Privacy Policy
Effective Date: December 17, 2025
This Privacy Policy explains how C.A.M. First Agency Kft. (also referred to as "our", "us" and "we") collects, uses, shares, and protects your personal data when you use our application AdRaptor (the “App”). It also outlines your rights under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). In all instances we are committed to transparency with our customers, employees, and to protecting your data privacy.
By using the App, you agree to the practices described in this Privacy Policy. If you do not agree with this policy, please do not use the App.
1. Data Controller
Name: C.A.M. First Agency Kft.
Address: 1213 Budapest, Csalitos utca 11
Email: info@adraptor.ai
We are the data controller responsible for your personal data under the GDPR.
2. Data Storage
Your personal data is stored and processed on secure servers operated by our hosting provider, INTROSERV d.o.o., located in:
- Primary Data Center: Naaldwijk, Netherlands
- Backup/Failover Locations: Naaldwijk, Netherlands
If personal data is transferred outside the European Economic Area (EEA) — for example, to our cloud service providers or partners located in countries that do not have an adequacy decision by the European Commission — we implement appropriate safeguards, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Binding Corporate Rules (BCRs) where applicable
- Encryption and pseudonymization to enhance data protection
These measures are designed to ensure that your data receives the same level of protection as it would within the EEA, in accordance with Articles 44–49 of the GDPR.
3. What Personal Data We Collect
The table below explains what personal data we collect and why.
| Category of Personal Data | Specific Data | Purpose of Processing | Retention |
|---|---|---|---|
| Contact data | Email address | Adding you to the waitlist and notifying you about product availability | Until you are removed from the waitlist or request deletion |
| Marketing data (optional) | Email address | Sending occasional product and development updates | Until you withdraw your consent |
| Consent records | Consent text, date and time, method of consent | Demonstrating GDPR compliance | Stored for the duration of the consent and afterwards as required by law |
| Technical data | IP address | Documenting consent and preventing fraud | Stored for the duration of the consent and afterwards as required by law |
| Technical data | Browser and device information (user agent) | Documenting consent and preventing fraud | Stored for the duration of the consent and afterwards as required by law |
We do not collect any additional personal data unless you voluntarily provide it.
4. Legal Basis for Processing
We process your personal data based on one or more of the following legal grounds:
- Consent: When you voluntarily provide data or agree to optional features
- Performance of a Terms of Service: To provide the App’s services and functionalities
- Legal Obligation: To comply with applicable laws
- Legitimate Interests: For analytics, improvements, and fraud prevention
5. How We Use Your Data
We use your data to:
- Operate and maintain the App
- Personalize your experience
- Respond to customer support requests
- Send service-related notifications and updates
- Analyze app usage for improvements
- Comply with legal obligations
6. Data Sharing and Disclosure
We do not sell your personal data. We may share it with:
- Service providers and partners who support the app’s functions
- Authorities when required by law or court order
- Affiliates and subsidiaries under common ownership
- Third-party analytics providers (e.g., Google Analytics)
7. Third-Party Services
We use certain third-party service providers to operate, analyze, and improve our App. These providers may process limited personal data on our behalf under strict contractual obligations and GDPR compliance standards.
The services we use include:
| Service | Purpose of processing | Location(s) | More information |
|---|---|---|---|
| Google Analytics | Analytics | USA | https://cloud.google.com/security/compliance |
These third parties are bound by data protection agreements.
8. International Data Transfers
If your data is transferred outside the European Economic Area (EEA), we ensure adequate protection by:
- Using countries with adequacy decisions by the European Commission, or
- Applying Standard Contractual Clauses (SCCs) approved by the European Commission
9. Data Retention
We retain your personal data only for as long as necessary for the purposes described in this policy, or as required by law. Criteria include:
- Duration of your account activity
- Legal obligations
- Resolution of disputes
10. Your Rights
As a data subject, you have the following rights:
- Right to Access: Know what personal data we hold
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure: Request deletion (“right to be forgotten”)
- Right to Restrict Processing
- Right to Data Portability
- Right to Object
- Right to Withdraw Consent
- Right to Lodge a Complaint with a supervisory authority
To exercise these rights, contact us at: info@adraptor.ai
11. Security Measures
We implement appropriate technical and organizational measures to ensure data security, including:
- Encryption
- Access controls
- Regular audits
- Incident response procedures
12. Data Breach Notification
We implement appropriate technical and organizational security measures to protect your personal data. However, in the unlikely event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
- Notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach (as per Article 33 GDPR).
- Inform affected users directly and without undue delay, describing the nature of the breach, its likely consequences, and the steps taken to address it (as per Article 34 GDPR), unless the breach is unlikely to result in a risk to your rights.
If you suspect a data breach or have questions about our data security practices, please contact us immediately at: info@adraptor.ai
13. Children’s Privacy
14. Changes to this Privacy Policy
15. How to contact us
Email us at: info@adraptor.ai
Or write to: 1213 Budapest, Csalitos utca 11
C.A.M. First Agency Kft.