Date: July 23, 2021

Overview

We are a privacy-oriented company and make all necessary efforts to protect personal data. Thus, we have adopted this Privacy Notice (“Notice”) to make the processing of your personal data fair, lawful, and transparent.

This Notice applies only to the processing of personal data in the context of access and using the website https://ultra-ads.com/ (“Website”) and to the processing necessary to maintain communication with you on general matters and regarding our services.

We notify You that we will process Your personal data under the provisions of Regulation (EU) 2016/679 (“GDPR”) for the purposes and on legal bases stated in this Notice.

In this Notice we provide the following information:

• Our contact details;
• Our role in personal data processing;
• Categories and sources of personal data;
• Purposes and legal bases for processing;
• Storage period;
• Recipients of your personal data;
• International data transfers;
• Data subject rights.

This Notice is an integral part of our Terms of use, and all terms used in this Notice have the same meanings as in our Terms of use. Other terms should be interpreted according to the provisions of the GDPR.

Our contact details

ULTRA ADS LIMITED, a company incorporated under the legislation of the Republic of Cyprus, with its company number HE315596 and registered address: Avenue, Nikolaou I. Nikolaidi Ave 33, Paphos 8010, Cyprus.

For any details regarding the processing of your personal data or to exercise data subject rights please contact us directly by sending an email to [email protected] or our registered address.

Our role in the personal data processing

When you access and use the Website we collect and process your personal data acting as a data controller within the meaning of the GDPR. It means that we determinewhy and how the processing should take place.

We also have the right to authorize other persons to process your personal data. Nevertheless, we are mainly responsible for processing your personal data within the scope of this Notice.

Categories and sources of personal data

Technical data. In the course of your access and use of the Website, we automatically collect from your browser and process the following personal data:

• IP address, your location, your mobile operator or Internet provider;
• data related to your device: its operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable);
• information about your browsing session and any interaction with the Website interface (for example, the number of pages you visited, the number of pages you clicked);
• information about the source from which you visited the Website;
• cookie data.

Contact data. When You contact us with general questions about our Company, our services, or this Website or to order our services we may collect and process the following personal data:

• Your name;
• Your email;
• Other data voluntarily provided by you.

Search data. When you contact uson behalf of the organization interested in our services and provide us with the name of the organization, we may analyze open-source information about you and the organization. We may collect the following data:

• Organization name, country of incorporation, characteristics of services and products provided;
• Information about you available on the organization’s website, public pages on social networks concerning our position, work experience, career, etc.

Purposes and legal bases for processing

To comply with the purpose limitation and lawfulness principles we collect and process your personal data for specified, explicit, and legitimate purposes and on appropriate legal bases. In this part of the Notice, you can find the description of purposes and legal bases for processing we carry out.

Legitimate purpose	Personal data	Legal basis
Making our Website available and usable	Technical data	Our legitimate interest according to Article 6 (1)(f) of the GDPR Ourlegitimate interest is to give you access to our Website and its complete functionality.
Ensuring the correctness of the Website operation and security	Technical data	Our legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to maintain our Website working without bugs and eliminate any external threats to the Website.
Optimization and improvement of the Website	Technical data	Our legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to make our Website better and more convenient for you.
Communication with You	Contact data Search data Technical data	Our legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to communicate with you both on general matters and in negotiations before entering into the contract with the organization you represent.
Understanding the context of future business relations with prospective clients	Contact data Search data	Our legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to understand and anticipate how to cooperate with prospective clients.

Storage period

We adhere to thestorage limitation principle, and we will not store your personal data longer than it is necessary to achieve the purposes stated above.

Different categories of personal data have their specific storage periods:

Technical data (except for cookie data). We will keep Technical data no longer than 14 (fourteen) months from your last visit to the Website.

Contact data and Search data. We needthese personal data during our communication with you. When the purpose of our communication with You is reached, we erase these data. 

Recipients of your personal data

To conduct our business and service our Website we engage a wide range of specialists, consultants, and services providers. Thus, we notify you that we may share your personal data with the following recipients:

• Employees, contractors, agents, affiliates, external consultants. To service our Website and conduct our business we may engage such persons entering into contracts with them. We guarantee that these persons have committed themselves to confidentiality and security of personal data. In any case, we are liable for their faults to perform obligations.

• IT services providers. Weusehosting provider services, cloud services, analytics services,and other technical solutions to maintain our Website and organize business processes. Accordingly, they may have access to your personal data, previously encrypted by the Company.

We currently use the services of the following providers:

Cloudflare. Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107, USA helps us to optimize the operation of the Website and ensure its protection. Please read more in Cloudflare Privacy Policy. The United States does not provide an adequate level of personal data protection, so standard contractual clauses (SCC) apply to the transfer of your personal data to Cloudflare.

Google. Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland provides Google Analytics services. Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA provides reCAPTCHA services. Please read more in Google Privacy Policy. The United States does not provide an adequate level of personal data protection, standard contractual clauses (SCC) apply to the transfer of Your personal data to Google LLC.

Insofar as we are constantly growing and developing, we can involve new IT services providers in the future.

International data transfers

We primarily store Your personal data within the EEA. However, for some purposes, we may share your personal data with the recipients outside the EEA as stated above. In any case, we guarantee that your personal data will be subject to appropriate safeguards (such as the European Commission adequacy decisions or standard contractual clauses with the recipients) and treated securely and in accordance with this Notice and the GDPR.

Data subject rights

Taking into account the requirements of the GDPR, we undertake toexercise your data subject rights, namely:

The right to access (Article of the 15 GDPR). You have the right to receive confirmation from us as to whether Your personal data are being processed, as well as to receive a copy of your personal data.

Right to rectification (Article 16 of the GDPR). You have the right to request the rectification of your personal data if the data are inaccurate, as well as the complete the data if the data are incomplete.

Right to erasure (Article 17 of the GDPR). You have the right to request the erasure of your personal data. This right applies if:

• Your personal data is no longer required for the purposes for which they were collected;
• Personal data are processed unlawfully;
• We do not need to store your personal data in order to comply with applicable law;
• In other cases where deletion is required or permitted by applicable law.

Right to restriction of the processing (Article 18 of the GDPR). You have the right to request the restriction of the processing of your personal data in the following cases:

• If You contest the accuracy of your personal data, we will restrict the processing of such data until we verify their accuracy;
• If you object to the processing of personal data based on our legitimate interest, we will restrict the processing of such data until the legitimate interest is confirmed;
• If the processing is unlawful, you can object to the deletion of personal data and request the restriction of their use instead;
• If we no longer need personal data, but you need it to establish, exercise, or defense legal of legal claims.

Right to object (Article 21 of the GDPR). You have the right to object to the processing of your personal data based on our legitimate interests. We will not continue to process personal data if we are unable to demonstrate the existence of compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

Right to lodge a complaint (Article 77 of the GDPR). You can always contact us with any questions regarding the processing of your personal data. However, if you believe that your rights have been violated, you can file a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our registration). Commissioner’s website: http://www.dataprotection.gov.cy.

If you are within the EU you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of work. You can find the list of data protection authorities in the EEA at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Updates to the Notice

Please note that we may modify, amend and update this Notice to be usually compliant with the data protection laws. The current version of the Notice will be posted on the Website.

Cookie Notice

Cookies are snippets of data that can be installed on Your internet web browser when You visit the Website. We use some types of cookies, but we are not interested in identifying You as an individual with the data from cookies.

We use the following cookies:

Name of Cookie	Type	Storage period	Purpose of use	Status
_ga	Analytics cookies	2 years	Google Analytics uses these cookies to analyze how users interact with the Website. With this information, we can improve the Website and Your experience on the Website.	Optional
_gid		1 day