Privacy Policy

1. Introduction

Adstorm LLC ("Adstorm," "we," "our," or "us") is committed to protecting the privacy and personal data of every individual who interacts with our websites, services, and communications. This Privacy Policy explains in detail how we collect, use, store, share, and protect your personal information, as well as the rights you hold over your data under applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant legislation.

This policy applies to all digital properties operated by Adstorm LLC, including any brand websites and microsites we own or manage, our consulting service portal, and any email marketing communications we send. By using our websites or services, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with the practices described in this policy, please discontinue use of our websites and services and contact us to exercise any applicable rights regarding data we may already hold about you.

2. Data Controller Information

Legal Entity: Adstorm LLC

Registered Office: Shams Media City FZ, Al Messaned, UAE

General Contact: hello@adstorm.agency

Data Protection Officer (DPO) / Privacy Contact: privacy@adstorm.agency

Adstorm LLC is the data controller for personal data processed in connection with our websites, brand properties, and consulting services. Where we process data on behalf of clients as a data processor, a separate Data Processing Agreement governs that relationship.

3. Personal Data We Collect

We collect different categories of personal data depending on the nature of your interaction with us. The table below summarizes the categories of data we may collect.

Data Category Examples Source
Identity Data First name, last name, username or similar identifier Directly from you
Contact Data Email address, telephone number, billing address, shipping address Directly from you
Financial Data Payment card details (processed and tokenized by our payment processor - we do not store raw card numbers), billing records Directly from you via payment processor
Transaction Data Details of products or services purchased, order history, refund history, subscription records Automatically generated; from you
Technical Data IP address, browser type and version, operating system, device identifiers, time zone, plug-in types, screen resolution Automatically collected
Usage Data Pages visited, time spent on pages, links clicked, referring URLs, search terms used on site, funnel step completions Automatically collected
Marketing and Communications Data Your preferences for receiving marketing from us, communication history, email open and click data, opt-out records From you; automatically generated
Profile Data Your account username and password, purchases or orders made, interests, preferences, quiz or survey responses From you; inferred from usage
Aggregated and Anonymized Data Statistical or demographic data for analytics purposes (e.g., 40% of users visited a specific page). This data cannot identify you individually. Derived from above categories

We do not intentionally collect Special Category Data (also known as sensitive personal data) such as data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning a person's sex life or sexual orientation. Please do not submit such data to us. If you do, we will delete it promptly.

4. How We Collect Personal Data

4.1 Data You Provide Directly

We collect personal data directly from you when you:

4.2 Data We Collect Automatically

When you visit our websites or interact with our emails, we automatically collect Technical Data and Usage Data using cookies, server logs, web beacons, and similar tracking technologies. This may include your IP address, browser type, pages visited, and how long you spent on each page. For full details, please see our Cookie Policy.

4.3 Data We Receive from Third Parties

We may receive personal data about you from the following third-party sources:

5. Legal Bases for Processing (GDPR)

For individuals located in the European Economic Area (EEA) or United Kingdom, we rely on the following legal bases under GDPR Article 6 to process your personal data:

Legal Basis When We Rely on It
Consent (Art. 6(1)(a)) When you have given clear, informed consent for a specific purpose - for example, opting in to receive marketing emails or accepting non-essential cookies
Contract (Art. 6(1)(b)) When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract - such as processing an order or providing a purchased service
Legal Obligation (Art. 6(1)(c)) When we must process your data to comply with a legal or regulatory obligation - such as tax record-keeping or responding to a lawful law enforcement request
Legitimate Interests (Art. 6(1)(f)) When processing is necessary for our legitimate business interests (or those of a third party) and those interests are not overridden by your rights and interests - for example, website security, fraud prevention, improving our services, and certain direct marketing to existing customers

Where we rely on consent, you may withdraw that consent at any time without detriment. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Purposes of Processing

We collect and use your personal data for the following purposes:

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate our websites, measure performance, and deliver relevant advertising. Cookies are small text files stored on your device that allow us to recognize you across sessions.

We use the following categories of cookies:

For a full list of cookies we use, their purpose, duration, and how to manage or disable them, please read our Cookie Policy.

8. Sharing Your Personal Data

We do not sell your personal data. We may share your data with the following categories of third parties, strictly for the purposes set out in this policy:

We require all third parties to respect the security and confidentiality of your personal data and to process it only in accordance with our instructions and applicable law.

9. International Data Transfers

Adstorm LLC is headquartered in the United Arab Emirates (Shams Media City FZ, Al Messaned, UAE). Your personal data may be transferred to, and processed in, countries outside your country of residence, including the UAE and other jurisdictions where our service providers operate.

For transfers of personal data from the EEA, UK, or Switzerland to countries that have not received an adequacy decision from the relevant data protection authority, we rely on the following safeguards:

You may request a copy of the specific safeguards we use for any particular transfer by contacting us at privacy@adstorm.agency.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The following general retention periods apply:

Data Type Retention Period Reason
Customer account data Duration of account + 3 years Contract performance and dispute resolution
Transaction and financial records 7 years from transaction date Legal and tax compliance
Marketing consent records Until consent withdrawn + 3 years Evidence of lawful processing
Email engagement data 3 years from last engagement Marketing optimization and suppression lists
Website analytics data 26 months Trend analysis and service improvement
Support and correspondence records 3 years from resolution Quality assurance and dispute resolution
Fraud and abuse records Up to 7 years Security and legal protection

When personal data is no longer needed, we securely delete or anonymize it. Where immediate deletion is not technically possible (e.g., data in backup archives), we isolate the data from further active processing until deletion is possible.

11. Your Rights Under GDPR

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights under the GDPR and UK GDPR with respect to your personal data:

To exercise any of these rights, please contact our DPO at privacy@adstorm.agency. We will respond within 30 days (or within 72 hours for data breach notifications). We may need to verify your identity before fulfilling a request.

12. Your Rights Under CCPA (California Residents)

If you are a resident of California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights:

California residents may submit a verifiable consumer request by emailing privacy@adstorm.agency. We will respond within 45 days of receiving a verifiable request, with an extension of up to 90 days where reasonably necessary.

Categories of Personal Information Collected in the Last 12 Months: Identifiers, commercial information, internet or other electronic network activity information, and inferences drawn from the above to create a profile.

13. Children's Privacy

Our websites, products, and services are not directed to children under the age of 18, and we do not knowingly collect personal data from minors. Our educational and personal improvement content is designed exclusively for adults.

If you are a parent or guardian and believe that your child under the age of 18 has provided us with personal data without your consent, please contact us immediately at privacy@adstorm.agency. Upon verification, we will delete such information from our records promptly.

14. Data Security Measures

Adstorm LLC has implemented appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

No method of transmission over the internet or method of electronic storage is 100% secure. While we use commercially reasonable measures to protect your personal data, we cannot guarantee absolute security.

15. Third-Party Links and Services

Our websites may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy notice of every website you visit when you leave our sites.

16. Marketing Communications

Where we have your consent or a legitimate interest as an existing customer, we may send you marketing communications about our products, services, and promotions. Each marketing email we send will include a clear and easy method to unsubscribe or update your communication preferences.

You may opt out of receiving marketing communications at any time by:

Note that even if you opt out of marketing communications, we may still send you transactional messages related to your purchases or account (e.g., order confirmations, password resets).

17. Automated Decision-Making and Profiling

We may use automated tools to segment our email list, personalize website content, and optimize ad delivery. These processes may involve profiling based on your Usage Data and Marketing Data. However, we do not make decisions about you that have a significant legal or similarly significant effect solely by automated means without human review. If you have concerns about any automated processing that affects you, please contact us.

18. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals websites not to track user behavior across sites. Because there is currently no agreed-upon standard for how websites should respond to DNT signals, our websites do not currently alter their behavior in response to DNT signals. You may manage tracking preferences through our cookie consent mechanism and your browser settings.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

We encourage you to review this Privacy Policy periodically. Your continued use of our websites and services after any changes constitutes your acceptance of the updated policy.

20. How to Exercise Your Rights - Contact Us

For all privacy-related inquiries, requests to exercise your rights, or questions about this Privacy Policy, please contact our Data Protection Officer:

Adstorm LLC - Data Protection Officer

Email: privacy@adstorm.agency

Postal Address: Shams Media City FZ, Al Messaned, UAE

General Inquiries: hello@adstorm.agency

We will acknowledge receipt of your request within 5 business days and provide a substantive response within 30 days (extendable to 60 days for complex requests under GDPR, or 90 days under CCPA). We will not charge a fee for exercising your rights unless your request is clearly unfounded or excessive.

If you are not satisfied with our response, you have the right to escalate your complaint to the relevant supervisory authority in your jurisdiction.

21. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the United Arab Emirates and the applicable regulations of Shams Media City Free Zone. Where EU GDPR or UK GDPR applies to your personal data, we comply with those frameworks as described above. Where the CCPA applies to California residents, we comply with those requirements as described in Section 12.