Privacy Policy

1. Scope of this Policy

This Privacy Policy applies to all personal information collected and processed by Adscod in connection with:

• Our website(s) and digital platforms
• Direct communications, including emails, chat, and web forms
• Advertising, marketing, and promotional activities
• Interactions on social media platforms
• Recruitment and job application processes
• Supplier and customer relationship management

2. Personal Data We Collect and Process

2.1 Customer Representatives

We process personal data of individuals representing our customers, including names, business emails, and job titles, for purposes such as contract management, service delivery, and customer support.

2.2 Prospective Customer Representatives

Through lawful marketing activities and events, we may collect contact and professional information to send promotional materials. Our lawful basis for processing is either your consent or legitimate interest, depending on context.

2.3 Contact Through Forms, Email, or Chat

When you reach out via contact forms, support chat, or email, we process your submitted personal information (e.g., name, email address, message content) to respond and provide assistance.

2.4 Creators and Creators

For creators and creators on our platform, we collect and process:

• Profile details, social media handles, and audience demographics
• Campaign performance metrics, engagement data, and click/conversion history
• Fraud-detection signals used by The Eye to screen for fraud — account age, follower velocity, conversion anomalies, click-burst patterns, and follower-legitimacy scoring
• Wallet balances, ledger entries, withdrawal history, and PIN-hashed credentials
• Payment data processed through Flutterwave, including mobile-money and bank payout details
• Fraud detection signals — engagement anomalies, follower velocity, click bursts, and resulting fraud scores
• Creator Boost history (plan type, duration, spend); Boost history data is retained for 24 months for fraud prevention and audit purposes

This data is processed to enable campaign management, analytics, payout processing, fraud prevention, and platform integrity, as governed by the Creator Terms of Use.

2.4b Conversion Tracking and Attribution

Brands who deploy the Adscod tracking pixel on their websites generate conversion events (page views, clicks, purchases) that are attributed to specific campaigns and creators. This conversion data is processed to calculate campaign ROI, fraud-risk signals, and payout allocations. End users whose browsers trigger these pixel events should refer to the applicable Brand's privacy notice, as Adscod processes this data on the Brand's behalf as a data processor.

2.4c The Eye — Matching and Fraud Detection

Adscod uses aggregated and anonymised platform data to train and operate The Eye, the automated engine that matches Brand campaigns to eligible Creators and Publishers and screens every click for fraud before it is billed or credited. Individual user data is not used to train models applied to other customers. Creators and Publishers may not opt out of being matched by The Eye, as this is core to the Platform's function; however, they may request that inaccurate profile data underlying their match or fraud signals be corrected by contacting privacy@adscod.com.

2.5 Job Applicants

Candidates submitting applications or Resumes (Curriculum Vitae) to jobs@adscod.com consent to the processing of their personal data (e.g., education, employment history) strictly for recruitment and hiring purposes.

2.6 Social Media Interactions

We process data generated through interactions on our official social media profiles (likes, comments, messages) to facilitate community engagement, support, and promotional activities.

2.7 Suppliers and Vendor Representatives

Personal data of suppliers' personnel (contact details, contractual records) is processed for procurement, relationship management, and financial administration.

3. Legal Basis for Processing

Adscod processes personal data in compliance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) and relevant African data protection legislation.

Our lawful bases for processing include:

• Consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate interests pursued by Adscod or third parties

3.2 Third-Party Data Sharing

We share personal data with the following categories of recipients, strictly on a need-to-know basis:

• Flutterwave — our payment processor for campaign funding, wallet operations, mobile-money payouts, and currency conversion across 18+ African countries
• Vultr (cloud infrastructure) — our servers are hosted in Johannesburg, South Africa, a jurisdiction governed by the Protection of Personal Information Act (POPIA), which provides data protection standards equivalent to the GDPR
• Analytics providers — for platform performance and usage insights
• Law enforcement or regulators — where required by applicable law

3.3 International Data Transfers

Adscod is incorporated in Uganda and serves users across Africa. Our infrastructure is hosted in Johannesburg, South Africa via Vultr. This constitutes a cross-border transfer of personal data under the Uganda Data Protection and Privacy Act 2019 (DPPA).

We rely on the following safeguards for this transfer:

• Adequate protection — South Africa's POPIA provides data protection standards substantially equivalent to those required under the Uganda DPPA, making it an adequate destination jurisdiction
• Data Processing Agreement — we maintain a signed Data Processing Agreement with Vultr governing how your data is stored and protected
• Encryption in transit and at rest — all data transferred to and stored on our servers is encrypted using industry-standard protocols (TLS 1.3 in transit)

For questions about our cross-border data transfer practices, contact legal@adscod.com.

4. Your Rights

Subject to applicable law, you have the right to:

• Access personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data where applicable
• Restrict processing of your data
• Receive your data in a structured, portable format
• Object to processing based on legitimate interests or marketing
• Withdraw consent where processing is consent-based

5. Cookies and Similar Technologies

We use cookies and related technologies on our websites to enhance user experience, analyze traffic, and support marketing efforts. For more details, please review our Cookie Policy.

6. Data Protection Officer (DPO)

Adscod has appointed a Data Protection Officer responsible for overseeing data protection compliance. For questions or concerns about your personal data, contact legal@adscod.com.

7. Complaints and Contact

If you believe your privacy rights have been violated or your personal data has been mishandled, please contact us promptly at legal@adscod.com. We are committed to addressing and resolving all complaints fairly and timely.

8. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in legal requirements, technology, or business practices. When material changes occur, we will notify you via email or platform notifications. The updated Privacy Policy will be posted on this page with a revised “Last Updated” date. We encourage you to review this policy regularly.