Privacy Policy

Our ADSALES website https://adsales.net/ (hereinafter referred to as the “Site”) and all subdomains of adsales.net.ua are owned and administered by LLC “DRIM TIM MEDIA”, a limited liability company established and operating in accordance with the laws of Ukraine (legal address: 01103, Kyiv, Mendeleeva St., 12, office 94/1) (hereinafter referred to as the “Company”, “We”).

You can contact us by email at: [email protected]

We specialize in providing advertising placement services on Telegram (hereinafter referred to as “Services”), which helps expand the presence of your brand or services on social media.

This Privacy Policy (hereinafter referred to as the “Policy”) applies only to the use of this Website and provides users with information about the processing of their personal data by the operator of this Website. The Policy does not extend to other websites that this Website may link to, regardless of whether such links were posted by us or other users.

We do not control how your data is collected, stored, or used by other websites, and we recommend that you review the privacy policies of such websites before providing them with any personal data.

This Policy applies to:

• Website visitors;
• Our clients (including their internal users, employees) (collectively referred to as “Users”, “You”).

The Company recognizes your right to the protection of personal data and is committed to protecting it. This Policy discloses what data we collect, how we use it, and how to correct or change such data. You can obtain the following information regarding your personal data:

• what data is collected;
• who collects the data;
• how the data is used;
• to whom the data may be transferred;
• what choices you have regarding the collection, use, and transfer of data;
• what procedures are applied to protect against loss, misuse, or alteration of data under our control;
• how you can correct any inaccuracies in the data.

If you have any additional questions, please contact our data protection team at [email protected]

1. Your Personal Data

We comply with all terms and requirements provided by the current legislation of Ukraine and European legislation, including, but not limited to, the General Data Protection Regulation (GDPR), as well as other international legislative acts regarding the protection of personal data.

We collect personal data based on consent obtained from users who have reached 18 (eighteen) years of age. If you are aware that the Company is processing data of persons under 18 (eighteen) years of age, please notify us by writing to us at [email protected]

We do not collect and/or process personal data about racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data concerning health, sexual life, biometric, or genetic data of an individual.

We guarantee that your personal data is processed lawfully, fairly, and transparently without negative impact on your fundamental rights and freedoms. The legal bases for processing personal data are:

• Your consent to the processing of personal data;
• permission to process personal data granted to us in accordance with applicable law exclusively for the exercise of our powers;
• conclusion and performance of a transaction with you, or a transaction concluded for your benefit, or to take steps preceding the conclusion of a transaction at your request;
• protection of vital interests of you as a personal data subject;
• necessity to fulfill our obligation provided by applicable law;
• necessity to protect our legitimate interests or the legitimate interests of a third party to whom personal data is transferred, except in cases where the need to protect your fundamental rights and freedoms in connection with the processing of your data outweighs such interests.

We use your data to provide you with the best experience while using the Website. This includes:

• provide the User with access to the Website and administer access;
• personalization and adaptation of the user experience on the Website;
• responding to user messages related to technical support, including responding to comments and inquiries;
• analyzing Website usage to improve user interaction.

We do not collect personal data when visiting the Website, except when you fill out a contact form for feedback. However, we may collect some data automatically (IP addresses and operating systems of devices from which the Website is visited, type and version of web browser, links that the user used to access the Website, user activity on the Website, links that the user followed after visiting the Website).

In some cases, data collection may be a requirement of applicable law or performance of a transaction, and we will be limited in the services we can provide to you without your consent to use such data.

In cases where you submit feedback and requests for information about the Website, we will request your name and email address. We will use this data exclusively to respond to your feedback and requests.

All statistics and data on Website performance are kept confidential, and no personal data is transferred to any of our partners without your permission. Occasionally, we may refer to our own statistics, but the data will be aggregated from our entire client base, without identifying any individual.

With your permission (consent) and/or if permitted by law, we may also use your data for marketing purposes, including sending you emails with necessary information, news, and offers. However, we will not send you unsolicited marketing materials or spam and will take all reasonable measures to ensure full protection of your rights and compliance with our obligations under GDPR and the Privacy and Electronic Communications Directive (EU Directive) of 2003, as amended in 2004, 2011, and 2015.

ALL PERSONAL DATA RELATING TO OUR CLIENTS, INCLUDING EMAIL ADDRESSES AND OTHER PERSONAL DATA, IS STORED SECURELY AND IS CONFIDENTIAL. WE DO NOT DISCLOSE, TRANSFER, SELL, OR EXCHANGE ANY PERSONALLY IDENTIFIABLE DATA WITH THIRD PARTIES WITHOUT YOUR PERMISSION.

2. Your Rights Under GDPR

GDPR provisions apply to users who are EU residents. Accordingly, this Policy provides you with the opportunity to exercise the following rights that you have under GDPR as a data subject who is an EU resident:

• the right to be informed about which of your personal data is being processed;
• the right to request access to your personal data, its erasure (“right to be forgotten”), or correction;
• the right to restriction of processing of your personal data;
• the right to data portability;
• the right to object to the processing of your personal data;
• the right to lodge a complaint with a supervisory authority;
• the right to refuse automated decision-making and profiling.

To exercise any of the above rights, please contact our data protection team at [email protected]

If any of your personal data is used by us for automated decision-making, and these decisions have a legal (or similarly significant) effect on you, you have the right to challenge such decisions under GDPR, requiring human intervention in making such decisions.

The right described above does not apply under the following circumstances:

• the decision is necessary for entering into or performing a contract between you and us;
• the decision is authorized by law; or
• you have provided your explicit consent to such automated decision-making.

Currently, we do not use ANY automated decision-making for any purposes.

We profile personal data for marketing and advertising. In the event of using personal data for such profiling, the following applies:

• clear information will be provided explaining the profiling, including its significance and likely consequences;
• appropriate mathematical or statistical procedures will be used;
• necessary technical and organizational measures will be applied to minimize the risk of errors, as well as to ensure that such errors can be easily corrected; and
• all personal data processed for profiling purposes will be protected to prevent discriminatory consequences that may arise as a result of profiling.

3. Data Collection and Storage

All data collection on the Website is carried out in a manner that is clear and transparent to our users. We store your data only as long as necessary for the purposes specified in Section 2, and/or as long as we have your permission to store it. In any case, we conduct an annual review to determine whether we need to continue storing your data. Your data will be deleted if we no longer need it.

We primarily store user data in Ukraine. To facilitate our operations worldwide, we may transfer and access such data from around the world, including other countries in which we operate. Some or all of your data may be stored or transferred outside the European Economic Area (“EEA”). If you do not agree with this, please contact our data protection team with an appropriate request. In the event of storing or transferring data outside the EEA, we will take all reasonable measures to ensure that your data is processed as reliably and securely as within the EEA and in accordance with GDPR. Such steps may include implementing contractual obligations between us and any third parties we engage.

4. Data Security

Data security is of great importance to us, and to protect your data collected through the Website, we have implemented appropriate physical, electronic, and administrative procedures.

We take the following measures to ensure the security and protection of your data:

• access to data stored on the Website is restricted to a defined number of our employees;
• we use industry best practices to ensure the security of any data collected and/or transmitted to the Website. The Website is protected by SSL protocol, which provides encryption of all transmitted data;
• we use the TLS cryptographic protocol, better known as HTTPS, for all data we send and receive. This ensures that all user data during transmission is secure and protected, and accessible only to those for whom it is intended;
• the Website is protected by: a) firewalls that establish a barrier between our trusted, secure internal network and the Internet, and b) access restrictions to specific IP addresses;
• we use third-party providers to prevent attacks on the Website, destruction, or theft of any data. Such providers also monitor potential attacks to notify you in the event that their content and/or any related data has been compromised;
• we periodically review our data collection and processing methods and make appropriate changes to this Policy.

Despite the security measures we take, it is important to remember that data transmission over the Internet cannot be completely secure, and we recommend that you take appropriate security measures when transmitting data to us over the Internet.

5. Data Disclosure

We may enter into transactions with third parties (search engines, advertising and marketing) to provide you with services presented on the Website on our behalf. In some cases, third parties may need access to some or all of your data. In such cases, we will provide access only with your consent and will take all reasonable measures to ensure that your data will be processed securely, reliably, and in compliance with your rights, our obligations, and the obligations of third parties in accordance with applicable law.

We may collect statistical data on the use of the Website, including data on traffic, user behavior, sales, etc. All such data will be anonymized and will not include any data identifying a specific individual. We may from time to time share such data with third parties, such as potential investors, affiliates, partners, and advertisers. Data will be transferred and used only within the framework of applicable law.

Under certain circumstances, we may be legally required to transfer certain data, which may also include your personal data. Such cases relate to our participation in legal proceedings, compliance with legal requirements, court orders, or satisfaction of requests from competent government authorities. In such cases, we will not require your additional consent to transfer your personal data.

6. Transfer of Control

We may from time to time expand or reduce the list of services presented on the Website, which may include the sale and/or transfer of control over the entire Company or part of it. If data provided by users relates to any part of our business being transferred, then in such case it will be transferred along with that part. The new owner or new controlling party, in accordance with the terms of this Policy, will be allowed to use this data for the purposes for which it was originally collected by us. In such cases, we will not notify you of such changes.

7. Cookies

Our Website does not use cookies and we do not collect any information about users through cookies.

However, we inform you that we may independently at our own discretion change our decision regarding the use of cookies on our Website at any time and such changes will be reflected in this Policy in accordance with Section 9.

8. Opt-Out

We provide you with the opportunity to withdraw your consent to the use of your personal data at any time, update, change, or delete your personal data from the Website, as well as unsubscribe from receiving messages from us. Please contact our data protection team with an appropriate request at [email protected] or by mail at: Ukraine, 01103, Kyiv, Mendeleeva St., 12, office 94/1.

9. Amendments

We may from time to time make changes to this Policy if we deem it necessary, or if required by applicable law. Any changes will be promptly published on the Website, and you will be deemed to have reviewed the updated Policy upon your first use of the Website after the published changes. We recommend that you regularly check this page for current information.