PRIVACY POLICY - CORE
AdBlock360

1. WHO WE ARE

Company: AdBlock Ltd.
Registration: C 104782 (Malta)
Director: Marco Mercieca
Address: International House, Mdina Road, Mriehel BKR 3000, Birkirkara, Malta
Email: privacy@adblock360.com
Website: https://www.adblock360.com
Support: https://support.adblock360.com

We provide ad-blocking software through our Windows desktop application and website services.

Data Protection Officer: Not appointed. Based on our assessment, we are not required to appoint a DPO as we:

• Employ fewer than 250 people
• Do not process special categories of data at large scale
• Do not conduct regular and systematic monitoring at large scale

2. INFORMATION WE COLLECT

2.1 Information You Provide

Account Information:

• Email address
• Name (optional)
• Password (hashed)
• Account preferences

Payment Information (via processors):

• Last 4 digits of payment method
• Payment method type
• Billing country

Communications:

• Support ticket content
• Email correspondence
• Feedback and surveys

2.2 Information Collected Automatically

Usage Data:

• Product features used
• Performance metrics
• Error reports (if enabled)

Device Information:

• Operating system and version
• Hardware ID (for license validation)
• Browser type (website only)

Analytics Data: See platform-specific addendums for details on:

• Google Analytics
• Microsoft Clarity
• Convert.com (A/B testing)
• Voluum (conversion tracking)

2.3 Information from Third Parties

Social Sign-On (Google SSO):

• Email address
• Name
• Google User ID

Payment Processors:

• Transaction status
• Subscription status

3. HOW WE USE YOUR INFORMATION

3.1 Service Provision

• Create and manage your account
• Provide ad-blocking services
• Process payments and subscriptions
• Provide customer support

3.2 Service Improvement

• Analyze usage patterns
• Fix bugs and improve performance
• Develop new features
• Conduct A/B testing

3.3 Communications

• Service-related notifications
• Security alerts
• Marketing (with consent)
• Newsletter (opt-in)

3.4 Legal and Safety

• Comply with legal obligations
• Prevent fraud and abuse
• Protect rights and property
• Enforce terms of service

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share data with providers who help us operate:

Infrastructure

• Amazon Web Services (cloud hosting) - US East, EU regions
• Google Cloud Platform (database, analytics) - EU (Frankfurt)

Payments

• Stripe (payment processing)
• PayPal (alternative payments)

Communications

• Brevo (email delivery)
• Zendesk (customer support) - EU data center

Analytics

• Google Analytics (website analytics)
• Microsoft Clarity (user behavior)
• Convert.com (A/B testing)
• Voluum (conversion tracking)

Error Tracking:

• Sentry.io (error reporting)

4.2 Legal Requirements

We may disclose information when required by:

• Court orders or legal process
• Government authorities
• Law enforcement requests
• Protection of rights and safety

4.3 Business Transfers

In case of merger, acquisition, or sale of assets, your information may be transferred with appropriate protections.

4.4 Your Consent

We share information with your consent, such as:

• Public testimonials
• Referral programs

We do NOT sell your personal information to third parties.

5. INTERNATIONAL DATA TRANSFERS

As a Malta-based company (EU member state), we primarily process data within the EU/EEA.

Transfers outside EU/EEA:

• United States: AWS services (Standard Contractual Clauses)
• Other countries: Only with appropriate safeguards

Legal Basis for Transfers:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions where applicable
• Your explicit consent where required

6. DATA SECURITY

We implement appropriate technical and organizational measures:

Transfers outside EU/EEA:

• Encryption in transit (TLS/HTTPS)
• Encryption at rest (AES-256)
• DPAPI encryption for sensitive local data
• Access controls and authentication
• Regular security updates

Organizational Measures:

• Limited access on need-to-know basis
• Confidentiality agreements
• Security training
• Incident response procedures

While we strive to protect your data, no system is 100% secure. Please use strong passwords and protect your account credentials.

7. DATA RETENTION

We retain personal information only as long as necessary:

Requirements:
Certain retention periods are mandated by law (e.g., tax records, consumer complaints).

8. YOUR PRIVACY RIGHTS

8.1 Rights for All Users

Access: Request a copy of your personal data
Correction: Update inaccurate information
Deletion: Request deletion (with exceptions)
Portability: Receive data in portable format
Communication Preferences: Opt-out of marketing

8.2 Regional Rights

EU/UK (GDPR):

• Object to processing
• Restrict processing
• Lodge complaint with supervisory authority
• Withdraw consent

California (CCPA):

• Know what information is collected
• Delete personal information
• Opt-out of "sale" (we don't sell data)
• Non-discrimination for exercising rights

South Korea (PIPA):

• Consent withdrawal
• Access to processing records
• Request processing suspension

Australia (Privacy Act):

• Access and correction
• Complaint to OAIC

Canada (PIPEDA):

• Challenge compliance
• Access with exceptions

8.3 How to Exercise Rights

Email: privacy@adblock360.com
Subject: "[Your Region] Privacy Rights Request"
Include: Your email address and specific request
Response Time: Within 30 days (sooner where required)

9. CHILDREN'S PRIVACY

Age Restrictions by Region:

• European Union: Under 16
• South Korea: Under 14
• United States & Other regions: Under 13

AdBlock360 is not intended for children under these ages.

We do not knowingly collect data from children. If we discover we have collected children's data, we will promptly delete it.

Parents: Contact privacy@adblock360.com if you believe we have your child's information.

10. CHANGES TO THIS POLICY

We may update this policy to reflect:

• Changes in our practices
• New legal requirements
• New features or services

Notification:

• Material changes: Email + website notice
• Minor changes: Updated date at top

Your Rights:

• Review changes before they take effect
• Close account if you disagree

11. CONTACT US

Privacy Inquiries:
AdBlock Ltd.
International House, Mdina Road
Mriehel BKR 3000, Birkirkara
Malta

Email: privacy@adblock360.com
Support: https://support.adblock360.com

EU Supervisory Authority:
Office of the Information and Data Protection Commissioner (Malta)
Website: https://idpc.org.mt

APPENDIX: LEGAL BASIS FOR PROCESSING (GDPR)

END OF CORE PRIVACY POLICY