Privacy Policy

1. Controller and Data Protection Officer (DPO)

The controller is VALTEVO, Unipessoal Lda, tax ID 518368521, Portugal, which operates adPluga. You can contact the Data Protection Officer at privacidade@adpluga.com.

2. Our dual role: controller and processor

We are the controller of data we process for our own purposes (e.g., accounts, billing, security). We are a processor when we process data on customers' behalf (e.g., first-party audiences the customer provides, or events from its inventory) — in that case the customer is the controller and a Data Processing Agreement (DPA) applies.

3. Categories of data we process

We process the following categories of data (we do not sell personal data):

• Account and contact — name, email, company, role.
• Billing — plan data, transactions and payment identifiers (processed by payment providers).
• Usage and technical — access logs, device, browser, language.
• Ad delivery — pseudonymized identifiers, hashed IP, user-agent, approximate location, slot/context, to serve, measure and detect fraud.
• Communications — support messages and preferences.
• Connected channels — when you connect your Meta (Facebook and Instagram) ad account, the access token Meta gives us, stored encrypted, and the identifiers of the ad account and Page you chose.

4. Purposes and legal bases

We process data on the following bases (GDPR art. 6; LGPD art. 7 and 11):

• Performance of the contract — to provide and manage the Service, billing and support.
• Legitimate interests — security, fraud prevention (IVT), measurement and product improvement, balanced against your rights.
• Consent — non-essential cookies/tracking and marketing communications, where applicable (revocable at any time).
• Legal obligation — tax, accounting and legitimate requests from authorities.

5. Cookies, SDK and tracking technologies

We use essential cookies and, with consent, measurement cookies. We favor contextual targeting (no third-party cookies). The delivery tag/SDK uses pseudonymized identifiers; test mode generates no production data. Preferences are manageable via our consent banner (CMP). To know which channel brought each account, a first-party cookie (ap_attr) keeps the visit's campaign parameters (UTM, ad click identifier, invite code, referring domain and landing page): it lasts only for the session without measurement consent and up to 90 days with it, is never shared with third parties, and is deleted at sign-up, when it becomes part of the account data. We measure visits to our website with our own tool: each page viewed goes into a daily count by page, source, country and screen type, without identifying anyone. Only with measurement consent do we also keep a random identifier in our own cookie (ap_vid, up to 13 months) to group pages into visits and, if you create an account, to know how many visits and days it took to sign up; it is never shared with third parties and is deleted when you withdraw consent. Ad delivery uses no cookies: the tag and the web SDK keep the adpluga_uid identifier in the browser's local storage (localStorage) and, where the GDPR applies, only with your consent to store information on the device (see section 15). The app SDKs keep the identifier in memory only.

6. Sharing and subprocessors

We share data only with necessary subprocessors under contract (DPA): hosting/cloud, payment providers, transactional email and observability. With your consent, and only for the categories you accept in the cookie preferences, we also use Google Analytics and Google Ads (Google Ireland Ltd.) and the Meta Pixel (Meta Platforms Ireland Ltd.) to measure visits and the results of our own advertising campaigns, such as a completed registration. We also measure visits to our website with our own tool, hosted by us, with no sharing with third parties (see section 5). With Marketing consent, blog articles show a space of the adPluga network: our tag requests the ad and may keep the adpluga_uid identifier on your device. We may disclose data where required by law. There is no sale of personal data. When an ad is requested from an ad network (mediation), we send it the IP, user-agent, device type, country and your consent choice, as the OpenRTB standard requires; the adpluga_uid identifier is only sent with your consent. If you use the dashboard assistant, your questions and your account's status are sent to Anthropic PBC (USA), which generates the answer; conversations are deleted after 90 days. If you connect an AI assistant to your account through our MCP server (for example Claude, by Anthropic, or ChatGPT, by OpenAI), the assistant receives the account data its tools return, only within the permissions and the mode (Test or Live) you chose when connecting it; from then on that data is processed by the assistant's provider, under its own terms. You can disconnect it at any time in Settings › AI assistants. If you connect your Meta ad account in Settings › Channels, we use the token Meta gives us only to create, paused, the campaigns of the promotions you choose to send to Facebook and Instagram and to read their status and results; Meta processes the data of those campaigns under its own terms, and Meta charges your account's payment method. The token is stored encrypted on our servers (Contabo GmbH, Germany) and passes through Cloudflare, Inc. on the return from Meta's dialog.

7. International transfers

We operate in the EU and Brazil and may use providers in other countries. Where an international transfer occurs, we apply adequate safeguards (adequacy decisions or standard contractual clauses) under the GDPR and the LGPD.

8. Retention

We retain data for as long as necessary for the purposes: account data while the relationship lasts and for up to 60 days after an admin asks to delete the account, a period in which the request can be cancelled; billing for the legal periods. In ad delivery events (impressions and clicks), the IP and user-agent hashes are deleted after 365 days, leaving only aggregated measurement and billing data; first-party audiences are deleted after 365 days, or sooner if the advertiser sets a shorter expiry; the adpluga_uid identifier stays in your browser until you delete it. Technical logs, where the IP appears in clear, are deleted after 7 days; contact requests from the website after 2 years; the visit journey of those who consented to measurement after 13 months, leaving only the daily counts, which identify no one. Test data is kept for a short period. After these periods, we delete or anonymize. For each AI assistant connection we keep the assistant, the permissions, the mode and when it was created, last used and disconnected, for as long as the account exists; the assistant's access keys are stored only as a hash, stop working when you disconnect it and are deleted when the account is deleted. Of the assistant's calls we record which tool was used and the result, not the content of the conversation. The token of a connected ad account (channels) is deleted when you disconnect the channel or when the account is deleted.

9. Security

We apply technical and organizational measures: encryption in transit (TLS), pseudonymization, isolation of creatives in a sandboxed iframe (anti-XSS), access control (RBAC) and audit logs. In the event of a data breach, we comply with applicable notification deadlines (authority and, where required, data subjects).

10. Automated decisions and profiling

We use automated processing for invalid-traffic detection and to rank ads (relevance/eCPM ranking). These processes do not produce significant legal effects on individual data subjects; you may contact us for clarification.

11. Your rights

You have the right of access, rectification, erasure, portability, objection, restriction, and to withdraw consent, under the GDPR and the LGPD. To exercise them, contact privacidade@adpluga.com. We will respond within legal deadlines.

12. Minors

The Service is intended for professional use and is not directed at minors. We do not knowingly collect data from minors.

13. Supervisory authorities

Without prejudice to other avenues, you may lodge a complaint with the competent authority: CNPD (Portugal/EU) or ANPD (Brazil).

14. Changes to this Policy

We may update this Policy. Material changes will be communicated; the "last updated" date reflects the version in force.

15. Advertising and the IAB Transparency & Consent Framework (TCF)

Where the GDPR applies, adPluga reads the choice you made in the consent banner (CMP) of the site or app where the ad appears, through the IAB Europe TCF, and applies it before choosing the ad: without consent to store information on the device, the request is treated as anonymous; without consent to profiles, audiences are not used; if you object to our legitimate interest, we show only an adPluga ad, which is not billed; and the request goes only to ad networks that have a legal basis in your choice. Without any consent signal, a visitor from the EU, the EEA, the United Kingdom or Switzerland is treated as subject to the GDPR. We only accept choices from CMPs registered with IAB Europe. adPluga participates in the IAB Europe Transparency & Consent Framework and complies with its Policies and Specifications; adPluga's Vendor ID appears in the Global Vendor List once assigned. We declare the following purposes and legal bases:

• Purpose 1, store and/or access information on a device — consent. The adpluga_uid identifier in the browser's local storage.
• Purpose 2, use limited data to select advertising — legitimate interest. Page or app context, country, device type and frequency capping.
• Purposes 3 and 4, create and use profiles to select personalised advertising — consent. First-party audiences provided by the advertiser.
• Purpose 7, measure advertising performance — legitimate interest. Impressions, clicks, viewability and conversions.
• Special purposes — legitimate interest: ensure security, prevent and detect fraud, and fix errors (invalid traffic filtering with the IP and user-agent hashes); deliver and present advertising; save and communicate privacy choices (your choice is passed on to the ad networks we request an ad from).
• Features — match and combine data from other sources (the advertiser's audiences) and identify devices based on information transmitted automatically (IP and user-agent hashes, for anti-fraud). We do not link devices, use precise geolocation or actively scan device characteristics.
• Retention — 365 days, under section 8. The technical list of what we store on the device and the domains we use is at adpluga.com/.well-known/deviceStorage.json.

16. Legitimate interests

For purposes 2 and 7 and the special purposes, our legitimate interest is to deliver the advertising that funds the site or app you are using, to measure whether it was delivered and billed correctly, and to protect advertisers and publishers from fraud. We limit data to what is needed: context, country and device type to choose the ad; IP and user-agent hashes to measure and detect fraud. We do not build profiles on the basis of legitimate interest. You can object to these purposes by writing to privacidade@adpluga.com and, once adPluga is listed as a TCF vendor, also in the consent banner of the site or app; from then on we show you only adPluga's own ads, which are not billed. Fraud detection continues, because it also protects those who object.

17. Requests from public authorities

When a public authority asks us for personal data, we follow this process:

• We review the legality of each request: its legal basis, the requester's competence and whether it complies with the GDPR and applicable law.
• We challenge, through the available legal means, any request we consider unlawful, disproportionate or outside the requester's competence.
• We disclose only the minimum data needed to comply with a valid request.
• We record each request, our response, the legal reasoning and the people involved and, where the law allows, inform the affected customer or data subject.

18. Contact

VALTEVO, Unipessoal Lda · Data Protection Officer: privacidade@adpluga.com.