Privacy Policy

Update October 1, 2023

This Privacy Policy (the “Policy”) determines how information is obtained, collected and used on this site (the “Site”) and in course of services provision via the Site (all of the above together referred to as the “Services”).

The Site and all associated intellectual property rights are owned by Adverzia (Registration No.:306131408, address: Dvaro g. 20-2, Gudkaimio k., Kybartų sen., Vilkaviškio r. sav., Lithuania, 70455), WITYTECH LTD (Registration No.: HE 450585, address: 121 Prodromou Avenue, Hadjikyriakion Bldg 1, Nicosia, 2064, Cyprus) serves as the operational manager for the Site, handling day-to-day operations and payment processing.

By accessing this Site or using the Services you acknowledge that you have read and understood this Policy and accepted the rules and conditions provided herein.

We reserve the right to make changes to this Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Policy. Any changes or modifications will be effective immediately upon posting the updated Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of the Site after the date such revised Policy is posted.


We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Information we collect directly from you. We collect information directly from you when you provide it to us when You use Our Services, create an account on Our Site, or contact Us through email, telephone number or any other way.

The personal information provided by You may include the following:

  • Information about your visits to our Site, your use of the Site;
  • Geographical location;
  • Operating system;
  • Browser type;
  • Information source;
  • Visit duration;
  • Number of pages viewed;
  • Pages requested by your browser from our server (via cookies).
  • Personal information when you register and use the Site through Google, Facebook or Apple accounts (e.g. email, sex, place of birth, location (current place of residence).

Please note that we do not collect any sensitive information like racial or ethnic origin, political opinions, religious or philosophical beliefs, physical or mental health information. etc.

Information collected through automatic data collection technologies. We collect information through automatic data collection technologies like cookies and web beacons additionally to any information provided by You whenever you interact with Our Site and/or use Our Services.

Information or data obtained by us with the use of automatic data collection technologies may include:

  • Usage information (your searches, the pages you visited, other actions on Site);
  • IP address;
  • Cookie id;
  • Browser and device characteristics;
  • Referring URLs;
  • Country;
  • Location;
  • Other technical information.

Information collected from other sources. If you choose to register your account on Our Site with a third-party service (e.g. Facebook), we may receive certain information about you from your social media provider such as your profile information. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

We will use the information we receive only for the purposes that are described in this Privacy Policy. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.

As WITYTECH LTD operates our website, they may gather various user data to ensure a comprehensive user experience. This encompasses personal information, browsing habits, and also payment-related data like credit or debit card details, billing address, and transactional history. Stringent security measures are employed by both our organizations to safeguard your data.

We may use third-party payment providers that process your payment information in accordance with their privacy policies.

We do not store your payment information on our servers. We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred, for example, the date and amount of your purchase and the last 4 digits of your card number so that we can verify your purchase with our records.


We process your personal information only when we have lawful bases under applicable law.

If you are located in the EU, UK, other countries of the European Economic Area (“EEA”) or Switzerland, processing will be justified on the basis that:

  • you have provided your consent for us to use your personal information for a specific purpose, such as sending you our newsletters and marketing emails;
  • our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
  • processing is necessary for the purposes of our legitimate interests (e.g. the assessment of business efficiency by analyzing website traffic and financial performance indicators; user session control and fraud prevention, ensuring the appropriate protection of personal data; promotion of Services through social media networks);
  • the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. data subject request processing).

If you are located in California, please see section 12 below.

If you are located in Canada, please see section 13 below.


We may process the personal data you provided us voluntarily for the purposes defined below:

  • to provide Services to you, to create your account, respond to your inquiries, requests, and complaints as well as support the provision of Services (including technical and customer support);
  • to contact you for the purpose of operational requirements (e.g. for technical updates or updates on changes in our usage policies);
  • to send you company updates and marketing offers based on your consent to receive such information from Us;
  • to protect our Services, to prevent fraud and maintain a safe and secure marketplace and services;
  • to save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm;
  • to determine the effectiveness of our marketing and promotional campaigns;
  • to demonstrate the characteristics of the target audience to advertisers;
  • to provide assistance to advertisers in attracting the target audience;
  • to maintain appropriate business records, to comply with applicable laws and regulations or as otherwise required by law.

As our site operator, WITYTECH LTD accesses and uses your data for multiple purposes, ranging from ensuring optimal site functionality to securely processing your payments. The data shared and used by them adheres to their comprehensive privacy policies, ensuring utmost confidentiality and security.


Third-party service providers. In order to provide Services and operate the Site We may share your data with third-party service providers, contractors, who perform services for Us such as hosting services, billing and payment processors, web analytics and performance tools services. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions.

Comprehensive Data Transfer to WITYTECH LTD: Given that WITYTECH LTD operates our website, we transfer extensive user data to them. They’re dedicated to upholding the privacy and security of this data. While they manage various aspects of the user experience, it’s essential to understand that your information might be stored and managed within WITYTECH LTD’s infrastructure. 

Compliance with laws and law enforcement entities. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes;

Business Transfers. We reserve the right to sell, assign, or transfer our business or assets. In any such event or similar event, including but not limited to a corporate sale, merger, reorganization, dissolution, etc., Personal Information or Personal Data may be part of the transferred assets. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Information or Personal Data as set forth in this Privacy Policy.


The Site may gather information about your general Internet use by using cookies and similar tracking technologies (like web beacons and pixels). Where used, these cookies are downloaded to your computer automatically. A cookie is a file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. The Site uses cookies to help you personalize your online experience.

Types of cookies that We use:

Essential cookies. Some cookies are essential for our service to function and cannot be switched off in our systems. They are used to enable core functionality, such as authentication, security, connection stability, etc. You can always set your browser to block or alert you about these cookies, but this may affect the Site functions.

Analytics Cookies. Analytics cookies help us know which pages are popular and how visitors move around the site. We use them to count visits, check traffic sources, and measure and improve the Site’s performance.

Marketing Cookies. Certain 3rd-party service providers and advertising partners manage our advertising on other sites. Such 3rd parties use cookies through our site to provide you with advertising on other sites based on your interests and preferences.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the sites you visit.


Your personal information will be stored by Us no longer than is necessary for the purposes for which the personal information is processed unless a longer retention period is required or permitted by law. Generally, We retain your personal information as long as your account is active.

In case your account expires or you decide to delete your account We retain your personal data no longer than necessary to fulfill our legal obligations.

Personal Information collected when you opted in receiving marketing letters will be stored as long as you are interested in receiving our marketing emails and newsletters. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails.

If you have agreed to receive marketing letters by email or via SMS from us or our partners, you can unsubscribe at any time by using the contact details provided in the section 14 below.


Our Site may, from time to time, contain links to and from third-party sites, online services, or mobile applications and/or contain advertisements from third parties. If you follow any link to a third-party resource, keep in mind that this site, service or application has its own privacy policy and that We do not assume any responsibility or obligations under such policy. Please examine this policy prior to transferring any personal data to other third-party resources.


We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your personal user data and other information transmitted to us. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.


Our Site and Services are not intended for use by children under the age of 18 years (or the applicable age in your country). By using the Services, you represent that you have sufficient capacity or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn we have collected or received personal information from a child who lacks capacity, we will delete that personal information. If you believe we might have any information from or about a child who lacks capacity, please contact us at [email protected]


Under applicable EU regulation, you have the following rights in respect of your personal information:

  • the right of access -to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
  • the right to rectification – to rectify inaccurate personal information;
  • the right to erasure – to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for Us to hold your personal information; (b) We are processing your personal information on the basis of legitimate interests and you object to such processing, and We cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to Us with your consent and you wish to withdraw your consent and there is no other ground under which We can process your personal information; and (d) where you believe the personal information We hold about you is being unlawfully processed by Us;
  • the right to restrict processing -to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) We no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to Us processing your personal information based on Our legitimate interests and We are considering your objection;
  • the right to object- to challenge processing which We have justified on the basis of Our legitimate interest;
  • the right not to be subject to a decision based solely on automated processing- to object to decisions that are based solely on automated processing or profiling;
  • the right to data portability – where you have provided your personal information to Us with your consent, to ask Us for a copy of this data in a structured, machine-readable format and to ask Us to share (port) this data to another data controller;

WITYTECH LTD, a company registered under the laws of Cyprus with the registered address at 121 Prodromou Avenue, Hadjikyriakion Bldg 1, Nicosia, 2064, Cyprus will be the controller of your personal data.

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.

You can make a request by contacting us by using the contact details provided in the section 14 below.

We will consider and act upon any request in accordance with applicable data protection laws. We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause Us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, We will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 14 below.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in the section 14 below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.


Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.


California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice. The California Code of Regulations defines a “resident” as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your Rights under the CCPA. The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
  • The right to request. You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information
  • The right to say no to the sale of Personal Information (opt-out). You have the right to direct business to not sell Your personal information. Please note that We do not sell your personal information to third parties.
  • The right to delete Personal Information. You have the right to request the deletion of Your Personal Information, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Information from our records, unless an exception applies.

We may deny Your deletion request if retaining the information is necessary for Us to:

  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
  • The right to correct inaccurate personal information. You have the right to request the correction of Your Personal Information, subject to certain exceptions. Once We receive and confirm Your request, We will correct Your personal information in our records
  • The right to limit use and disclosure of sensitive personal information. Please note that We do not use and do not disclose your sensitive personal information to third parties.

Exercising Your CCPA Data Protection Rights. In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by using the contact details provided in the section 14 below. If you are an authorized agent submitting a rights request on behalf of a California consumer you need to provide a copy of the written authorization signed by the consumer.

Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.


We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations


If you have questions or comments about this policy, you may contact us:

[email protected]

Last Updated on October 1, 2023

Effective Date: October 1, 2023