Clickadu s.r.o. (hereafter called as the “Clickadu”, “We”, etc.) takes the privacy of your personal data very seriously and complies with the EU General Data Protection Regulation laws (hereafter GDPR). This document (Privacy Policy) is designed to tell you about our availability and services, about our practices regarding the collection, usage and disclosure of your personal information that may be collected and processed via this website www.clickadu.com (hereafter called as the “Website”, “Platform”) as well as on other resources where our services are provided.
We process your personal data based on consent according to GDPR Privacy, DSA, PDPB, Consumer Protection Act 2019, IT Rules 2021 PDPD, Decree No. 70/2021/ND-CP. You’ll see consent options when you visit our website for the first time. You can change your decisions at any time by clicking the button below. If you change your decision it will not affect the lawfulness of processing based on consent before its withdrawal.
In this Privacy Policy, “personal data” means any information relating to you as an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
For the avoidance of doubt, personal data does not include data from which you cannot be identified (which is referred to simply as data, non-personal data, anonymous data, or de- identified data).
In this Privacy Policy, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Identity and contact details of the data controller
Clickadu, a company, whose headquarter is located at Clickadu s.r.o.Zenklova 32/28, Praha 8 – Libeň, 180 00, Czech Republic Tax ID number 04066260, is responsible for processing your personal data collected on the website www.clickadu.com, and when using our services, within the meaning of the regulations applicable to personal data and in particular the EU Regulation 2016/679 (GDPR), ePrivacy, DSA, PDPB, Consumer Protection Act 2019, IT Rules 2021 PDPD, Decree No. 70/2021/ND-CP on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
For the purposes of this Data Protection Policy:
“Advertiser(s)” – individuals or companies who market goods or services with Ads on Publishers’ Websites using Company Service as a mediator. Detailed rules for the advertiser are specified in the terms and conditions at the link. “Account” means a unique account created for You to access our Service or parts of our Service. “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to Clickadu s.r.o. “Data Controller”, for the purposes of the GDPR , refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. “Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet. “Other users” are individuals, or a company, or other legal entity on behalf of which such an individual is accessing or using the Service on the other website (Publisher’s website) where our service is provided. “Personal Data” is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; “Publisher(s)” – individuals or companies who display Advertisers’ ads on their Websites using Company Service as a mediator. Detailed rules for the publisher are specified in the terms and conditions at the link. “Service” refers to the services according to the Website. “Unregistered Users” – users of the platform-website https://www.clickadu.com, who are not authorized under the account and are not publishers or advertisers according to this policy. “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). “Website” refers to Clickadu s.r.o., accessible from https://www.clickadu.com. “You” means the platform users accessing or using the Service, or the company, or other legal entity including: Advertiser(s), Publishers, Other users and unregistered users
This document (Privacy Policy) is provided by Clickadu s.r.o (hereafter called as the “Clickadu”, “We”, etc.), registered by the legal address: Zenklova 32/28, Praha 8 – Libeň, 180 00, Czech Republic and constitutes an integral part of an agreement between and the Advertiser or Publishers (hereafter called as, “You”, “Your”, etc.), binding on the basis of acceptance of Clickadu Terms & Conditions. As the Part of this document We take commercially reasonable measures to adhere to all industry guidelines
You may also contact our support or representative team on any matter by the following contact details:
Email: support@clickadu.com
Email Data Protection Officer: dpo@clickadu.com
Email for requests concerning personal information and GDPR: privacy@clickadu.com
Support Ticket System (for creating applications and issues): support.clickadu.com
Please note that the general website www.clickadu.com and its subdomains may contain external links to other third-party websites. We do not accept any responsibility or liability for third-party websites on their policies or how they process your personal information. We strongly recommend you to examine these third-party websites policies before submitting any personal information.
Also pay attention that we process and collect personal data not only on the Website, but also on third-party websites of our partners when providing our services. Users and Unregistered Users.
We may collect and process the information that you provide to Us by submitting the registration form on our Website, subscribing to our newsletters form, and performing any other actions on our Website (Platform) and the Publisher’s website.
The information you provide may include your first name and last name, address, e-mail address and phone number, address, state, province, ZIP/Postal code, financial and credit card information, personal description and photograph, usage data and any other information.
As well, for a user performing any actions on our Website (Platform) we may automatically collect the following information:
Your Clickadu credential information, personal information, platform, OS and browser versions, timezone, IP (Internet protocol) and other technical information.
Analytical information considering your Website (Platform) visits. This information may include: The incoming source of your visit, your behavior flow, bounce-rate, enter and exit pages, page response times, certain pages spending time, and other information.
The information we receive from the third-party Information sources. (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). This document (Privacy Policy) and Cookie Policy reflects the occasion of receiving this data. As well, we may notify you when we receive any information about you from the third-parties and the purposes for which we intend to use that data.
We specify the types of information (mentioned above) that we collect, store and process:
Personal information
Usage data
Technical information
Data received from third parties.
The data that we may collect and process from each type of User is listed in the following table:
We use SSL certificates for end-to-end encrypted connections among all of our servers and Services. Data used for payment processing is encrypted and securely stored by independent companies that provide payment-processing services for the Сlickadu.
Legitimate groundsBy submitting your personal information (paragraph 3) and accepting the Clickadu Terms & Conditions and Privacy Policy on our Website (Platform) you consent with the legitimate grounds of processing your personal information.Please examine the list of legitimate grounds that sets out the manner in which we will process the different types of personal data we hold as data controller:We may use Personal Data for the following purposes:
We may use your personal information for marketing purposes to promote our Website (Platform) and Clickadu services.
In the process of using and processing data we keep a balance between the importance of complying with a legal obligation (AML, KYC, GDPR, etc.) and the importance of our legitimate interests (updating our records in order to study how customers use our Service).
Please note that we need additional consent in order to add you to Clickadu newsletter mailing list.
However, you still may receive technically-important information considering our services.
In both cases, you have a right to unsubscribe from any mailing lists using the opt-out form or any additional applications described in this Policy.
Disclosures to third parties.We may disclose your personal information in the following cases:For the purposes set out above who will be subject to obligations to process such information in compliance with the same safeguards that we deploy.On demand by court order and/or regulators or law enforcement and at the request of the competent authorities regarding legal proceedings or investigations.
World Base Check/KYC/AML and other checks.As part of the EU legal system, we have an obligation to perform certain procedures aimed at prevention of illegal activities. Under this obligation, We and other organizations may also access and use your personal information to undertake KYC/AML checks, credit checks, and checks to prevent fraudulent or illegal activity and money laundering. Your personal data may be passed to the relevant authorities including credit reference agencies and fraud prevention agencies if the information provided lacks credibility and/or You are suspected of fraudulent or illegal activity. As well, We will keep these records in order to prevent any illegal actions in the future.
Clickadu S.R.O. will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone other than anAcquirer, Visa/Mastercard Corporations, or in response to valid government requests.
Transfers of Your Personal Information to Other Countries
If we share the information with the EU and other regions with complete data protection laws, we can ensure that all of the data is transferred according to Privacy Policy and permitted by data protection legislation.
By using the Website, you agree to the possibility of transfer of the information we collect about you (including personal information) to any country in which we, members of our corporate group or our service provider are located.
In order to help keep your media secure, we partner with Google to provide publicly trusted SSL certificates for end-to-end encrypted connections among all of our servers, Services, and client applications.
We have put in place commercially reasonable physical, electronic, and organizational procedures to safeguard and secure the information we collect. For example, password information is stored on our servers and is protected using hashing and encryption technologies.
We do not store any of your payment or credit card information on our servers. The data is encrypted and securely stored by independent companies: banks or other officially licensed payment methods, which provide payment-processing services for Clickadu. Please, review their websites for more information.
Clickadu protects your identification documents sent for a Know Your Customer (KYC) verification process and will not transfer them to third parties.
For any question related to the collection and processing of your data by Digital Core Limited, you can contact our data protection officer by email at the following address: dpo@clickadu.com .
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online. If a standard policy for online tracking is adopted that we must follow in the future, we will inform You about it in a revised version of this privacy policy. Please contact dpo@clickadu.com
You have certain rights under applicable legislation, and in particular under the GDPR. We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
To exercise any of the below rights please contact us in the first instance on the above contact details.
Requests are free of charge, unless manifestly unfounded or excessive in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Requests will be processed within one month of receipt but this might be extended to two months in case of a complex request, where you have made a number of requests, or if the identity of the requestor cannot be verified. In such cases, we will notify you and keep you updated, and may seek additional information to allow us to understand your request.
Please note that the Company may be subject to legal and regulatory obligations which may limit or restrict the enforcement of your rights on some occasions.
Right to information
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source) and this Privacy Policy intends to provide such information. Of course, if you have any further questions you can contact us on the above details.
Right of access
You have a right to obtain confirmation from us as to whether or not your personal data are being processed and, where this is the case, a right of access to your personal data. We have an obligation to provide additional information when complying with an access request, and we have endeavored to capture this information within this Privacy Policy. We are happy to provide you with details of the personal data that we process about you. To protect our customers’ personal information, we follow strict storage and disclosure procedures, which means that we will require proof of identity from you prior to disclosing such information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to rectification
You have the right to have any inaccurate personal data rectified and to have any incomplete personal information about you completed.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If we do hold personal data and you believe it is incorrect, you may submit a request to us to correct any alleged mistakes.
We shall communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to erasure (‘right to be forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
We shall communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to restrict processing
Instead of requesting erasure, you also have the right to right to restrict processing of your personal information where:
We shall communicate any restriction of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to object to processing
You also have the right to object to processing of your personal information under certain circumstances, such as:
Exercise of this right may impact the services we can provide and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.
Right to data portability
With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to object
You have a right to object at any time to processing of personal data (including profiling) concerning you which is based on:
We do not process personal data on grounds of public interest or exercise of official authority. We do however rely on our legitimate interests as a lawful basis for processing personal data as outlined in this Privacy Policy. This applies, in particular, in the context of directly marketing to you.
We will only send you marketing information where you have agreed to opt-in to receive it. You have a choice about whether or not you wish to receive direct marketing information from us. We will not contact you for marketing purposes unless:
We will only use your preferred communication channels to contact you, and on each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You can change your marketing preferences and/or opt-out at any time by contacting us on the above details.
Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.
Other rights
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
Right to lodge a complaint with a relevant supervisory authority
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Office of the Commissioner for Personal Data Protection Commissioner. You may contact the Office on the below details: Clickadu s.r.o.Zenklova 32/28, Praha 8 – Libeň, 180 00, Czech Republic
This Website (platform) collects and uses cookies as it’s described in paragraph 3 so that we can differentiate you from other users of our Website. We use the data that we collect for providing a positive experience while browsing our Website (Platform), future Website improvements for your convenience, and overall high usability of our Service for all users. For detailed information on cookies collection and its purposes see our Cookies Policy.
The content of this document (Privacy Policy) and Cookie policy may change at any moment in the future without any further notice. We strongly recommend that you check this page from time to time to ensure that you agree with the current policy clauses.
Last updated: 2024.09.17