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.
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:
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:
Personal data collected from other sources, including:
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:
| Type of information | Purpose | Legal basis of processing |
|---|---|---|
| Data about your use of our Website. User ID, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, timing, frequency, pattern of your service use. | To analyse the operation of our Website and services. | Legitimate interests in monitoring and improving our Website and services. |
| Profile data. Your name, address, telephone number, email address, gender, date of birth. | Operating our Website, providing our services, communicating with you. Fulfilment of KYC/AMLprocedures. | Legitimate interests in the proper administration of our Website. Performing the contract we have with you. |
| Publication data. Information that you post for publication on our Website or through our services. | The publication data may be processed for the purposes of enabling such publication and administering our Website and services. | Legitimate interests for the proper administration of our Website and business. Performing the contract we have with you. |
| Inquiry data. | The inquiry data may be processed for the purposes of fulfilment of our KYC and AML obligations. The proper performance of our payment obligations to you. | Performing the contract we have with you. |
| Transaction data. The transaction data your contact details, your card details and the transaction details. | The transaction data may be processed for the purpose of payments and keeping proper records of those transactions. | Performing the contract we have with you. |
| Notification data. | The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. | Consent. Performing the contract we have with you. |
| Correspondence data (including AI-assisted communications). The communication content and metadata associated with the communication, including AI Assistant Interaction Data (i.e. any instructions and prompts submitted to our AI-powered features (including the AI Assistant), whether directly or through a Connected AI Agent you authorise; generated outputs; and interaction logs and related metadata), as well as messages exchanged with us via our bots in messengers or through the platform, including your full name, messenger user ID, username and related chat metadata. | The proper performance of our contractual obligations before you, including to provide and administer our Services, communicate with you about your use of the Services, enable you to use, create, manage and optimize monetization through our AI-powered features and tools, maintain records of your communications and of your actions performed through your account, and ensure the security, integrity and reliable operation of our Services and related communication channels. | Consent. Performing the contract we have with you. Where applicable (e.g. security, abuse prevention and service reliability), our legitimate interests. |
| To improve our services and AI systems (including quality assurance of our AI-powered features). Propush.me does not use personal data to train AI models; we use aggregated, anonymised or otherwise non-personal information for this purpose. | Our legitimate interests. You may object to this processing at any time (the Right to Object – see Section 5). | |
| To maintain internal records of our business communications and to manage our sales and customer relationships, including AI-assisted logging, summarisation and analysis of such communications to prepare internal reports and account overviews, with the use of AI-powered instruments subject to human review. | Our legitimate interests. You may object to this processing at any time (see Section 5). | |
| Any of your personal data identified in this policy. | Exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, the protection and assertion of our legal rights, your legal rights and the legal rights of others. | Our legitimate interests. |
| Any of your personal data identified in this policy | The obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. | Our legitimate interests. |
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.
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. This category includes, inter alia: (i) the third-party provider of the Constructor; and (ii) service providers supporting our communications tools and AI-powered features, including the AI Assistant and any of our chatbots in WhatsApp, Telegram or other messengers. In particular, where you communicate with us via our chatbots or use AI-powered features of our platform (including the AI Assistant), we may disclose limited correspondence and interaction data (such as your full name and username or user ID in the relevant messenger, the content of chat messages, the prompts and instructions submitted to such features, and related information) to providers of AI services/models (e.g. OpenAI, Anthropic) acting on our behalf and under appropriate contractual safeguards, used to generate automated replies and outputs and to support the operation, security and quality of such features, only to the extent necessary for the purposes described in this Privacy Policy. Such service providers implement appropriate technical and organisational measures to protect your personal data.
4.6. Advertising Platforms for Audience Matching. Where you have previously provided your consent to the relevant third party from whom we receive the information in question, we may share your hashed email address with third-party advertising platforms, including but not limited to those listed below, for the purpose of audience matching and targeted advertising in a pseudonymous form (SHA-256 hash):
| Platform | Data Processing Terms |
| Google Ads | https://privacy.google.com/businesses/processorterms/ |
| Meta Ads | https://www.facebook.com/legal/terms/dataprocessing |
| LinkedIn Ads | https://legal.linkedin.com/dpa |
| Reddit Ads | https://advertising.reddithelp.com/en/categories/policy-guidelines/data-processing-addendum-custom-audiences |
| X (Twitter) Ads | https://gdpr.x.com/en/controller-to-controller-transfers.html |
Each of these platforms acts as an independent data controller with respect to their own users’ data. They process the uploaded hashed email addresses under their own privacy policies and data-processing terms (linked above). International transfers of data to these platforms (where applicable) are conducted on the basis of, at least, Standard Contractual Clauses (SCCs), as implemented by those platforms under their respective data-processing terms. Users whose data is shared with advertising platforms for audience-matching purposes may exercise their right to object and opt out at any time by contacting us at dpo@propush.me.
4.7. Sub-processors and service providers that support the operation of our platform and AI-powered features, including providers of artificial-intelligence, machine-learning and cloud-hosting services, who process personal data on our behalf and under appropriate contractual safeguards, solely for the purposes set out in this policy.
4.8. Where you connect a Connected AI Agent or authorise a third-party application or AI provider to access your account or our API, we will make available to that agent, application or provider the account and related data necessary to perform the operations you request. Such disclosure is made on your instruction and at your direction; you are responsible, as controller or otherwise, for that recipient’s subsequent processing of the data, including where the recipient is located outside the EEA.
You have the following rights in terms of the personal data we hold about you: the right to be informed; the right to access; the right to correction (rectification); the right to erasure (the right to be forgotten); the right to restrict processing; the right to data portability; the right to object (including to processing based on our legitimate interests, such as processing for the improvement of our services and AI systems and for internal business-communication analysis); the right to withdraw consent; and the right to complain to the data-protection authorities responsible (see http://www.dataprotection.gov.cy). We endeavour to address all of your requests promptly.
6.1. Your personal data may be transferred to, or accessed from, countries outside the European Economic Area (EEA), including where the operation of our platform or our AI-powered features involves our sub-processors and service providers (including, without limitation, providers of AI services/models located in the United States such as OpenAI and Anthropic, cloud-hosting providers, and the third-party advertising platforms listed in clause 4.6) or the third-party provider of the Constructor. Where such transfers take place, we ensure that an appropriate transfer mechanism and safeguards are in place in accordance with applicable data-protection law, such as an adequacy decision of the European Commission, and/or Standard Contractual Clauses, together with supplementary measures where required. You may contact us at dpo@propush.me for further information on the safeguards applied.
Where you direct a transfer of your data to a Connected AI Agent or a third-party AI provider of your choosing, you are responsible for ensuring an appropriate transfer mechanism for that onward transfer.
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:
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.
8.4. These obligations apply equally to any API Credentials issued to or generated by you: you are responsible for keeping them confidential, for not sharing them with any third party other than a Connected AI Agent acting on your behalf, and for notifying us promptly of any suspected compromise.
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.
This Policy was last updated on July 24, 2026.
