Privacy Notice

Version 2026-07-26-1

PRIVACY NOTICE – AdGentle
Version 2026-07-26-1 – 26 July 2026

1. Controller
The controller of personal data relating to the AdGentle platform is the owner of the AdGentle brand and service (“AdGentle”, “we”). Contact: via the channels indicated on adgentle.com or the support email associated with the account when published.

2. Scope
This notice covers:
a) use of the AdGentle website and private area (customers and prospects);
b) the AdGentle script installed on Customers’ sites (“script”).
It does not replace the notices the Customer must provide to visitors of their own site as an independent controller.

3. What we do NOT do with cookies on the script
The AdGentle script on Customers’ sites does NOT use first-party HTTP cookies to choose or personalize banners.
Which banners / offers are shown is decided server-side using algorithms and analysis tools, including those based on artificial intelligence (page context, product catalogue, site rules, performance), not through AdGentle advertising profiling based on tracking cookies.
To make the script work technically we may use, in the visitor’s browser:
- sessionStorage: technical session identifier (e.g. impression/click counts in the same browsing session);
- localStorage: short cache of configuration / products to reduce calls and improve performance.
These local stores are not cookies; they remain on the device and serve the operation of the Service. The Customer, as controller towards their visitors, assesses whether and how to inform them in their own privacy/cookie policy.

4. Cookies on the AdGentle site (private area)
On the AdGentle domain (login, dashboard) we use technical session cookies necessary for authentication and account security (e.g. session after Google login). We do not use third-party advertising profiling cookies to show ads on adgentle.com.

5. Data processed – Customers (account)
- Google account data (identifier, name, email, profile image if provided);
- registered site data (domain, integration status, settings);
- payment / tax data provided by the Customer (IBAN, tax ID/VAT, address, etc.) to pay out fees;
- technical logs, notifications, preferences;
- Service metrics (impressions, clicks, conversions aggregated or linked to the site).
Legal basis: performance of the contract / pre-contractual measures; legal obligations (tax); legitimate interest (security, abuse prevention, Service improvement) within legal limits.
Purposes: deliver the Service, authentication, support, payments, fraud prevention, improvement of offer-selection algorithms.

6. Data processed – visitors of Customer sites (via script)
When a visitor opens a page with the script, AdGentle may receive technical data necessary for the Service, for example: page URL/path, user-agent, IP address (processed in a limited way for security and anti-abuse), banner view/click events, technical session identifier (sessionStorage), product/banner references.
Purposes: operate banners and links, measure performance, feed offer-selection algorithms, security.
Legal basis: legitimate interest of AdGentle and the Customer in delivering editorial monetization and technical measurement; where required by law, the Customer obtains additional bases/consents towards their users.
AdGentle does not sell visitor lists and does not create cross-site advertising profiles based on AdGentle cookies.

7. Publishers and clicks
By clicking a banner the visitor may be redirected to Publisher / merchant networks. From that point third-party cookies and processing (Publishers, advertisers) may apply under their notices. AdGentle does not control those third-party cookies.

8. Google OAuth
Login is via Google. Google’s terms and privacy also apply for what concerns them. We only receive the profile data needed for the account.

9. Retention
We retain data for as long as needed for the purposes (contractual relationship, tax obligations, legal defence, security). Technical logs and Service analytics may be aggregated or anonymized where possible.

10. Recipients
Technical providers (hosting, email, notifications), advisors, Publishers within the limits needed for the Service, authorities if required. Extra-EU transfers only with appropriate safeguards where applicable.

11. Rights
Where applicable (GDPR), the data subject may request access, rectification, erasure, restriction, objection, portability and lodge a complaint with the supervisory authority. For requests relating to the Customer account: contact AdGentle. For data collected on the Customer’s site as independent controller: contact the Customer.

12. Updates
We may update this notice by publishing the new version on adgentle.com. Current version: 2026-07-26-1.