Privacy Statement

1. About Us

Our Site clicknetic.media (also “Our Site”) is owned and operated by Adtelligent Inc, a US corporation headquartered in the United States, Delaware, 16192 Coastal Hwy, City of Lewes, County of Sussex, 19958 (also referred to as “Adtelligent”, “we”, “our”, “us” etc.).

Our data protection officer can be contacted at legal@clicknetic.media.

Adtelligent provides a software-as-a-service solution to businesses and agencies all over the world that need to manage their (or their clients’) digital advertising resources (herein, “Service”). This Privacy Statement applies only to Your use of Our Site. It does not extend to any websites that are linked to Our Site (whether We provide those links or whether they are shared by other users). We have no control over how Your data is collected, stored, or used by other websites, and We advise You to check the privacy statements of any such websites before providing any data to them.

This Privacy Statement applies to:

• Our Site visitors;
• Our customers (including their internal users);

(jointly referred to as “Users”, “You”, and “Your”)

The Adtelligent recognizes Your right to confidentiality and is committed to protecting Your privacy. This Privacy Statement discloses what data We gather, how We use it, and how to correct or change it. You can expect to be hereby notified of the following:

• What personally identifiable data of Yours is collected;
• Who is collecting the data;
• How the data is used;
• With whom the data may be shared;
• What choices do You have regarding the collection, use, and distribution of the data;
• What kinds of security procedures are in place to protect against the loss, misuse, or alteration of the data under our control;
• How You can correct any inaccuracies in the data.

If any additional questions arise, You should direct them to Our Data Protection Team, reachable at legal@clicknetic.media.

2. Representation in the EEA

We value your privacy and your rights as a data subject located in the EEA and have therefore appointed Prighter Group with its local partners as our privacy representative for purposes of Article 27 of GDPR and your point of contact.

Prigther Group is a representative company that helps with compliance with privacy laws and is on the side of the consumer to protect their rights under the GDPR. Prighter Group gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data).

All the necessary information about Prighter Group you can reach out by clicking the link below or on its official website https://prighter.com/

If you want to contact us via our representative, Prighter Group, or make use of your data subject rights, please visit the following website: https://prighter.com/q/12482014860

3. Your Personal Data

We adhere to all conditions and requirements stipulated by the current legislation in the USA and European legislation, including, but not limited to, the General Data Protection Regulation (GDPR), as well as other international legislative acts concerning data protection. For more information about the data processing of US Residents, please visit Our US Residents Privacy Notice.

We collect personal data on the basis of consent obtained from the Users who have reached eighteen (18) years of age. If You know that the Company processes data of persons under eighteen (18) years of age, please inform about this by writing to the email address: legal@clicknetic.media.

We do not collect and/or process sensitive data, which means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Under GDPR, We ensure that Your personal data is processed lawfully, fairly, and transparently without adversely affecting Your rights. We will only process Your personal data if at least one of the following grounds applies:

• You have given consent to the processing of Your personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which We are subject; and/or
• Processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject, which require protection of personal data, in particular where the data subject is a child.

We use Your data to provide the best possible user experience to You. This includes:

• Providing and managing Your access to Our Site;
• Personalizing and tailoring Your experience on Our Site;
• Responding to communications from You (to provide users support, including responding to Your comments and questions);
• Keeping You informed about newsletters You have subscribed to (You may unsubscribe or opt-out at any time by changing Your email preferences link in Our emails);
• Analyzing Your use of Our Site to improve Your user experience.

We do not collect personal data when You visit Our Site unless You sign-up for a service, register an account with us, place an order, register, complete a survey, fill in the contact form or subscribe to the newsletter. When You visit Our Site, we also may collect certain data by automatic means that may include Your IP address; Your web browser type and version; Your operating system; a list of URLs starting with a referring site, Your activity on Our Site, and the site You exit to.

In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide You without Your consent for Us to be able to use such data.

When You sign-up for a service, We will ask you for the following personal information: name, surname, your company, billing address and details, skype contact and email address. We may use your personal information to contact You for account purposes.

When you register an account or place an order (upgrade to a paid version of the software), we will ask you for the following personal information:  name, surname, email, billing address, mailing address, job title, your company, phone number, skype contact and banking details. This information is requested to verify your identity. This information is transmitted via a secure encrypted server using Transport Layer Security (TLS) encryption, more commonly known as HTTPS, the approved industry standard (see Security section below). We may use your personal information to contact you for account purposes.

When You submit feedback or questions via email or contact Us for information about Our Site, We will request Your name and email address. We use this data solely to respond to Your inquiries.

When You subscribe to a newsletter, We will request Your name, and email address. We use this data to provide You with the news and information according to Your subscription. You can revoke Your consent to receive a newsletter at any time, and Your subscription will be cancelled

All performance statistics and data are kept private, and any personally identifiable data is not released to any of Our partners without Your permission. Occasionally, We may reference Our own statistics, but the data will be aggregated by Our whole client base, without any party’s identification provided.

With Your permission and/or where permitted by law, We may also use Your data for marketing purposes, including contacting You by email with information, news, and offers. We will not, however, send You any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect Your rights and comply with Our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

ALL PERSONAL DATA RELATING TO OUR CLIENTS, INCLUDING EMAIL ADDRESSES AND OTHER PERSONAL DATA, IS KEPT SECURE AND CONFIDENTIAL. WE DO NOT SHARE, SELL, RENT, OR BARTER ANY IDENTIFIABLE PERSONAL DATA TO ANY THIRD PARTY WITHOUT YOUR PERMISSION.

4. Your Rights Under GDPR

Our Privacy Statement provides You with the opportunity to exercise the following rights You have under the GDPR as a data subject:

• the right to be informed of what data processing is taking place;
• the right to request access to, deletion of, or correction of Your personal data;
• the right to restrict the processing of Your personal data;
• the right to data portability;
• the right to object to the processing of Your personal data;
• the right to complain to a supervisory authority;
• the right to refuse automated decision-making and profiling.

To enforce any of the foregoing rights, please contact Our Data Protection Team at legal@clicknetic.media.

In case any of Your personal data is used by Us for the purposes of automated decision-making, and those decisions have a legal (or similarly significant) effect on You, You have the right to challenge such decisions under GDPR by requesting human intervention, expressing their own point of view, and obtaining from Us an explanation of such decisions.

The right described in the section above, however, does not apply in the following circumstances:

• The decision is necessary for the entry into, or performance of a contract between You and Us;
• The decision is authorized by law; or
• You have given Your explicit consent for such automated decision-making.

We currently use NO automated decision-making for any purpose.

We currently profile personal data for the purposes of marketing and advertising. Where We use personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;
• Appropriate mathematical or statistical procedures will be used;
• Technical and organizational measures are necessary to minimize the risk of errors and to enable such errors to be easily corrected; and
• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising from profiling.
• Data Collection and Storage

All the data collection on Our Site is carried out in a manner that is clear and transparent to Our Users. We only keep Your data for as long as needed in order to use it for the purposes set in Section 2, and/or for as long as We have Your permission to keep it. In any event, We are conducting an annual review to ascertain whether We need to keep Your data. Your data will be deleted if We no longer need it.

We primarily store data about Users in Ukraine and the United States. To facilitate Our global operations, We may transfer and access such data from around the world, including from other countries in which We are operating. Some or all of Your data may be stored or transferred outside of the European Economic Area (“the EEA”). If You are not accepting this, please refer to Our Data Protection Team with a correspondent request via the email: legal@clicknetic.media. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage.

5. Security

Data security is of great importance to us, and to protect Your data ,We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Site.

Steps We take to secure and protect Your data include:

• Access to the data stored within Our Site is restricted to a limited number of Our employees;
• We use industry best practices to keep any data collected and/or transmitted to the site secure. Our Site is secured by SSL protocol, which provides encryption to all data transmitted;
• We use Transport Layer Security (TLS) encryption, more commonly known as HTTPS, for all of the data that We send and receive. This ensures that all users’ data in transit is both safe and secure, and additionally only available to the intended recipients;  
• Our Site is protected by a) firewalls establishing a barrier between Our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to allowed IPs;
• We use third-party vendors to prevent attacks on the site, and the destruction or theft of any data. Such vendors also monitor potential attacks to inform You in the event their content and/or any related data has been compromised;
• We review Our data collection and processing practices periodically and will review and amend this Privacy Statement accordingly.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the Internet may not be completely secure and that You are advised to take suitable precautions when transmitting to Us data via the Internet.

6. Data Sharing

We may contract with third parties to supply services represented via Our Site to You on Our behalf. These may include search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of Your data. Where any of Your data is required for such a purpose, We will accomplish this only under Your consent and take all reasonable steps to ensure that Your data will be handled safely, securely, and in accordance with Your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, sales, and other data. All such data will be anonymized and will not include any personally identifying data. We may, from time to time, share such data with third parties such as prospective investors, affiliates, and partners. Data will only be shared and used within the bounds of the law. In certain circumstances, We may be legally required to share certain data, which may include Your personal data, for example, where there is involvement in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your data in such circumstances and will comply as required with any legally binding request that is made by the competent authorities.

7. Transfer of Control

We may, from time to time, expand or reduce services represented via Our Site, and this may involve the sale and/or the transfer of control of all or part of the Company. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use the data for the purposes for which it was originally collected by Us.

In the event that any of Your data is to be transferred in such a manner, You will not be contacted in advance and informed of the changes.

8. Cookies

To better serve You, We use “cookies” for the continuous improvement of Your users’ experience across Our Site. Cookies are pieces of data that Our Site can set on Your browser or device, and they can typically be read on future visits to learn about You more and to personalize Your experience, including the ads that are displayed to You.

We collect and process a variety of non-personally identifying data in order to prevent fraud and support and maintain a higher-quality browsing experience for all users.

To know more about the way how We process cookies and use such data, please refer to our Cookie Policy.

9. Your Choice/Opt-Out

We provide You with the opportunity to withdraw Your consent for Us to use Your personal data, update, change, or remove Your personal data from Our Site, and opt out of receiving communications from Us at any time. Please contact Our Data Protection Team with the corresponding request at legal@clicknetic.media or by post at:

­­­ Adtelligent Inc., 16192 Coastal Hwy, City of Lewes, County of Sussex, 19958 DE.

10. Changes to this Privacy Statement

We may change this Privacy Statement as We may deem necessary from time to time or as may be required by law. Any changes in force will be posted on Our Site in a timely manner, and You will be deemed to have familiarized with this Privacy Statement during Your first use of Our Site following the alterations published. We recommend You check this page regularly to keep up-to-date.