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Privacy Policy

What we collect, why we collect it, and what we do not do. The short version: we collect what an order needs, we set two first-party cookies — one to keep you signed in, one to remember how you first found us — and we run no third-party analytics or advertising trackers.

Last updated

Draft pending legal review. The description of what we collect matches how the service works. The legal basis, retention periods and controller details in brackets are to be completed by counsel before launch.

Who is responsible

The controller of your personal data is [legal entity name and address]. You can contact us about privacy at [privacy contact].

What we collect

When you create an account

  • Your name, email address and project name.
  • A one-way hash of your password. We never store the password itself and cannot read it.

When you place an order

  • The placements ordered, their prices, and the order’s status.
  • Payment records from our processor: the invoice, the payment status, the amount and coin paid, and the deposit address the processor issued. We do not receive or store card details, and we never hold your private keys.
  • The campaign content you supply for the placement.

How you found us

  • On your first visit we note the kind of source that brought you (search engine, AI assistant, social network, another website, a campaign link or direct), the referring site’s domain, any campaign tags in the link, and the page you landed on. It is stored in a cookie on your device and copied to your account if you sign up. We do not record the full address of the page you came from.

Security records

  • Sign-ins, failed sign-ins, password and two-factor changes, with the time and IP address. We keep these to detect and stop attempts to break into accounts.

If you apply to list your site

  • The site, its traffic and prices, and the contact details you give us, to review the application.

What we do not collect

We run no third-party analytics, no advertising pixels and no third-party tracking scripts. We do not build profiles of visitors or sell data to anyone.

Why we use it

  • To create and secure your account and keep you signed in.
  • To take, fulfil and support your orders, and to deal with refunds.
  • To arrange your placement with the publisher.
  • To understand which channels bring customers, in aggregate, so we know where to spend effort.
  • To protect accounts against break-in attempts.
  • To meet legal and accounting obligations.

Legal basis

[Legal basis for each purpose — for example, performance of a contract for orders, legal obligation for accounting records — to be confirmed by counsel]

Who we share it with

  • NOWPayments, our payment processor, which issues invoices and processes cryptocurrency payments under its own privacy policy.
  • The publisher or supplier of the placement you buy, which receives your campaign content and the details needed to run it.
  • Our hosting provider, which stores the service’s data on our behalf.
  • Telegram, which carries internal notifications to our team about new sign-ups and orders (name, email, the placement and the amount).
  • Authorities, where the law requires it.

Cookies

We set two cookies, both first-party — read only by this site:

cmt_sessionKeeps you signed in. Strictly necessary, set only after you sign in, HTTP-only so scripts cannot read it, and expires after seven days.
cmt_srcRemembers the source of your first visit (for example “search · google”) so a sign-up can be credited to the channel that brought it. HTTP-only, contains no identifier, and expires after 90 days. [Confirm with counsel whether this requires consent in the markets served]

There are no third-party analytics or advertising cookies.

How long we keep it

[Retention periods for account data, order records and payment records]

Your rights

Depending on where you live, you may have the right to access, correct, delete or export your personal data, and to object to or restrict how it is used. To exercise any of these, contact us using the details above. [Supervisory authority and complaint route]