Last updated: 2026-08-29

Privacy Policy

This policy explains what personal data AdsEmber collects, why we collect it, how we use and protect it, and the rights you have under the EU General Data Protection Regulation (GDPR) and the UK GDPR.

1. Who we are

AdsEmber ("AdsEmber", "we", "us", "our") is a subscription service that monitors competitors' advertising on the public Meta Ad Library and the public TikTok Ad Library and sends you weekly, daily, or on-demand digests by email and (optionally) Telegram.

For the purposes of the GDPR, the data controller for personal data described in this policy is:

• Yulia Kulakova (Individual Entrepreneur)
• Registered in Georgia (the country), [registered address, Georgia]
• Email: privacy@adsember.com

2. What we collect and why

We collect only the data we need to operate the service and your account. Specifically:

3. Legal bases for processing

Under Article 6 of the GDPR, we rely on the following legal bases:

• Performance of a contract (Art. 6(1)(b)). Processing your email, password hash, plan, monitoring list, digest settings and usage counters is necessary to provide the service you have subscribed to.
• Legitimate interests (Art. 6(1)(f)). Monitoring publicly available Ad Library data to produce competitive-intelligence digests, securing our systems, preventing abuse, and maintaining service records. We balance these interests against your rights and only process what is necessary.
• Consent (Art. 6(1)(a)), where applicable — for example if you choose to connect optional Telegram delivery, or opt in to any non-essential communication. You may withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)), where we must retain certain records (for example, tax/accounting records relating to your subscription).

4. How we use your data

• To create and secure your account and sign you in.
• To run the monitoring you configure and generate your digests.
• To deliver those digests by email and, if connected, Telegram.
• To operate billing through our payment provider and manage your plan.
• To send essential service notices (for example, security, billing, or material changes to the service).
• To detect, prevent and investigate abuse, fraud, and technical problems.

We do not sell your personal data, and we do not use advertising or tracking cookies or third-party analytics.

5. Sub-processors

We use a small number of trusted service providers ("sub-processors") to run AdsEmber. Each processes personal data only on our instructions and under a data-processing agreement:

We may update this list as our service evolves; material changes will be reflected here.

6. International — EU & UK users and transfers

AdsEmber is operated from Georgia, which is outside the EU/EEA and the UK. Because we offer the service to users in the EU and the UK, the EU GDPR and the UK GDPR apply to us extraterritorially under Article 3(2) — that is, they apply to our processing of the personal data of individuals in the EU/UK even though we are established outside those territories. We are committed to handling your data in line with those rules as set out in this policy.

Where a representative in the EU and/or UK is required under Article 27 GDPR, one will be appointed and named here: [EU/UK representative — to be appointed].

We aim to keep hosting and databases within the European Union. However, because we operate from Georgia and use the sub-processors listed above, your personal data may be processed outside the EU/EEA and the UK (for example, for operations, email delivery, scraping fallback, messaging, or payments). Where that happens, we rely on appropriate safeguards under Chapter V of the GDPR — such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement/Addendum, or an adequacy decision — so that your data receives an essentially equivalent level of protection.

7. How long we keep your data

• Account data (email, password hash, settings, monitoring list) — kept while your account is active.
• After you close your account — we delete or anonymise your personal data within a reasonable period, except where we must retain limited records to comply with legal obligations (for example, billing and tax records) or to resolve disputes.
• Backups — residual copies in encrypted backups are overwritten on our normal backup cycle.

8. Your rights

Subject to the conditions in the GDPR and UK GDPR, you have the right to:

• Access — obtain a copy of the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — ask us to delete your personal data ("right to be forgotten").
• Data portability — receive your data in a structured, commonly used, machine-readable format.
• Restriction — ask us to limit how we process your data.
• Objection — object to processing based on our legitimate interests.
• Withdraw consent — where we rely on consent, withdraw it at any time (this does not affect processing already carried out).
• Lodge a complaint — with a supervisory authority. In the EU this is your local data protection authority; in the UK it is the Information Commissioner's Office (ICO).

To exercise any of these rights, contact privacy@adsember.com. We will respond within the time limits set by law (generally one month).

9. Children

AdsEmber is a business tool intended for users aged 18 and over. It is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it.

10. Security

We take appropriate technical and organisational measures to protect your data, including storing passwords only as bcrypt hashes, using HTTPS/TLS for data in transit, restricting access to production systems, and hosting on EU infrastructure. No method of transmission or storage is completely secure, but we work to protect your data and to respond promptly to any incident.

11. Changes to this policy

We may update this policy from time to time. When we do, we will change the "Last updated" date above and, for material changes, notify you by email or in-app. Your continued use of AdsEmber after an update means you accept the revised policy.

12. UK GDPR & California (CCPA/CPRA) note

UK users. If you are in the United Kingdom, the UK GDPR and the Data Protection Act 2018 apply in the same way as described above. Your supervisory authority is the Information Commissioner's Office (ICO), and you may lodge a complaint with them.

California users. We do not sell or "share" (as defined under the CCPA/CPRA) your personal information, and we do not process it for cross-context behavioural advertising. California residents may request access to, or deletion of, their personal information, and will not be discriminated against for exercising these rights. To make a request, contact privacy@adsember.com.