PREAMBLE
Fluxrise LTD. is a company registered in the Republic of Cyprus
The Company provides a business-to-business (B2B) advertising technology platform (fluxrise.net), which enables Clients — such as advertisers and advertising agencies — to manage, optimize, and analyze digital advertising campaigns.
Access to the Platform is limited exclusively to Clients acting in a professional or business capacity. The Platform is not designed for or made accessible to Users, i.e., individual consumers or members of the general public.
The Platform does not host or display advertisements to Users directly. It functions solely as a backend system through which Clients configure campaigns. These campaigns are then delivered through third-party publishers, mobile applications, or other advertising channels to Users.
In the course of campaign execution, certain data related to Users — including, but not limited to, IP addresses, cookies, device identifiers, and behavioral data — may be processed by the Platform. This processing is conducted solely for purposes such as ad targeting, frequency control, and performance measurement. The Company does not collect, retain, or control this data but processes it temporarily on behalf of its Clients as a technical intermediary.
Users who engage with ads served through campaigns managed via the Platform may be redirected to third-party websites or services, typically belonging to Clients. The Company assumes no responsibility for the content, privacy practices, or terms and conditions of these external websites or services.
Clients are solely responsible for ensuring that their advertising campaigns comply with all applicable laws and regulations, including, but not limited to, data protection and privacy laws (e.g., GDPR, CCPA), and for obtaining all necessary consents from Users where required by law.
The following Privacy Policy (the “Policy”) explains how the Company processes personal data in connection with its website and Platform. For the purposes of this Policy:
“User” refers to any individual who is shown, interacts with, or is otherwise affected by advertisements delivered via campaigns run through the Platform. Users do not access the Platform directly and are not in a contractual relationship with the Company.
“Client” refers to an advertiser or advertising agency that uses the Platform to configure, manage, or deliver advertising campaigns. Clients may access dedicated services and features via account-based access.
The Company is committed to protecting the privacy of both Clients and Users. In particular, the Company undertakes to maintain a level of protection of personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
Personal data is processed by the Company in its role as a data processor acting on behalf of its Clients. (INSERT COMPANY INFORMATION) acts solely as a technical intermediary and does not collect or permanently store User data.
The Company may also process certain data about Users and Clients through cookies and similar technologies, solely for operational and analytical purposes, as described below.
By confirming the relevant notification displayed on the website or Platform, the Client expressly acknowledges and agrees that the Company may process data in accordance with this Policy. In the case of Users, data processing is conducted on behalf of and under the instructions of the relevant Client.
Such confirmation by the Client constitutes informed, specific, and unambiguous consent to the processing of their data for the purposes outlined in this Policy. The Client acknowledges that they have received clear and comprehensive information about the categories of personal data processed, the purposes of such processing, and their rights under applicable data protection laws.
By entering into a service agreement with the Company, the Client further agrees that the Company may process additional categories of personal data necessary for the fulfillment of services, compliance with legal obligations, and client account management. This includes, but is not limited to, identity verification and service provision data. This processing is an inherent part of the contractual relationship.
For the purposes of this Policy, “personal data” means any information relating to an identified or identifiable natural person, processed under this Policy. The Company undertakes appropriate technical and organizational measures to ensure the protection of personal data.
“Processing of personal data” refers to any operation or set of operations performed on personal data, whether by automated means or otherwise. This includes, but is not limited to, collection, recording, organization, storage, adaptation, retrieval, consultation, use, transmission, anonymization, or erasure, in the context of ad delivery and related services.
The Company does not collect, store, or independently process any personally identifiable information (PII) related to Users. All User-related data processed through the Platform — such as IP addresses, device identifiers, or behavioral signals — is either anonymized, pseudonymized, or used in aggregate form and is not linked to any identified or identifiable individual by the Company.
All collection of User data (where applicable) is conducted exclusively by the Client or its authorized third-party partners (e.g., publishers or analytics providers).
CATEGORIES OF COLLECTED DATA
The Company processes different types of information depending on whether the individual is a User or a Client. The scope, purpose, and method of data collection differ accordingly.
| Users | Clients |
|---|---|
| Technical information: IP address; Device type and operating system; Browser type and version; Language preferences; Screen resolution and time zone. | Information provided during registration: Full name (individual or company representative); Email address and phone number; Username and password; Country of residence or incorporation; Preferred language and communication preferences. |
| Usage data: Pages visited; Time spent on the site; Clickstream data (links clicked, navigation paths); Referring URLs (how the user arrived at the site). | Information provided during contract formation: Personal identification data (e.g., passport, national ID, driver’s license); Corporate documentation (e.g., certificate of incorporation, tax identification number, business licenses); Proof of address (utility bills, bank statements); Signed agreements or service contracts. |
| Cookies and tracking technologies: Session cookies; Persistent cookies; Web beacons and pixels. | Billing and financial data: Invoicing details; Bank account or payment method information; Transaction history and payment confirmations. |
Interaction data, such as mouse movements, scroll activity, or interactions with forms and buttons (used for analytics or UX optimization) | Service usage data: Logs of service requests or inquiries; Communication history (emails, chats, support tickets); Files or documents uploaded via the platform; Activity logs related to the use of services provided under contract. |
| Approximate geolocation data: Derived from IP address. | Compliance and verification data: KYC (Know Your Customer) and AML (Anti-Money Laundering) checks; Sanctions list screening results; Risk assessments and internal audit logs. |
In addition to the categories of information listed above, Clients are also subject to the same data collection practices applicable to Users. This means that technical data, usage information, cookies, geolocation data, and other automatically collected information described above are also collected from Registered Clients when they access or use the website.
The Company may also collect other data and information necessary for the provision of its services. In such cases, the Users and/or Clients shall receive a request to provide separate consent for the collection of such additional data.
USE OF TECHNOLOGY FOR PERSONAL DATA COLLECTION
The Company uses various technologies to facilitate the delivery and measurement of advertising campaigns managed through the Platform. These technologies may involve the temporary processing of certain technical data related to Users (such as device identifiers, cookie data, or IP addresses) for the sole purpose of enabling advertising features such as targeting, frequency capping, and analytics. The Company does not collect or store this data for its own purposes but processes it exclusively on behalf of its Clients as a technical intermediary.
When a Client accesses the Platform, the Company may automatically collect certain technical data from the Client’s browser or device, subject to the Client’s consent where required by law. Such data may include the Client’s IP address, device type, operating system, browser type and language, and general location. This information is used strictly for security, account management, and service optimization purposes.
The Company may use standard internet technologies, including but not limited to cookies, pixels, and tracking scripts, to support the functionality of the Platform and the performance of advertising campaigns. Such technologies may be embedded by Clients or their authorized third parties in advertisements served to Users via third-party publisher environments. The Company itself does not embed tracking mechanisms directly into User-facing content but may process resulting data in real time to enable reporting, optimization, and campaign measurement, strictly under the instructions of its Clients.
PURPOSES OF AND LAWFUL BASES FOR THE COLLECTION OF THE PERSONAL DATA
The Company processes the personal data relating to Users and Clients, which are listed above of this Policy, in order to provide the best service possible to the Clients. This article gives the Clients an overview of how their personal data shall be processed in the context of their use of the Platform.
| Category of personal data | Purpose of Collection | Legal Bases |
|---|---|---|
| IP address, device type and OS, browser, language preferences, screen resolution, time zone, approximate geolocation data, derived from IP address | Ad delivery optimization, geotargeting, fraud prevention, performance analytics | Legitimate interests |
| Pages visited, time spent on site, clickstream data, referring URLs | Engagement analysis, campaign optimization, user journey personalization | Legitimate interests |
| Cookies (session and persistent), web beacons, tracking pixels | Functionality support, ad effectiveness measurement, retargeting | Legitimate interests – for essential cookies |
| Mouse movements, scroll behavior, interaction with forms/buttons | User experience (UX) optimization, technical troubleshooting, interaction monitoring | Legitimate interests Legal obligation |
| Full name, email address, phone number, username, country, preferred language | Account creation and management, communication, support | Legitimate interests |
| Identification documents (passport, ID, driver’s license), corporate certificates, tax numbers, proof of address, signed contracts | Contract execution, identity verification, compliance with legal obligations (e.g., KYC/AML) | Legitimate interests Legal obligation |
| Billing data, bank/payment method information, transaction history | Invoicing, payment processing, accounting, financial audits | Legal obligation |
| Service request logs, communication records (emails, chat, support), uploaded files, service usage logs | Client support, dispute resolution, contract fulfillment | Legitimate interests Legal obligation |
| KYC/AML data, sanctions screening results, internal risk assessments | Compliance with legal obligations related to anti-money laundering, counter-terrorist financing, and sanctions | Legitimate interests |
| IP address, device type and OS, browser, language preferences, screen resolution, time zone | Ad delivery optimization, geotargeting, fraud prevention, performance analytics | Legitimate interests Legal obligation |
The Company may collect additional categories of personal data beyond those explicitly listed in this Policy, where necessary to provide specific services, fulfill legal obligations, or enhance the Users and/or Clients’ experience. Such data shall be collected only:
with the explicit and informed consent of the User and/or Client, where required by law; or on another lawful basis permitted under applicable data protection legislation, such as for the performance of a contract, compliance with a legal obligation, or the pursuit of the Company’s legitimate interests.
In each case, the Company ensures that data subjects are properly informed about the nature and purpose of the data collection and their rights in relation to such processing.
THE RECIPIENTS OF THE PERSONAL DATA
The personal data collected and processed by the Company may be disclosed to the following recipients or categories of recipients:
To individuals authorized by the Company to process personal data on behalf of Clients, including Company employees, who are bound by confidentiality obligations and non-disclosure agreements;
To service providers engaged by the Company to perform specific processing operations related to the data of Clients and, where applicable, technical data related to Users processed on behalf of Clients. These may include:
Payment service providers (for processing transactions initiated by Clients);
Hosting and infrastructure providers (for the maintenance and operation of the Platform);
Platform maintenance and development service providers;
Analytics providers involved in campaign performance measurement;
Email delivery services (for transactional or service-related communication with Clients)..
All subcontractors engaged by the Company provide appropriate safeguards as required under applicable data protection laws. These subcontractors are granted access only to the data strictly necessary to perform their services and are not authorized to process any data for their own purposes.
The Company does not share or disclose any personal data of Users (i.e., individuals who receive advertising through campaigns run by Clients) for its own purposes. Any processing of User data is conducted solely on behalf of and under the instructions of Clients, in accordance with applicable data protection obligations.
DATA RETENTION PERIOD
The Company retains personal data of Clients only for as long as is strictly necessary to fulfill the purposes for which the data was collected, including the performance of services and compliance with contractual or legal obligations.
After the end of the active use period, Client data may be archived with restricted access for a limited additional duration, solely to enable the Company to meet legal or regulatory requirements related to data retention and audit.
Personal data of Users is not retained by the Company beyond the technical timeframe required to facilitate real-time ad delivery and analytics on behalf of Clients. Once processing is complete, such data is either deleted or anonymized, unless longer retention is legally required by Clients acting as data controllers.
PROTECTION OF PERSONAL DATA
The Company implements appropriate technical and organizational measures to protect the personal data of its Clients, and any User data processed on their behalf, against unauthorized access, disclosure, alteration, or destruction.
Although the Company follows industry best practices and security standards, it cannot guarantee absolute security of any information transmitted or stored. Clients are responsible for maintaining the security of their own login credentials and communication channels.
All data processing activities are carried out in accordance with recognized international standards and legal frameworks governing the collection, use, and protection of personal data, including GDPR and related regulations.
THE RIGHTS OF THE USERS AND CLIENTS
Clients have the right to access, rectify, erase, and receive a copy of their personal data, as well as the right to restrict or object to processing, withdraw consent, and request data portability, subject to applicable legal requirements.
Users (i.e., individuals who are shown advertisements by Clients through the Platform) also retain the rights granted under applicable data protection laws. However, since the Company processes User data solely on behalf of Clients, any such requests should generally be directed to the relevant Client acting as the data controller. The Company will assist Clients in responding to such requests where required by law.
Clients and, where applicable, Users may object at any time to the processing of their personal data for direct marketing purposes or in accordance with applicable regulations.
Requests may be submitted to the Company:The Users and Clients may send their request to Company:
in writing, to the following address: ([email protected]);
by e-mail, to: ([email protected])
DELETION OF PERSONAL DATA
Clients may request the deletion of their personal data held by the Company by sending a written request to: ([email protected]).
With respect to Users, as the Company does not collect or store User data for its own purposes and processes such data solely on behalf of Clients, any deletion requests from Users should be addressed to the Client responsible for the relevant advertising campaign. The Company will assist Clients in fulfilling such requests if technically feasible and legally required.
Upon receipt of a valid deletion request, the Company will take reasonable steps to delete the relevant personal data from its systems, unless such data must be retained to comply with legal obligations or for the establishment, exercise, or defence of legal claims.
Clients acknowledge that deleting certain data may impact access to or functionality of the Platform
CHANGES TO THIS PRIVACY POLICY
The Company may modify or update this Privacy Policy at any time, at its sole discretion. Any such changes will become effective upon publication of the revised version on the Platform, along with an indication of the last update date.
Where required, the Company will notify Clients and, where appropriate, Users of any material changes to this Privacy Policy. Notification may include email communication or a prominent notice on the Platform.
Clients and Users are encouraged to review this Privacy Policy periodically to remain informed about how their data is processed and protected.
COOKIES COLLECTION
Cookies are small text files placed on devices when visiting websites. They are widely used to ensure website functionality, improve user experience, and provide analytical data to operators.
Cookies may be session cookies (deleted when the browser closes) or persistent cookies (stored for a defined period or until deleted).
Cookies placed by the Company enable it to recognize devices accessing the Platform and to store information about how Clients use the Platform for campaign management.
The Company does not place cookies for collecting or storing personal data of Users (end recipients of advertising) but may process cookie data collected by Clients in relation to their campaigns.
In accordance with applicable laws, the Company and Clients will seek consent where required before placing non-essential cookies.
The Company uses the following types of Cookies:
| Cookie Category | Description |
|---|---|
| Strictly Necessary Cookies | These cookies are essential for the operation of the Platform and cannot be disabled. They are typically set in response to actions made by you, such as logging in, filling out forms, or setting privacy preferences. |
| Functional Cookies | These cookies enable the Platform to provide enhanced functionality and personalisation. They may be set by us or by third-party providers whose services we have integrated into our Platform. |
| Performance and Analytical Cookies | These cookies allow us to collect information about how users interact with the Platform, including the number of visitors, the pages visited, and traffic sources. This information helps us improve the performance and usability of the Platform. |
| Targeting and Advertising Cookies | These cookies may be set through our Platform by advertising partners to build a profile of your interests and deliver relevant advertisements on other websites. They do not store directly identifiable personal data, but they are based on uniquely identifying your browser and internet device. |
| Third-Party Cookies | We may allow third-party service providers to place cookies on your device for the purposes described above. These providers may include analytics companies and advertising networks. The Company does not know which cookies are used by these third-party websites. The use of cookies by third parties is subject to their own privacy policies and not this Policy. |
| Purposes of Cookie Collection | The Company uses cookies for the following purposes: |
LEGAL BASES FOR THE USE OF COOKIES
Upon first access to the Platform, Clients will see a cookie banner enabling them to accept, reject, or customize cookie preferences.
Users (end recipients of advertising) may be asked for consent by Clients when interacting with ads, according to applicable regulations.
Consent is obtained through clear affirmative action, and mechanisms to withdraw consent are equally accessible and user-friendly.
Clients and Users may modify or withdraw their consent at any time through platform settings or browser controls.
The Company maintains records of consent as required.
WHO ARE THE RECIPIENTS OF THE DATA COLLECTED THROUGH THE COOKIES?
Data strictly necessary to provide services to Clients is not disclosed to third parties except the Platform hosting provider.
Data related to performance, audience measurement, and conversion tracking may be used by the Company or third parties such as Google, Facebook, LinkedIn, Pinterest, and Inspectlet. Each receives only data relevant to its services.
Data may also be disclosed to:
Data may also be disclosed to authorized Company personnel bound by confidentiality agreements, external advisors (lawyers, auditors), authorities as required by law, or third parties in case of corporate restructuring
CONSENT AND COOKIE SETTINGS
Clients receive a cookie consent banner on their first visit to the Platform and may withdraw or change cookie preferences anytime via browser or device settings.
Users may be presented with consent requests by Clients or third parties when interacting with advertisements.
Disabling certain cookies may impact Platform functionality.
MANAGING COOKIES
Users and/or Clients can control and delete cookies through your browser settings. Instructions for managing cookies in commonly used browsers are available at:
For more information about cookies and how to manage them, please visit: www.allaboutcookies.org
COOKIE RETENTION PERIODS
Cookies placed on Clients’ devices are retained up to thirteen (13) months, then deleted or renewed upon consent.
Personal data collected through cookies is retained up to twenty-five (25) months unless longer retention is legally required, after which it is deleted or anonymized.
The Company does not retain personal data of Users beyond processing on behalf of Clients.
CONTACT INFORMATION
If you have any questions or concerns regarding this Policy or our use of cookies, please contact us at:
Email: [email protected]