transferred from a web server to the hard drive on your device. Cookies may be used to collect the date and time of the visit to the website, Internet browsing history, your preferences, and your username. You can set your browser to decline all or some "cookies" or to warn you when websites you visit set or access "cookies". Please keep in mind that if you disable or decline "cookies", some parts of our services/Platform may become unavailable or may not function as intended. For more information on the "cookies" we use, please see our Policy on "cookies" and similar technologies.
   4. Data from third parties or publicly available sources – we receive your personal data from various third parties [and public sources], as indicated below.
      • Specific technical data and information on the use of Services from analytics providers, such as Google Analytics, Facebook, Google and the like;
      • Data collected from reading cookies, data from ad networks, such as Programmatic Advertising and the like;
      • Publicly available specialized information from providers of information on searches, such as public online catalogs and directories;
      • Data from Social network profiles, when you access our services on the Platform using these profiles.
4. PURPOSES OF PERSONAL DATA PROCESSING
   1. The purpose of data collection and processing is to offer services and tools, where visitors to the adscout.io and scoutefy.com platform can participate in activities, including, without limitation, registering and creating a profile, publishing or viewing lists of online announcements, and implementing multiple related functions on the adscout.io and scoutefy.com platform. In addition to the aforementioned, we process your personal data for marketing purposes, including personalized offers, analysis of user preferences, and enhancing the quality of the provided services, on the following grounds:
      1. On the grounds of a contract – when you use the services of AdScout Ltd.
         • Purposes of processing:
           1. establishing your identity;
           2. managing and performing your requests for products or services;
           3. preparing and sending a bill/invoice four the products and/or services you use with us;
           4. complete servicing by us;
           5. notification about everything relating to the products and services you use with us;
           6. preparation of a user profile and maintaining client history;
           7. storing correspondence regarding placed orders, processing of requests, reporting problems, etc.
         • On these grounds, we process the following data:
           1. personal data for contact – contact address, telephone number, and email;
           2. dentification data – full name, unified citizen's number or foreigner's personal number, permanent address, ID card No.;
           3. data on orders placed using the user profile;
           4. email, letters, information on your requests for troubleshooting, complaints, requests, other feedback we receive from you;
           5. any other information required in order to provide a specific service and without which the service could not be provided;
           6. identifier created for identification of Promoters;
           7. other personal data provided by you or a third party when concluding or in the effective period of a contract with us, more specifically: full name, unified citizen's number or foreigner's personal number, proxy's permanent address indicated in an authorization document, data on social network profile, contact data, contact person, username, password (upon signing up on our webpage or other similar service); Processing of the indicated personal data about you is required, so that we can conclude the contract with Promoters/Partners and comply with it.
         • Data collected on these grounds is deleted 5 years after termination of our contractual relationship with you. This period is determined by the 5-year statute of limitations for possible contract claims.
      2. Based on legal requirements – the law may envisage an obligation for us to process your personal data. In these cases, we are required to perform the processing, such as:
         1. obligations under the Law on Measures against Money Laundering;
         2. compliance with obligations regarding remote sales, sales outside the retail location envisaged in the Consumer Protection Act.
         3. providing information to the Commission for Consumer Protection or third parties envisaged in the Consumer Protection Act;
         4. obligations envisaged in the Accounting Act and the Tax and Social Security Procedure Code and other related regulations having regard to keeping lawful accounting;
         5. providing information to the court and third parties within court proceedings, in accordance with the requirements of regulations applicable to the proceedings;
         6. verifying age when shopping online.
         • we delete data collected in accordance with an obligation envisaged in the law when the obligation for collection and storage is fulfilled or canceled.
         • Providing your personal data to third parties – where the law envisages an obligation for us to do so, we may provide personal data to the competent state body, natural person or legal entity.
      3. Based on your express consent – in all other cases – We process your personal data on these grounds only after you give your express, unambiguous and willing consent.
      4. Withdrawal of consent – consent granted may be withdrawn at any time. If you withdraw your consent for processing of personal data, we will not use personal data and information for the purposes above. To withdraw your consent, you need to contact us using the indicated contact data. Based on the consent provided by you, we process your email and other information you have given your express consent for. Data collected on these grounds is deleted when requested by you or 2 years after their initial collection.
5. RIGHTS OF DATA SUBJECTS In the event that we process personal data through adscout.io and scoutefy.com, you have the following rights:
   1. Right of access – you have the right to obtain confirmation whether personal data related to you is being processed. In the event that we process such data, we will provide you with a copy of the documents containing personal data (on the respective medium),as well as the following information:
      • purposes of processing;
      • respective categories of personal data;
      • recipients or categories of recipients to which personal data have been or will be disclosed;
      • where possible, the envisaged term, for which personal data will be stored, and where this is impossible – criteria used to determine it;
      • existence of a right to require the Data Controller to correct or delete personal data or limit the processing of personal data related to the data subject, or to object to such processing;
      • the right to complain with a supervisory authority;
      • where personal data is not collected from the data subject, any available information about their source;

      In the event that documents containing personal data on the subject include personal data of other persons, they will be redacted in a suitable manner;

   2. Right to amend: you have the right to require us to amend personal data related to you processed by us in the event that they are inaccurate. If you would like us to supplement your personal data, we will need you to provide a declaration containing the respective information. After we receive your request, we will amend/supplement it as soon as possible.
   3. Right to delete (so-called "right to be forgotten"): you have the right to request the erasure of personal data related to you, which will be deleted where one of the following grounds is applicable:
      • the personal data is no longer needed for the purposes, for which it was collected or otherwise processed;
      • you have withdrawn your consent serving as grounds for the processing of data, and we have no other legal grounds for its processing;
      • you object against the processing and there are no legal grounds for the processing, which would have precedence. When you have objected against processing for marketing purposes, grounds are not analyzed.
      • your personal data has been processed unlawfully;
      • the personal data must be deleted in order to comply with a legal obligation under EU law or Bulgarian legislation;
      • personal data has been collected with regard to offering of information society services; an Information society service is any service usually provided against consideration, remotely, using an electronic means and by an individual request of the recipient of services.

      Even where any of the hypotheses described above is present, we will not delete your personal data where processing is required:

      • in order to exercise the right to freedom of expression and right to information; in order to comply with a legal obligation which requires processing envisaged in EU law or Bulgarian legislation or to perform a task of public interest, or when exercising official authority of the Controller;
      • in order to establish, exercise or protect legal claims;
      • for further two specific hypotheses stipulated in art. 17, par. 3, items "c" and "d" of the Regulation.
   4. Right to limit processing – you have the right to ask us to limit processing, where one of the following applies:
      • you dispute the accuracy of personal data. In this case, limitation is applied for the period required by the Controller to verify the accuracy of the data.
      • Processing is unlawful, but you wish to limit the use of personal data instead of deleting it;
      • The Controller no longer needs the personal data for the purposes of processing, but you require the data to establish, exercise or protect legal claims;
      • You have objected against processing and are expecting verification whether the Controller's legal interests have precedence over yours;

      The Controller will inform any entity to which data has been disclosed, which data has been amended, deleted or limited, except in cases where this is impossible or requires disproportionate effort. If you wish, we will let you know who these entities are.

   5. Right to portability – you have the right to receive the personal data you have provided to us, in a structured, widely used and machine-readable format, and to require us to transfer it to another Controller of your choice. In order for us to take such actions, the following two requirements need to be met:
      • processing based on consent or contractual obligation and
      • automated processing of data.
   6. Right to object – you have the right to object against the processing of your personal data where it is based on:
      • performance of a task in the public interest or in exercising of official authority provided to the Controller or
      • lawful interest.

      We will discontinue processing your data immediately, if we are unable to prove that convincing legal grounds exist for the processing, which take precedence over your interests, rights, and freedoms, or to establish, exercise or protect legal claims.

      Where processing is implemented for marketing purposes, we will discontinue processing your data immediately.

6. PERSONAL DATA WE HAVE OBTAINED FROM THIRD PARTIES
   1. In some cases, we need to process your personal data which has not been provided to us by you or collected by us, but has been obtained by us from third parties. This data are as follows:
      • Data from social networks, such as Facebook – user profile data
      • Data from our Partners – in performance of contractual obligations or with express consent
   2. Optional Features for Business Clients
7. OPTIONAL FEATURES USING THIRD-PARTY INTEGRATIONS FOR BUSINESS CLIENTS

   Google Analytics Integration: AdScout offers an optional feature for Business clients to connect their Google Analytics accounts via the Google Analytics Data API. This feature enables clients to compare their existing analytics with AdScout's data to better understand their conversions and the value of our platform.

   1. Data Collection and Use
      • AdScout collects data via the Google Analytics Data API on a read-only basis.
      • The data includes aggregated performance metrics (e.g., website traffic, engagement, and conversions) for a specified time period, as selected by the client.
      • The purpose of this feature is to generate comparative insights and visual diagrams for enhanced decision-making.
   2. Data Sharing and Disclosure
      • AdScout does not collect any personal data from Google Analytics accounts.
      • AdScout does not share, transfer, or disclose any Google Analytics data to third parties.
      • The data is used solely within the AdScout platform to generate comparative analytics.
   3. Data Protection Mechanisms
      • Encryption: All data transmitted via the Google Analytics Data API is encrypted using HTTPS.
      • Access Controls: Only authorized personnel have access to sensitive data, protected by strict authentication measures.
      • Secure Storage: Data is securely stored using Google Cloud infrastructure, ensuring compliance with GDPR, CCPA, and other applicable regulations.
   4. User Control and Consent
      • The Google Analytics integration is an optional feature that clients can choose to enable.
      • Clients must explicitly grant AdScout read-only access to their Google Analytics data by authenticating by enabling this option.
      • Access can be revoked at any time through the client’s Google account settings.

   For more details about Google’s data policies, please refer to the API Services User Data Policy.

8. OPTIONAL CUSTOMER DATA COLLECTION

   AdScout may collect additional clients data (Name, Email, Phone) to enhance the platform's functionality and prevent misuse by Promoters who create and click on links solely to benefit at the expense of Partners. Additionally, this data collection aims to facilitate access to new clients for both Promoters and Partners. It is important to note that this data collection is recommended by the Partner; however, the decision to utilize this option rests solely with them. AdScout does not independently decide to access their clients

9. CONTACT
   1. For additional information or to exercise your rights, please check your profile settings/privacy or contact us by email at: support@adscout.io or using the Help center on our platform. You can also contact the Data Controller for local services at the following address: city of Sofia, 22, Chavdar Mutafov str., ent. 5, ap. 542 – AdScout Ltd.
   2. The main oversight body is:
      • Commission for personal data protection Address: Sofia 1592, 2, Tsvetan Lazarov blvd., Tel.: 02 915 3555 - For information on received complaints, signals, and questions: 02/91-53-519; fax 02/91-53-525; - For advice on the application of Regulation (EU) 2016/679 and the national legislation on the protection of personal data: 02/91-53-555 Website: http://www.cpdp.bg