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Adsspark Limited – GDPR / UK GDPR Privacy Supplement

Effective Date: 2025/09/10

This section supplements our Master Privacy Policy and applies to personal data processed by Adsspark Limited in the context of offering goods or services to, or monitoring the behavior of, individuals located in the European Economic Area (EEA), United Kingdom (UK), and Switzerland.

Legal Bases for Processing

Under the GDPR/UK GDPR, we must identify a lawful basis for processing personal data. Adsspark relies on the following:

  • Consent: When you agree to marketing emails, cookies, or optional data sharing.
  • Contractual necessity: When processing is required to perform a contract with you (e.g., affiliate or advertiser agreements).
  • Legal obligation: When processing is necessary to comply with EU/UK laws (e.g., tax or record-keeping).
  • Legitimate interests: For fraud prevention, service improvement, and analytics, provided these interests are not overridden by your fundamental rights.

Data Subject Rights

As an EU/UK/Swiss data subject, you have the following rights under GDPR/UK GDPR:

  1. Right of Access: Request confirmation of whether we process your data and receive a copy.
  2. Right to Rectification: Request correction of inaccurate or incomplete data.
  3. Right to Erasure (“Right to be Forgotten”): Request deletion of your data in certain circumstances (e.g., no longer necessary, consent withdrawn, unlawful processing).
  4. Right to Restriction: Ask us to limit processing where accuracy is contested or processing is unlawful.
  5. Right to Data Portability: Request transfer of your data to you or another controller in a machine-readable format.
  6. Right to Object: Object to processing based on legitimate interests, including profiling and direct marketing.
  7. Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing).
  8. Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, unless legally permitted.

Exercising Your Rights

You may exercise these rights by contacting us at:

  • 📧 contact@adsspark.co
  • 📍 Room 502C, 5th Floor, Ho King Commercial Center, 2-16 Fa Yuen Street, Mongkok, Kowloon, Hong Kong

We may request proof of identity before fulfilling your request. We will respond within 30 days (extendable to 90 days for complex requests, with notice).

Cross-Border Data Transfers

Since Adsspark is headquartered in Hong Kong, personal data collected in the EU/UK may be transferred outside the EEA/UK.

  • We use Standard Contractual Clauses (SCCs) approved by the European Commission and UK Addendum where required.
  • We implement technical and organizational measures to protect data during transfer.
  • Where necessary, we conduct transfer impact assessments to evaluate risks.

Data Protection Officer (DPO) & EU/UK Representatives

  • DPO: [Insert appointed Data Protection Officer’s name and contact details].
  • EU Representative (Article 27 GDPR): If required, we will appoint an EU-based representative to handle queries.
  • UK Representative (Article 27 UK GDPR): If required, we will appoint a UK-based representative.

Details of these representatives will be provided in updated versions of this policy.

Data Retention (GDPR Standards)

We apply GDPR principles when retaining personal data:

  • Data is kept only as long as necessary for the purposes collected.
  • We apply stricter retention limits for sensitive categories of data.
  • When data is no longer required, we delete, anonymize, or aggregate it securely.

Supervisory Authorities

If you believe your rights have been infringed, you have the right to lodge a complaint with your local data protection authority.

Examples include:

  • UK: Information Commissioner’s Office (ICO) – https://ico.org.uk
  • France: CNIL – https://www.cnil.fr
  • Germany: Each state has its own DPA (e.g., BayLDA in Bavaria).
  • EU list of DPAs: https://edpb.europa.eu/about-edpb/about-edpb/members_en

We encourage you to contact us first, so we can try to resolve your concerns.

Automated Decision-Making & Profiling

  • Adsspark does not engage in automated decision-making that produces legal or similarly significant effects without human involvement.
  • Where profiling is conducted for marketing or analytics, it is limited, transparent, and subject to safeguards.

Additional Notes

  • We do not knowingly process children’s data under 16 years of age (or the minimum age set by local law).
  • For marketing communications, we always seek opt-in consent from EU/UK users.
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