Introduction
Adpera respects your privacy and we would like to inform you on how we collect, use and
disclose any personal information that individually identifies you. This Privacy Policy explains
our online information practices applicable to the websites available (the “Sites”) and all
Adpera services like apps and other products made available to you on, through or in
association with the Adpera services (the “Services”). We will only collect, use and disclose
your personal information in accordance with this Privacy Policy in a lawful, fair, and
transparent manner.
If you have any questions about this Policy, including any requests to exercise your legal rights,
including any queries relating to this Policy, please contact us at
[email protected].
Personal data and basis for Collection
Personal data means any data or information about an individual from which that person can be
identified. Where Adpera is acting as a data controller, Adpera may collect, use, store and
transfer different kinds of personal data about you which Adpera has grouped together as
follows:
Identity Information are collected Directly from the individual via our Participation Contact,
Direct Interactions; for the purposes of Delivering our products or services, Marketing
purposes, Recruiting employees and contractors, Customizing and improving user experience,
To bill and collect money, Providing customer support, Contacting users, Meet legal
requirements, Record keeping and administration, Data analytics and market research,
Compliance and dispute resolution. The legal basis we rely for processing your Identity
Information is Consent of the user and we plan to keep your Identity Information for 5 years
and we share your Identity Information with our Cloud storage providers.
Contact Information are collected Directly from the individual via our Participation Contact,
Direct Interactions; for the purposes of Delivering our products or services, Providing customer
support, Contacting users, To bill and collect money. The legal basis we rely for processing
your Contact Information is Consent of the user and we plan to keep your Contact Information
for 5 years and we share your Contact Information with our Cloud storage providers.
Bank or Credit Card Information are collected Directly from the individual via our Direct
Interactions, Participation Contact; for the purposes of To bill and collect money. The legal
basis we rely for processing your Bank or Credit Card Information is Consent of the user
and we plan to keep your Bank or Credit Card Information for 5 years and we share your Bank
or Credit Card Information with our Cloud storage providers.
Tax and Invoice Details are collected Directly from the individual via our Participation
Contact, Direct Interactions; for the purposes of Meet legal requirements, To bill and collect
money. The legal basis we rely for processing your Tax and Invoice Details is Consent of the
user and we plan to keep your Tax and Invoice Details for 5 years and we share your Tax and
Invoice Details with our Tax authorities.
Social Media Information are collected Directly from the individual via our Direct
Interactions, Participation Contact; for the purposes of Data analytics and market research,
Delivering our products or services, Recruiting employees and contractors, Customizing and
improving user experience. The legal basis we rely for processing your Social Media
Information is Consent of the user and we plan to keep your Social Media Information for 2
years and we share your Social Media Information with our Analytics service providers,
Cloud storage providers, Advertising partners.
Usage and Log Data are collected Directly from the individual via our Participation Contact,
Direct Interactions; for the purposes of Customizing and improving user experience, Data
analytics and market research, Marketing purposes. The legal basis we rely for processing your
Usage and Log Data is Public Interest / Public Task and we plan to keep your Usage and Log
Data for 2 years and we share your Usage and Log Data with our Analytics service providers,
Cloud storage providers, Advertising partners.
Device and Technical Information are collected Directly from the individual, From a third
party (Google Analytics) via our Direct Interactions, Participation Contact; for the purposes of
Marketing purposes, Customizing and improving user experience, Data analytics and market
research. The legal basis we rely for processing your Device and Technical Information is
Public Interest / Public Task and we plan to keep your Device and Technical Information for 2
years and we share your Device and Technical Information with our Analytics service
providers, Cloud storage providers, Advertising partners.
Demographic Information and Interests are collected From a third party (Google Analytics),
Directly from the individual via our Direct Interactions, Participation Contact; for the purposes
of Customizing and improving user experience, Data analytics and market research, Marketing
purposes. The legal basis we rely for processing your Demographic Information and
Interests is Public Interest / Public Task and we plan to keep your Demographic Information
and Interests for 2 years and we share your Demographic Information and Interests with our
Analytics service providers, Advertising partners, Cloud storage providers.
We will actively review the information we hold and delete it securely, or in some cases
anonymise it, when there is no longer a legal, business or customer need for it to be retained.
If you fail to provide personal data
Where Adpera needs to collect personal data by law, or under the terms of a contract Adpera
has with you and you fail to provide that data when requested, Adpera may not be able to
perform the contract it has or is trying to enter. In this case, Adpera may have to cancel the
Services but it will notify you. Therefore, Adpera solely requests the data which are needed to
provide it’s services.
Data security
We have put in place Encryption, Access Controls, Access to data requires a password,
Employee Training security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorized way, altered or disclosed. Third party processors will
only process your personal data on our instructions and they are subject to a duty of
confidentiality. We shall implement penal clauses to our data processor agreements in order to
effectively supervise the third party processing activities.
Data Subject’s Rights
You can do the following at any time by contacting us via the email address or phone number
given on our website: (i) see what data we have about you, (ii) change/rectify any data we have
about you, (iii) have us delete any data we have about you, (iv) express any concern you have
about our use of your data and request the restriction of processing and (v) withdraw your
consent for processing of personal data.
Amendments to the Privacy Policy
As and when necessary, changes to this Privacy Policy will be posted here. Where changes are
significant, we may also email all our registered users with the new details, and where required
by law, we will obtain your consent to these changes.
