Privacy Policy

Effective Date: August 14, 2024

This policy explains how Adleton OÜ, an Estonian company ("Adleton", "we", "us"), processes your personal data. This policy applies to all users and visitors of our Services. For specific rights you may have, please see the **Region-Specific Supplements** at the end of this document.

1. Data We Collect
2. How We Use Your Data
3. Data Sharing and Disclosure
4. Your Rights and Choices
5. Data Security and Transfers
6. Scope and Contact Information

1. Data We Collect

We collect data to operate our services. The data we collect depends on your interaction with us.

Data You Provide (Account Holders)

Account & Contact Data: Information you submit during registration (e.g., username, email, password) and profile creation (e.g., bio).
Transaction & Payout Data: We collect details of transactions you make and your designated payout information. We use third-party payment processors; we do not collect or store your credit card information.

Data We Collect Automatically (All Visitors and Users)

Usage & Technical Data: When you visit our site, we automatically collect technical data such as your IP address, browser type, and pages you visit. This data is collected via server logs.
Cookie Data: We use cookies and similar technologies to help our site function and to understand user activity. Some cookies are strictly necessary for the site to work, while others (like for analytics) are optional. For detailed information and to manage your preferences, please see our separate Cookie Policy.

2. How We Use Your Data

We only process your data when we have a valid legal reason. We use your data to:

Provide Our Service: We process Account and Transaction data to perform our contract with you under our Terms of Service.
Improve and Secure Our Service: We process Usage & Technical data from all visitors for our legitimate business interests in analyzing performance, preventing fraud, and ensuring the security of our platform.
Send Communications: We will ask for your explicit consent before sending you non-essential marketing communications.

4. Your Rights and Choices

We provide you with control over your data through your account settings and by respecting your legal rights. You have the right to request access to, correct, or delete your personal data. For more details on rights specific to your location, please see the supplements below.

Please note, after a necessary retention period, we may anonymize or aggregate your data. This policy does not apply to such de-identified data.

5. Data Security and Transfers

We use appropriate technical and organizational measures to safeguard your data. As a global service, your data may be processed outside of your home country. We ensure such transfers are protected by legally-recognized mechanisms like the Standard Contractual Clauses.

6. Scope, Content, and Contact Information

Policy Scope

By using our Services, you agree to this Privacy Policy. If you do not agree, you may not use the Services.

Content and Copyright

This Privacy Policy governs personal data, not the content. Your rights and responsibilities regarding content, and our process for handling legal reports (such as notices under the US DMCA), are detailed in our separate Copyright Policy and our Terms of Service.

Contact

If you have any questions, please contact our Data Protection Officer at service@adleton.com.

Supplement for Users in the European Economic Area (EEA), UK, and Switzerland

If you are a user in this region, you have the following rights under the General Data Protection Regulation (GDPR) and the ePrivacy Directive:

Cookie Consent: You have the right to control the use of non-essential cookies. We will not place optional cookies on your device without your prior consent, which you can manage at any time via our cookie settings tool.
The right to lodge a complaint with a supervisory authority, such as the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
The right to data portability and the right to object to or restrict certain data processing activities.

Our Data Protection Officer can be reached at service@adleton.com.

Supplement for Users in the United States

This section provides additional details for residents of certain US states, such as California (under the CPRA).

Do Not Sell or Share My Personal Information: We do not sell your personal data or share it for cross-context behavioral advertising.
Right to Limit Use of Sensitive Personal Information: We do not use "Sensitive Personal Information" to infer characteristics about you.

You have the right to non-discrimination for exercising your privacy rights. To exercise any rights, please contact us.

Supplement for Users in Asia (e.g., Singapore)

Your use of our services constitutes your consent to the collection, use, and disclosure of your personal data as described in this policy, which is necessary for us to provide the service to you.

Our Data Protection Officer, who is responsible for our compliance with laws like Singapore's PDPA, can be reached at service@adleton.com.