PRIVACY POLICY

1. The terms we can use in this Privacy Policy:
   1. “Adheart” – HRET International Development LTD Agias Faneromenis, 143, PATSIAS COURT, 2nd floor, Flat/Office 201, 6031, Larnaca, Cyprus, whose Services are available at the Website.
   2. “Adheart‘s Services” (hereinafter “Services”) – consulting services for analytics, collection and tracking of data about an advertisement of the Facebook advertising network, which include: - providing the User with access to the catalog of advertisements identified by Adheart; - providing the User with access to the catalog of mobile applications identified by Adheart.
   3. “Administration of the Website” (hereinafter referred to as the “Administration”) - employees authorized to manage the Website, who organize and/or process Personal data, and also determine the purposes of processing Personal data, the composition of Personal data to be processed, actions (operations) committed with Personal data.
   4. “Personal data” - any information relating directly or indirectly to a specific or identifiable subject of personal data (“User”).
   5. “Personal data processing” - any action (operation) or a set of actions (operations) took with or without the use of automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal data.
   6. “Confidentiality of Personal data” - a mandatory requirement not to allow the disclosure of Personal Data without the consent of the Users or the existence of other legal requirements.
   7. “Website User” (hereinafter referred to as the “User”) is a person who has an access to the Website via the Internet and / or uses the Services.
   8. “Cookies” — a small piece of data sent by a web server and stored on the User‘s computer, which the web client or web browser sends to the web server in an HTTP request every time they try to open a page of the Website. The users are entitled to disable the creation of cookies or delete existing ones using the appropriate settings of the web browser, however, in this case, it will not be possible to fully use the functionality of ADheart.
   9. “IP-address” — Internet Protocol address, that is a series of numbers that identifies any device on a network.

1. The User‘s use of the Website and/or the Services means acceptance of this Privacy Policy and the terms of processing of the User‘s Personal data.
2. If Users disagree with the terms of the Policy, they must immediately stop using the Website and/or the Services.
3. This Policy is applied only to the Website. ADheart does not control and is not responsible for the third parties‘ websites, which the User can find following the links available on the Website.
4. The Administration does not check and is not responsible for the accuracy of the Personal Data provided by the User, however, it assumes that the User provides reliable and sufficient Personal data, and also keeps this information to be relevant.

1. The ADheart can acquire, store, process, use, and disclose Personal Data submitted by the User while using the Website and/or Service, as defined by this Policy. The User authorizes ADheart the right to receive, store, process, use, and disclose the Subject‘s Personal Data in accordance with the terms of this Policy by using any aspect of the Website and/or Service. ADheart collects, stores, processes, and uses the User‘s Personal Data to allow Users to use the Website and/or Services, as well as to defend the rights and legitimate interests of the User of Personal Data as set forth by law.
2. Personal data granted for processing under this Policy is provided by the User by filling out special forms on the Website and includes the following information:
   1. contact information of the User;
   2. email address (e-mail);
   3. Vkontakte page and name.
3. Any other personal information not is also a subject to secure storage and non-distribution, except as provided in paragraphs 5.2. and 5.3. of this Policy.

1. The Administration may use the User‘s Personal Data for the following purposes:
   1. User identification.
   2. Provision the User with access to the personalized resources of the Website.
   3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, processing requests and applications from the User.
   4. Confirmation of the accuracy and completeness of the Personal Data provided by the User.
   5. Providing the User with effective client and technical support in case of problems related to the use of the Website.
   6. Providing and paying for the Services, communicating with the User in order to inform him about changes or additions to the Services, or about the availability of any services provided by ADheart.
   7. Evaluation of the quality of the Services, implementation of ADheart marketing activities.
   8. Protection of the rights and legitimate interests of the User, ADheart and third parties, in accordance with applicable law.

1. The processing of the User‘s Personal data is carried out within a year, in any legal way, including in Personal data information systems using automation tools or without using such tools.
2. The User‘s Personal data may be transferred to authorized state authorities only based on and as it is prescribed by applicable law.
3. In case of loss or disclosure of Personal Data, the Administration informs the User about the loss or disclosure of such a Personal Data.
4. The Administration takes the necessary organizational and technical actions to protect the User‘s Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

1. The User‘s Personal data is treated in compliance with generally accepted international law, the laws of the Cyprus, and the rules that apply to you, including but not limited to:
2. If you live in the European Union (EU), you have privacy rights and all Personal Data processing is governed by regulations and rules that follow Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, also known as the General Data Protection Regulation (“GDPR”).
3. If you are located in the United Kingdom, all Personal Data processing is carried out in compliance with the Data Protection Act 2018 ("DPA 2018") and the UK General Data Protection Regulation (“UK GDPR”).
4. If you are based in Australia, all Personal Data processing is done in line with the Privacy Act 1988‘s norms and rules.
5. If you are located in Canada, all Personal Data processing is carried out in compliance with the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
6. If you live in New Zealand, all Personal Data processing is done in compliance with the Privacy Act 2020‘s regulations and procedures.
7. If you live in California, all Personal Data processing is done in accordance with the California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq. (“CCPA”) standards and procedures.
8. If you are located in Brazil, all Personal Data processing is done in line with the Lei Geral de Proteço de Dados (“LGPD”) legislation and rules.
9. The Children‘s Online Privacy Protection Act (“COPPA”) governs the online collecting of personal information about minors under the age of 13 by persons or businesses subject to US jurisdiction, including children outside the US (affected person). Before providing Personal Data on the Site, such Users must get parental approval. You may consent to the collection and use of your COPPA affected individual‘s information if you are the parent or guardian of that person, by emailing us at [email protected] you can withdraw your consent, inspect your COPPA Personal Data of the User, request that it be deleted, and/or refuse to enable continued collection or use of your COPPA data subject at any time.

1. To secure your Personal Data, ADheart follows the following principles, which are based on existing Cyprus legislation. If you live in the European Union (EU) we process your Personal data in compliance with the Art. 5 of the EU General Data Protection Regulation (GDPR):
   1. The principle of purpose limitation means that ADheart only collects Personal data for specific, explicit, and legitimate objectives, and ADheart doesn‘t process it in ways that are incompatible with those goals.
   2. Data accuracy is a principle that ADheart follows to ensure that Personal data is accurate and, where necessary, kept up to date. ADheart takes every reasonable precaution to guarantee that erroneous Personal data is promptly destroyed or corrected, taking into account the reasons for which it is collected.
   3. Principles of lawfulness, fairness, and transparency  - ADheart processes Personal Data about the data subject in a lawful, fair, and transparent manner.
   4. The principle of data minimization states that ADheart gathers only as much Personal data as is essential for the reasons for which ADheart is processing Personal data.
   5. Storage limitation principle - ADheart maintains Personal data in a form that allows data subjects to be identified for no longer than is necessary for the purposes for which the personal data are processed.

1. The User is obliged:
   1. Provide Personal Data that is necessary for ADheart to provide the Services.
   2. Do not disclose the data required to enter the ADheart personal account, and do not transfer access to the personal account to third parties.
   3. Do not use any automated means to collect data from the Website.
2. The Administration is obliged:
   1. Use the Personal Data solely for the purposes specified in clause 4 of this Policy.
   2. Ensure the storage of Personal Data information secretly, not to sell, exchange, publish, or disclose in other possible ways the transferred Personal Data of the User, with the exception of paragraphs 5.2. and 5.3. of this Policy. The provision of the User‘s information to third parties is made only in accordance with his instructions or if necessary in order to provide the User with a certain Service, or for other reasons in accordance with applicable law.
   3. Take reasonable and necessary precautions to protect the User‘s Personal Data.
   4. To carry out blocking of Personal data relating to the relevant User, from the moment of the request of the User or his legal representative or the authorized body for the protection of the rights of subjects of personal data for the period of verification, in case of detection of false personal data or illegal actions.
3. If Personal Data is disclosed, Adheart and the Administration are not responsible if this information:
   1. Had become publicly known before its loss or disclosure.
   2. It was received from a third party until it was received by the Administration.
   3. Was disclosed with the consent of the User.
4. In case of violation of any of the obligations specified in paragraphs 6.1.1-6.1.4, the User‘s personal account may be permanently blocked without the possibility of unblocking and refunding funds for the Services provided.

1. All issues or conflicts between the parties over the Policy‘s execution must be handled through dialogue. It is mandatory to send firstly a claim to another Party (a written proposal for a voluntary settlement of the dispute).
2. The recipient of the claim notifies the claimant in writing of the results of the consideration of the claim within 30 calendar days from the date of receipt of the claim.
3. If the parties do not reach an agreement within 50 (fifty) days, the matter may be brought before a court in Adheart‘s jurisdiction.
4. The current legislation of Cyprus is applied to this Privacy Policy and the relationship between the User, the Administration and Adheart.

1. Adheart is entitled the right to make changes to this Privacy Policy without the consent of the User.
2. The new Privacy Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy.
3. All suggestions or questions regarding this Policy should be directed to [email protected].
4. The current Privacy Policy is posted on the web page at https://adheart.me/terms-of-service/.

Name: IFZA Property FZCO

Registration address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates

Phone number: +971 4 228 52 85

TEHNOTYPE - FZCO

28996