Privacy Policy

OVERVIEW Market Essentials Limited trading as AdEvolver ("we," "us," or "our") understands that you care about how information about you is used. This Privacy Policy (the "Policy") explains how we collect, maintain, use, and share information about you when you use our AI-powered advertising optimization platform and services (the "Services"). By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Your use of Services is at all times subject to this Privacy Policy. COMPANY INFORMATION Data Controller: Market Essentials Limited (Company Number: 16766177) Registered Office: 128 City Road, London, EC1V 2NX, United Kingdom Trading as: AdEvolver Website: https://adevolver.uk DEFINITIONS "3rd Party Advertising Networks" means any platform AdEvolver is connected to run advertising such as Meta (Facebook, Instagram), Google, TikTok, Twitter and LinkedIn. "Personal Data" means any information relating to an identified or identifiable natural person as defined by applicable data protection laws. "Data Controller" means Market Essentials Limited, which determines the purposes and means of processing Personal Data. "Data Processor" means any third party that processes Personal Data on behalf of Market Essentials Limited. "Services" refers to our AI-powered advertising optimization platform and related services. TYPES OF DATA COLLECTED We collect the following types of Personal Data: INFORMATION YOU PROVIDE: - Name and contact information (email, phone number) - Company name and business information - Account credentials (username, encrypted password) - Payment and billing information - Communications with our support team - Advertising campaign data and content you upload INFORMATION COLLECTED AUTOMATICALLY: - Usage data and analytics (how you use our Services) - Device information (IP address, browser type, operating system) - Cookies and tracking technologies - Log files and technical data - Performance metrics and system diagnostics ADVERTISING DATA: - Campaign performance metrics - Audience targeting information - Ad creative content and variations - Conversion and engagement data - Third-party platform integration data LAWFUL BASIS FOR PROCESSING (GDPR/UK GDPR) We process your Personal Data under the following lawful bases: 1. CONTRACT (Article 6(1)(b)): To perform our contract with you and provide the Services you have requested 2. LEGITIMATE INTERESTS (Article 6(1)(f)): To improve our Services, prevent fraud, ensure security, and conduct business analytics 3. CONSENT (Article 6(1)(a)): Where you have given specific consent for certain processing activities (e.g., marketing communications) 4. LEGAL OBLIGATION (Article 6(1)(c)): To comply with applicable laws and regulations HOW WE USE YOUR INFORMATION We use the information we collect to: SERVICE PROVISION: - Provide, maintain, and improve our AI-powered advertising Services - Process transactions and manage your account - Generate AI-powered advertising insights and recommendations - Optimize advertising campaigns using evolutionary algorithms - Integrate with third-party advertising platforms COMMUNICATION: - Communicate with you about your account and our Services - Send important service updates and security notifications - Provide customer support and respond to inquiries - Send marketing communications (with your consent) BUSINESS OPERATIONS: - Analyze usage patterns to improve user experience - Conduct research and development for new features - Ensure platform security and prevent fraud - Comply with legal obligations and enforce our terms INFORMATION SHARING AND DISCLOSURE We may share your information in the following circumstances: WITH THIRD-PARTY ADVERTISING PLATFORMS: We share necessary data with advertising platforms (Meta, Google, etc.) to manage and optimize your advertising campaigns according to your instructions. If you are a business customer processing personal data through our Service, please refer to the Data Processing Agreement section in our Terms of Service for detailed information about data processor responsibilities. WITH SERVICE PROVIDERS: We may share information with trusted third-party service providers who assist us in: - Cloud hosting and data storage - Payment processing - Customer support services - Analytics and performance monitoring - Security and fraud prevention FOR LEGAL REASONS: We may disclose information if required by law, court order, or to: - Protect our rights, property, or safety - Protect the rights, property, or safety of our users - Investigate fraud or security issues - Comply with legal processes BUSINESS TRANSFERS: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. WITH YOUR CONSENT: We may share information for other purposes with your explicit consent. INTERNATIONAL DATA TRANSFERS We may transfer your Personal Data to countries outside the European Economic Area (EEA) and United Kingdom. When we do so, we ensure appropriate safeguards are in place through the following mechanisms: ADEQUACY DECISIONS: - European Commission adequacy decisions for countries deemed to provide adequate protection - UK adequacy regulations for approved countries STANDARD CONTRACTUAL CLAUSES (SCCs): - We use European Commission approved Standard Contractual Clauses (2021/914/EU) with service providers in non-adequate countries - UK International Data Transfer Agreement (IDTA) for transfers from the UK - Additional safeguards including technical and organizational measures SPECIFIC TRANSFER SCENARIOS: - United States: We rely on SCCs with US service providers. Note that some US providers may not be covered by adequacy frameworks - Cloud Services: Data may be processed in multiple regions with appropriate contractual protections - Advertising Platforms: Meta, Google, and other platforms process data globally under their respective data transfer mechanisms DATA TRANSFER IMPACT ASSESSMENTS: We conduct Transfer Impact Assessments (TIAs) to evaluate the level of protection in destination countries and implement additional safeguards where necessary. Countries we may transfer data to include: - United States (cloud services, advertising platforms) - SCCs and additional safeguards - European Economic Area countries - adequacy decisions - Other countries as required for service provision - appropriate safeguards implemented You can request copies of the safeguards we have in place by contacting privacy@adevolver.uk. YOUR RIGHTS UNDER GDPR AND UK GDPR If you are located in the EEA or UK, you have the following rights: RIGHT OF ACCESS (Article 15): Request information about the Personal Data we hold about you, including a copy of your data. RIGHT TO RECTIFICATION (Article 16): Request that we correct inaccurate or incomplete Personal Data. RIGHT TO ERASURE (Article 17): Request that we delete your Personal Data in certain circumstances, such as when it's no longer necessary for the original purpose. RIGHT TO RESTRICT PROCESSING (Article 18): Request that we limit how we use your Personal Data in certain situations. RIGHT TO DATA PORTABILITY (Article 20): Request a copy of your Personal Data in a structured, machine-readable format. RIGHT TO OBJECT (Article 21): Object to certain types of processing, including direct marketing and processing based on legitimate interests. RIGHT TO WITHDRAW CONSENT: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal. RIGHTS RELATED TO AUTOMATED DECISION-MAKING (Article 22): Request human intervention, express your point of view, and contest decisions made solely by automated processing. To exercise these rights, please contact us at privacy@adevolver.uk. YOUR RIGHTS UNDER CCPA (CALIFORNIA RESIDENTS) If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA): RIGHT TO KNOW: Request information about: - Categories of Personal Data we collect - Sources of Personal Data - Business purposes for collecting Personal Data - Categories of third parties we share Personal Data with - Specific pieces of Personal Data we have about you RIGHT TO DELETE: Request deletion of Personal Data we have collected about you, subject to certain exceptions for: - Completing transactions or providing requested services - Security purposes and fraud prevention - Legal compliance obligations - Internal uses reasonably aligned with your expectations RIGHT TO OPT-OUT OF SALE: We do not sell Personal Data as defined by CCPA. RIGHT TO NON-DISCRIMINATION: We will not discriminate against you for exercising your CCPA rights by: - Denying goods or services - Charging different prices or rates - Providing different levels of quality - Suggesting you will receive different pricing or service levels To exercise these rights, please contact us at privacy@adevolver.uk or call our toll-free number (if applicable). COOKIES AND TRACKING TECHNOLOGIES We use cookies and similar tracking technologies to: ESSENTIAL COOKIES: Necessary for the website to function properly PERFORMANCE COOKIES: Help us analyze how you use our Services FUNCTIONAL COOKIES: Remember your preferences and settings TARGETING COOKIES: Provide personalized content and advertisements (with consent) You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Services. For detailed information about our cookie practices, please see our Cookie Policy. DATA RETENTION We retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods: - Account information: Until account deletion plus 7 years for legal compliance - Usage and analytics data: 3 years from collection - Marketing communications data: Until you unsubscribe plus 2 years - Payment and transaction data: 7 years for tax and accounting purposes - Customer support communications: 3 years from last contact - Security logs: 1 year from creation CHILDREN'S PRIVACY Our Services are not directed to children under 16 years of age. We do not knowingly collect Personal Data from children under 16. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us at privacy@adevolver.uk, and we will take steps to remove such information. DATA SECURITY We implement appropriate technical and organizational measures to protect your Personal Data against: - Unauthorized access, alteration, disclosure, or destruction - Accidental loss or damage - Unlawful processing Our security measures include: - Encryption of data in transit and at rest - Regular security assessments and updates - Access controls and authentication systems - Employee training on data protection - Incident response procedures However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security. PRIVACY POLICY CHANGES We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by: - Posting the updated Privacy Policy on our website with a new effective date - Sending you an email notification to your registered email address - Providing notice through our Services or other appropriate means Your continued use of the Services after any changes indicates your acceptance of the updated Privacy Policy. DATA PROTECTION OFFICER For questions about data protection, to exercise your rights, or to raise concerns, you can contact our Data Protection Officer at: Email: dpo@adevolver.uk APPLICABLE LAW AND DISPUTE RESOLUTION This Privacy Policy and all matters relating to your privacy and data protection are governed by and construed in accordance with the laws of England and Wales. JURISDICTION: Any disputes, claims, or proceedings arising out of or relating to this Privacy Policy or our processing of your Personal Data shall be subject to the exclusive jurisdiction of the courts of England and Wales. REGULATORY COMPLIANCE: - UK GDPR (as incorporated into UK law by the Data Protection Act 2018) - EU GDPR (Regulation 2016/679) for EEA residents - California Consumer Privacy Act (CCPA) for California residents - Other applicable local data protection laws DISPUTE RESOLUTION PROCESS: 1. Contact our Data Protection Officer at dpo@adevolver.uk 2. If unresolved, contact the relevant supervisory authority 3. Legal proceedings in English courts as a last resort SUPERVISORY AUTHORITY You have the right to lodge a complaint with the relevant supervisory authority: For EEA residents: Your local data protection authority For UK residents: Information Commissioner's Office (ICO) - Website: https://ico.org.uk/ - Phone: 0303 123 1113 - Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF CONTACT INFORMATION If you have any questions about this Privacy Policy or our data practices, please contact us: Privacy Inquiries: privacy@adevolver.uk Data Protection Officer: dpo@adevolver.uk General Support: support@adevolver.uk Legal Matters: legal@adevolver.uk Registered Office: Market Essentials Limited 128 City Road London, EC1V 2NX United Kingdom Website: https://adevolver.uk Please note: Email is our preferred method of communication for fastest response. Our registered office address is for legal and regulatory correspondence only. SPECIFIC PROVISIONS FOR AI AND AUTOMATED PROCESSING Our Services use artificial intelligence and automated processing to: AUTOMATED DECISION-MAKING: - Optimize advertising campaigns based on performance data - Generate audience targeting recommendations - Create and test ad variations using evolutionary algorithms - Provide real-time bidding and budget optimization PROFILING ACTIVITIES: - Analyze campaign performance patterns - Segment audiences for targeting recommendations - Predict campaign outcomes and optimization opportunities YOUR RIGHTS REGARDING AUTOMATED PROCESSING: - Request human intervention in automated decision-making processes - Express your point of view regarding automated decisions - Contest decisions that significantly affect you - Receive explanations about the logic involved in automated processing TRANSPARENCY MEASURES: - We provide clear information about our AI processing activities - You can access logs of automated decisions affecting your campaigns - We maintain human oversight of all automated systems - You retain control over final campaign decisions and implementations Last Updated: October 11, 2025