Propeller Ads Ltd (Cyprus) and Propeller Ads Limited (Isle of Man) (referred to as "Propush.me" or "we" or "us" or "our") is committed to protecting and respecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process may vary depending on the service we provide to you.

• provides an overview of how Propush.me collects and processes your personal data, and informs you about your rights under the EU General Data Protection Regulation ("GDPR") and any national law supplementing or implementing the GDPR,
• contains important information about, among others, the collection and use of personal data; the legal grounds for the processing of that data; disclosures of that personal data to third parties and the use of cookies on the Website.

• when we refer to "personal data" we mean data which identifies or may identify you and which may include, for example, your name, address, identification number, telephone number, date of birth, occupation and family status,
• when we refer to "processing" we mean the handling of your personal data by us, including collecting, protecting and storing your personal data, and
• when we refer to our "Website" or our "Platform" we mean www.propush.me

Propeller Ads Ltd is a company registered in the Republic of Cyprus, under registration number HE353513 as a limited liability company having its registered office at Zinonos Rossidi 11, 3082, Limassol, Cyprus.

Propeller Ads Limited is a company registered in the Isle of Man, under registration number 011883V as a limited liability company having its registered office at First Floor, Jubilee Buildings, 26-28 Athol Street, Douglas, IM1 2SH, Isle of Man.

This Privacy Policy will apply to both Propeller Ads Ltd in Cyprus and Propeller Ads Limited in the Isle of Man.

We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
• Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
Accurate and where necessary kept up to date (Accuracy).
• Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
• Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
• Made available to data subjects and data subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).
• We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

Date 21st of May 2019

1.1 This privacy policy applies where we are acting as a data controller with respect to your personal data and therefore determine the purposes and means of the processing of that personal data.

1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our Website.

1.3 Our Website incorporates privacy controls you can use to specify whether you would like to receive marketing, limit the publication or any other use of your information. You can access such privacy controls via dpo@propush.me.

2.1 We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal data.

Personal data collected directly from you, including:

• when you complete our Client registration forms, which are available on our Website,
• when you enter and use our Website, and/or performing contractual obligations, and
• when you contact us for any enquiries, complaints or for any other reason.
Personal data collected from other sources, including:

• via third parties including our business partners, contractors and/or vendors in a manner that is permitted,
• through tags in websites you use and/or manage or control.

We may collect the following personal data from you depending on the service we provide to you. We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

We may disclose your personal data to the third parties listed below. When we do so, we require those third parties to have appropriate technical and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this privacy policy, nor will we sell your personal data to anyone.

4.1 Any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this privacy policy.

4.2 To our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 Payment services providers we have chosen to support us with financial transactions relating to our Website. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In specific, when paying by WebMoney your information may be disclosed and/or transferred and/or collected by Paymaster24 LTD in UK, as per the Paymaster24 LTD Privacy Policy.

4.4 Governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable Propush.me to comply with its legal and regulatory requirements.

4.5 Partners, contractors and/or vendors in order to perform contract we have with you.

You have the following rights in terms of the personal data we hold about you:

We endeavour to address all of your requests promptly.

6.1 We may transfer your personal data to our offices in the Isle of Man, where the European Commission has determined that the territory provides adequate protection for the privacy rights of individuals. We will only do so when it is necessary for one of the purposes set out in this Privacy Policy.

6.2 We do not envisage that any of your personal data will be transferred to any other countries outside the European Economic Area (EEA) as our offices, facilities, subcontractors and other third parties with which we work are all located within the EEA.

6.3 In the event that this changes in the future and one or more recipients of your personal data are located outside the EEA, where data protection laws may be of a lower standard than in the EEA, we will impose the same data protection safeguards that we deploy inside the EEA to ensure that your personal data are always protected.

7.1 We will keep your personal data for as long as is necessary for the purpose for which we initially collected them. Once such period has ended, we will keep your personal data for the longest of the following periods: a) any retention period set out in our retention policy which is in line with regulatory requirements relating to retention; or (b) the end of the period in which legal action or investigations might arise in respect of the services provided.

7.2 Once the retention period of your personal data lapses, we will ensure that your personal data are either irreversibly anonymised or securely destroyed.

8.1 We deploy various security measures such as encryption and authentication tools in line with the current state of the art to protect and maintain the security, integrity and availability of your personal data.

8.2 100% protection against unauthorised access in the case of data transfers across the internet or a website cannot be guaranteed, but we and our service providers and business partners do our utmost to protect your personal data in line with the prevailing data protection legislation by means of physical and electronic physical precautions. Among other things, we use the following measures:

• Strict criteria for authorisation to access your personal data on a "need-to-know" basis only and exclusively for the specified purpose;
• Transfer of acquired data in secured form;
• Storage of confidential data in our secure servers;
• Firewall safeguarding of IT systems to provide protection against unauthorised access, and
• Continuous monitoring of access to IT systems to detect and prevent the misuse of personal data.

8.3 If you have received a password from us in order to be able to access certain parts of our Website, you are responsible for keeping this password confidential and for compliance with all other security procedures which we make you aware from time to time. We ask you not to share your password with anyone.

9.1 Our Website uses cookies to distinguish you from other users of the Website and provide contractual obligations in a high quality level. This helps us to ensure its smooth operation in order to improve your experience. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy at https://propush.me/cookies/

10.1 We may update this privacy policy from time to time by publishing a new version on our Website.

10.2 We will notify you appropriately when we make changes to the privacy policy and we will amend its revision date so that you know when we last amended it. We do however encourage you to review this statement periodically so as to always be informed about how we are processing and protecting your personal information.

10.3 We may notify you of changes to this policy by email or through the private messaging system on our Website.

11.1 If you have any questions about our privacy policy or wish to obtain more details in relation to the personal data we process about you or wish to exercise any of your rights set out in Section 5, please contact us via email at: dpo@propush.me.