Adipolo Privacy Policy **Adipolo Privacy Policy** **Effective Date:** June 24, 2025 — ### 1. Introduction Adipolo (“we,” “our,” or “us”) operates the Adipolo advertising program and the websites adipolo.com, adipolosolutions.com (collectively, the “Sites”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect information about you in compliance with the EU General Data Protection Regulation (GDPR), California’s Consumer Privacy Act (CCPA), and other applicable laws. ### 2. Information We Collect #### 2.1 Device Information We and our third‑party service providers automatically collect information about your device and browsing activity, including: * Web browser type and version * IP address and general geographic location (country/region) * Device identifiers (mobile advertising IDs, localStorage, IndexedDB) * Referring/exit pages, time stamps, and interactions with ads and content * Anonymous identifiers stored via localStorage or ad SDKs #### 2.2 Order Information When you make a purchase through the Sites, we collect: * Name, billing and shipping address * Payment details (e.g., encrypted credit card numbers, PayPal account) * Email address and phone number ### 3. How We Use Information We use Device Information to: * Detect and prevent fraud and security incidents * Analyze and improve our Sites, products, and advertising performance * Deliver and optimize personalized ads via legitimate interest We use Order Information to: * Process and fulfill your orders (billing, shipping, invoices) * Communicate order updates and provide customer support * Screen for potential risk or fraud under legitimate interest ### 4. Lawful Bases for Processing | Purpose | Data Category | Lawful Basis | Retention Period | | ——————————————- | ——————- | ————————- | —————— | | Store/access device identifiers | Device Information | Consent | 395 days | | Personalize and select ads | Device Information | Consent | 395 days | | Measure advertising performance | Device Information | Legitimate interest (LIA) | 395 days | | Measure content performance | Device Information | Legitimate interest (LIA) | 395 days | | Develop and improve services | Device Information | Legitimate interest (LIA) | 395 days | | Order processing and transaction management | Order Information | Contractual necessity | 7 years | | Security, fraud prevention | Device & Order Info | Legitimate interest (LIA) | 395 days / 7 years | | Save and communicate privacy choices | Privacy signals | Legitimate interest (LIA) | 395 days | > **Consent:** We obtain explicit opt‑in consent before any profiling or ad personalization. > **Legitimate interest:** We perform and document a Legitimate Interest Assessment (LIA) to ensure our interests do not override your rights. ### 5. Data Retention * **Device Information:** Retained up to 395 days (13 months) in accordance with IAB TCF guidelines. * **Order Information:** Retained for up to seven (7) years to comply with financial and tax regulations. * **Privacy Signals:** Retained for up to 395 days. ### 6. Sharing Your Personal Information We may share your data with: * Advertising partners (SSPs, DSPs, ad networks) for ad delivery and analytics * Payment processors and logistics providers to fulfill orders * Analytics providers (e.g., Google Analytics) for Site performance insights * Law enforcement, courts, or regulators when required by law or to protect our rights All third parties are contractually bound to protect your data and only use it for the purposes we specify. ### 7. Your Rights Depending on your jurisdiction, you may have the right to: * Access, correct, update, or delete your personal data * Object to or restrict processing of your data * Withdraw consent at any time (without affecting prior processing) * Receive a copy of your data in a structured, portable format * Opt out of the sale of personal data (CCPA residents) To exercise your rights, contact us at **brandon@adipolo.com We will respond within one month. ### 8. Security Measures We implement technical and organizational safeguards, including: * Encryption in transit (TLS) and at rest * Access controls and audit logging * Regular security assessments of our systems and vendors ### 9. Children’s Privacy Our Sites are not directed to children under 16. We do not knowingly collect personal data from minors. If you believe we have collected data from a minor, please contact us to request deletion. ### 10. CCPA/CPRA Notice to California Residents Under California law, residents have additional rights, including: * Right to know what personal data is collected, used, shared, or sold * Right to delete personal data * Right to opt out of sale of personal data * Right to non‑discrimination for exercising privacy rights Submit CCPA requests at brandon@adipolo.com. ### 11. Changes to This Policy We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the revised version with a new Effective Date. ### 12. Contact Us If you have questions or complaints, please contact: **Adipolo Ltd.** Albert Kioso 3, Tel Aviv, 6813470, Israel Email: brandon@adipolo.com