I. Introduction
All terms starting with a capital letter in this Privacy Policy, but not defined, have the definition provided in the General Terms of Service.
Data protection and data security are priorities for AdBooks (“AdBooks”).
AdBooks processes and uses personal data only to the extent necessary to provide Services to the User. AdBooks requests that users carefully read the General Terms of Service, this Privacy Policy, as well as the Data Processing Agreement (“DPA” or “Agreement” provided below), which constitute the agreement between AdBooks and the User.
As a service provider, AdBooks ensures that personal data of the User and their customers is collected, stored, and processed by the User only to the extent necessary for the execution of the contract between AdBooks and the User, and as authorized by law or mandated by the legislator.
AdBooks, as the service provider, will treat the confidentiality of personal data of the User and their customers in accordance with applicable data protection laws and will not disclose such data to third parties unless necessary to fulfill contractual obligations and/or legal obligations to transfer data to third parties.
In order to ensure auditability of the data processing, the creation, modification, and deletion of data will be recorded with the User’s name, their customer’s name, and the processing date.
Using the Services may require the service provider to process personal data on behalf of the User. This requires a specific data processing agreement. AdBooks and the User agree that the User is responsible for processing the data they upload into the Software and on the website, and that the User can modify or delete this data as needed. AdBooks, at all times, acts as a subcontractor because AdBooks processes data on behalf of the User. AdBooks and the User thus enter into a DPA, the terms of which are provided below.
The User confirms that they are authorized to request AdBooks to process this information and that all instructions provided will be lawful.
AdBooks will process the User’s and their customers’ data only in accordance with the User’s instructions and not for its own unauthorized use.
The User must own all data provided to AdBooks. The Software allows the User to export data and records owned by the Software, and the User can export all data before the termination of their AdBooks subscription.
AdBooks shares data for processing only for the purpose of providing its services to the User or when required by a court or regulatory authority, and in such cases, only to the extent necessary.
If AdBooks must share data outside the EEA or with territories not previously approved by the European Commission, AdBooks guarantees full compliance with the level of data protection required.
The User agrees that a copy of the bank certificate or the statement issued by their bank may be stored in the AdBooks database and external databases. The User also agrees that data retrieved from the User’s bank via a bank feed may be available and stored in the System.
AdBooks will maintain the confidentiality of all confidential information provided by the User, unless such information has become publicly available other than by breach of this clause, or if AdBooks has received such information from a third party without an obligation of confidentiality or when the information must be disclosed by a regulatory body, government agency, or competent court, and only to the extent necessary.
AdBooks undertakes all necessary technical and organizational security measures to ensure the secure processing of the User’s data and to prevent accidental or unlawful destruction, loss, or alteration of data, or unauthorized disclosure or access to data, which is contrary to data protection laws. AdBooks complies with its obligations under all applicable data protection laws as a data processor and takes specific guidance from the General Data Protection Regulation (GDPR).
In the event that consent declarations for data protection are obtained from the User in the context of using AdBooks services, it is stated that the User may withdraw such consent at any time.
II. Data Privacy Statement
AdBooks (company name: Admonet LLC – 30 N Gould St Ste R Sheridan, WY 82801, EIN number: 30-1290301) is the operator of the website and the provider of services and software. AdBooks is responsible for the collection, processing, and use of personal data in accordance with all data protection laws, particularly the General Data Protection Regulation (“GDPR”).
The User is the “controller,” and AdBooks, the service provider, is the “processor.” AdBooks uses user data only within the framework of data protection laws. AdBooks also has a Data Protection Officer (“DPO”) who can be contacted by mail or email at info@adbooks.co.
With this Privacy Policy, AdBooks explains to the User which personal data is collected and recorded during visits to the website or when the User uses the services and software offered on the website. The User will be informed about how AdBooks uses their data and the rights the User has regarding the use of their data. This data privacy statement also applies to access and use of the Software, as well as other available Services.
1. Data Security
To protect the data of the User and their customers, all data provided by the User is encrypted in accordance with the TLS (Transport Layer Security) security standard. TLS is a secure and tested standard, commonly used for online banking. The User will be able to see this secure TLS connection with an “s” following “http” in the URL displayed in their browser (example: https://…).
AdBooks also takes appropriate technical and organizational security measures to protect your data from accidental or deliberate manipulation, partial or complete loss, destruction, and/or unauthorized access. To prevent data loss, AdBooks operates a “mirror” database configuration, meaning that user data is always stored at two separate locations. Additionally, AdBooks updates and stores data every 24 hours in an offsite backup in accordance with high-risk analysis protocols. The User’s password is stored via a secure encrypted process. AdBooks will never ask the User for their password via email. If the User forgets their password, AdBooks can reset it. AdBooks continuously improves its security measures in accordance with technological advancements.
Personal data collected by AdBooks is stored in a secure environment in Germany and is treated confidentially. Access to this data is restricted to selected employees and suppliers of AdBooks. AdBooks always complies with legal data protection requirements.
AdBooks Data Security Measures and Data Collection
AdBooks makes every effort to ensure the security of the User’s and their customers’ data to the best of its ability, but it cannot guarantee the security of such data when transmitted via the Internet. When data is transmitted over the Internet, there is always a risk that third parties may access the data in an unauthorized manner. In other words, AdBooks cannot be held responsible in the case of data leakage or unavailability due to force majeure. The security of User data during transmission is the responsibility of the User as the data controller.
2. Collection and Storage of Personal and Business Data, and the Nature and Purpose of Their Use
A. During User Visits to the Website
The User can visit the website without disclosing their identity. The User’s browser automatically sends certain information to the website’s servers. This information is temporarily stored in a document called a “log.” The following information is automatically collected and stored until it is automatically deleted:
- The IP address of the requesting computer,
- Date and time of access,
- The name and URL of the accessed data,
- The referring website (referrer URL),
- The browser used and, if necessary, the operating system of the User’s computer, as well as the name of the access provider.
These data are collected and processed for the purpose of enabling the use of the website (establishing a connection), ensuring the security and stability of the AdBooks system, as well as for the technical administration of the network infrastructure. AdBooks does not draw any conclusions about the User as an individual based on this data. Additionally, AdBooks uses cookies, as well as web analysis and marketing tools.
B. During User Registration for Online Services
On the website, AdBooks offers online invoicing and quoting services. To use these services, the User must first register. During registration, the User is required to provide an email address and create a password so that AdBooks can create an account for the User and allow access. If the User wishes to use country-specific features, they must first select the country where their business is located.
To use all features and services, it may be necessary to provide additional personal data. For example, to generate a legal invoice, the User must enter the name of their company, address, account number, and payment information, etc. AdBooks also uses the User’s name and contact details to identify the User, justify, process, and manage the contractual relationship between AdBooks and the User regarding the use of the services, verify the accuracy of the data entered, and, if necessary, contact the User.
C. During Newsletter/Blog Subscription
If a User agrees to receive a newsletter, AdBooks may use the User’s email address to send regular newsletters and information about Services. To receive newsletters, AdBooks must first obtain the User’s consent, which can be given during registration. The User can withdraw consent at any time, either by managing settings in their account, disabling email, or sending an email to AdBooks to request to stop receiving such communications. Users can also unsubscribe from newsletters at any time, for example, by clicking the unsubscribe link in the newsletter. info@adbooks.co
If the User unsubscribes, AdBooks will retain the email address solely to ensure the User no longer receives these emails.
D. Third-party Data (developers, customers, suppliers, accountants, teams, etc.)
Through the Services, Users can input third-party data, grant third parties access to their account, link their account with third parties, or offer third-party applications. AdBooks respects privacy regarding third-party data and may access it through the User’s use of the Services. If the User believes changes are needed, they can contact AdBooks. The User is responsible for any third-party data entered on the site.
Users should note that AdBooks has no control over compliance with data protection standards outside of the website, software, or services AdBooks provides. In such cases, the User, or any third party they’ve authorized, is responsible.
- Consent for Data Transfer
AdBooks may transfer personal data to third parties (e.g., for sending invoices or estimates electronically) if the User gives explicit consent or makes a direct request to AdBooks, or if there are obligations to do so.
AdBooks reserves the right to share data within its group of companies as necessary to provide services to the User. From time to time, AdBooks may require data sharing with a sister company, for example, for billing purposes. Data security is ensured at all times. By registering on AdBooks, the User consents to the processing of their data.
The User also explicitly consents to sharing their data with third parties when necessary for using various services.
AdBooks ensures that User data is only shared with third parties that maintain an adequate level of data security in accordance with all data protection laws.
Specifically, when AdBooks shares data with territories outside the EU/EEA or with a country not approved by the European Commission, AdBooks ensures compliance with all EU data protection standards.
The User has the right to withdraw their consent to process and/or share their data at any time, either by deactivating their AdBooks account or contacting AdBooks to request account closure, which will be processed as soon as possible. After termination of the User’s subscription, AdBooks will retain only the minimal data necessary to fulfill legal requirements for the shortest period.
For any questions regarding User data processing or if the User wishes to request data access, they can contact AdBooks’ Data Protection Officer at info@adbooks.co or by postal mail at the address provided.
If the User is dissatisfied, they have the right to file a complaint with the relevant data protection authority. AdBooks will fully cooperate with any such investigation and seek to meet all requests within its capabilities. The competent authority for each country can be found on the European Commission’s website.
Cookies
The website uses cookies. Cookies are small files automatically created by the user’s browser and stored on their device (laptop, tablet, smartphone, etc.) when the User visits the site. Cookies do not harm the device and do not contain viruses, trojans, or other malicious software.
Cookies store information related to the user’s device. However, this does not mean that AdBooks will receive detailed information about the user’s identity.
The purpose of using cookies is to create a more convenient experience when using the Services. Therefore, AdBooks uses session cookies to track whether the User has visited specific pages on the website or has already created an account. These cookies are automatically deleted by the user’s browser when they expire.
For usage purposes, AdBooks uses temporary cookies stored on the user’s device for a certain period of time. If the User visits the website again to use the services, they will be recognized as a previous visitor and the settings and actions performed will be remembered, so the User does not have to repeat them.
AdBooks also uses cookies to track website usage statistics and optimize the offering. When the User revisits the website, these cookies enable AdBooks to automatically recognize the user’s previous visit. After a certain period, the cookies will be automatically deleted.
Most browsers automatically accept cookies. The User can configure their browser to prevent cookies from being saved on their device or to always show a warning before a new cookie is created.
However, the User should note that completely disabling cookies may lead to limitations in the functionality of the website.
Web Analytics
In order to design and continuously optimize the website, AdBooks uses various web analytics services. Therefore, AdBooks creates anonymous user profiles and uses cookies.
The User will find additional information about our web analytics services and other opt-out options below. AdBooks uses, among other analytics systems, Google Analytics and Amplitude.
Information related to the use of the website, software, and services by the user (including the user’s IP address) collected through cookies is transferred to the servers of the service providers’ statistical analysis and stored there. IP addresses are anonymized, so they cannot be assigned (IP masking) to the User. This information is used to analyze the use of the website, software, and services, to create reports on website activities, and to provide other services related to the use of the website and the internet. The data the User inputs while using the Services will never be merged with other data collected by the service providers.
Data transfer by Google to third parties will only occur if required by law or if third parties process data on behalf of Google.
Additionally, AdBooks uses Google Optimize. This is a web analytics service by Google Inc., integrated with Google Analytics. Google Optimize enables A/B and multivariate testing. This allows AdBooks to understand which version of the website users prefer.
An opt-out cookie will be set to prevent future data collection when visiting the website. The opt-out cookie is valid only in this browser and for this website and will be stored on the user’s device. If the User deletes the cookie in their browser, they will need to set the opt-out cookie again.
For more information on data protection related to Google Analytics, the User can refer to the Google Analytics Help page.
- Facebook Targeting
AdBooks does not use social media plugins from Facebook or other social networks.
As part of our Facebook advertising, AdBooks uses a pixel-based tracking mechanism. This is a web analytics service provided by Facebook Ireland Ltd. The information is used for tracking conversions from the Facebook platform.
This service provided by Facebook Ireland Ltd. is subject to the European Union’s data privacy laws. AdBooks does not share any data entered by the User while using the Services with Facebook.
For more information, please visit Facebook’s data protection page for details about the purpose and scope of data collection, processing, and usage by Facebook, as well as your rights and privacy protection options.
- Google Tracking Code
AdBooks uses Google’s retargeting technology. If the User has shown interest in AdBooks’ offers, they may receive personalized advertisements based on their interests. The ads are displayed based on an analysis of the User’s previous usage behavior, as tracked by cookies, but no personal data is stored. In the case of retargeting technology, a cookie is stored on the User’s computer or mobile device to collect anonymous data about their interests and thus personalize the ads based on the stored information.
The User will then see ads that are most likely to correspond to their product interests and related information. The User can permanently opt out of the placement of advertising preference cookies by downloading and installing a browser add-on available at the following link: Google Ads Settings.
For more information and terms regarding data protection in relation to advertising and Google, the User can find details here: Google Privacy & Ads.
Information, Corrections, Blocking, Deletion
The User has the right to information about the personal data stored and the right to correct or modify incorrect data, as well as the right to block or delete such data.
As the data controller, the User is responsible for the content they publish. The User has the right to correct, block, or delete any of their data at any time. AdBooks may decide to delete content published by the User upon the User’s request, but AdBooks reserves the right not to delete content that has already been published or that must be retained to comply with legal obligations.
For more information about your personal data, correcting incorrect data, blocking or deleting data, or other inquiries regarding the use of your personal data, the User can email info@adbooks.co.
Additionally, the User can consult and modify data stored in their account by logging into the website using their login details. The User may delete their data from their account at any time using the appropriate option in their user account. AdBooks clarifies that if the User deletes their data, they may not be able to fully use the Services at best, or at worst, not at all.
- Changes to This Privacy Policy
Due to the development of the website, software, and services or due to changes in legal or regulatory requirements, it may be necessary to update this privacy policy from time to time.
- Introduction of Data Processing Agreement (DPA)
This DPA forms the basis of the relationship between the User, as the data controller, and AdBooks, the service provider, as the data processor under data protection laws (GDPR). It is an essential agreement that outlines the contractual basis for the processing of data by AdBooks on behalf of the User. It explains how the User’s data may be processed, as well as the purpose of such processing. AdBooks processes the User’s personal data solely in accordance with the User’s needs and instructions, as set out in the DPA.
Due to the scope of AdBooks’ clientele, it would be impractical to enter into a separate DPA with each individual User. Therefore, this DPA is included here and will apply between any User and AdBooks. This DPA ensures that AdBooks, as your subcontractor, complies with the requirements of the GDPR. The User is further assured that AdBooks will maintain the necessary agreements with all its third parties. The User’s company data is automatically populated in their account when they agree to the Terms of Service and the Privacy Policy (which includes the DPA). Information about the User will always represent the most recent data provided by the User to AdBooks.
Data Processing Agreement (DPA)
Between: The User (hereinafter referred to as “User” or “Controller”) acknowledging that this information will be automatically retrieved when registering.
I. AdBooks (Company Name: Admonet LLC – 30 N Gould St Ste R Sheridan, WY 82801, EIN: 30-1290301) (hereinafter “AdBooks” or “Processor”)
The parties have agreed to the terms of this Data Processing Agreement (hereinafter “DPA” or “Agreement”) regarding the processing of personal data, where the User acts as the data controller and AdBooks acts as the processor, to fulfill the service obligations described in the Service Agreement (detailed below).
As part of fulfilling these service obligations, AdBooks will process certain personal data on behalf of the controller, in accordance with the terms of this Agreement.
Each party agrees and ensures that the terms of this Agreement will apply fully to its affiliates who may be involved in the personal data processing operations for the project defined in the Service Agreement.
Specifically, AdBooks will ensure that all subcontractors operate under the same terms as this Agreement when processing the User’s personal data.
Preamble and Definitions
“Personal Data” is defined as any information relating to an identified or identifiable natural person, directly or indirectly, through an identifier such as name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual (or legal entity, if applicable).
All other definitions mentioned here, including the terms “controller” and “processor,” are determined by data protection laws, including Regulation (EU) 2016/679 of April 27, 2016 (hereinafter “GDPR”).
It is understood that sensitive personal data is not processed within the scope of the service provided by the data processing center and is, therefore, excluded from the terms of this Agreement.
By using the Software and accepting the General Terms and Conditions of Service, Privacy Policy, and this DPA, the Parties agree, in accordance with all national data protection laws and the GDPR, that this Agreement governs the relationship between the controller and processor, defining the processing of the User’s personal data by AdBooks. This Agreement takes precedence unless replaced by another signed DPA, which states its precedence over this Agreement.
The processing of the User’s personal data by AdBooks aims to ensure the full use of the Services by the User and to facilitate compliance with this Agreement. AdBooks guarantees that appropriate security measures will be maintained to protect personal data at all times.
The Parties confirm their authorization to enter into this Agreement.
Responsibilities of the Processor
The processor (AdBooks) must manage all personal data on behalf of the controller and follow the controller’s instructions. By entering into this Agreement, AdBooks (and all subcontractors with whom AdBooks has a legal agreement for services) assumes responsibility for processing the User’s personal data:
i. In compliance with all applicable national and European laws
ii. To fulfill its obligations under the service requirements
iii. Following the instructions of the controller
iv. As outlined in this Agreement
Subprocessor’s Responsibilities
The subprocessor is responsible for providing continuous support to users, optimizing their experience with the service, offering relevant suggestions, and ensuring accurate communication. Any personal data processed within the Software must comply with this DPA and applicable laws. The subprocessor must implement appropriate technical and organizational measures to ensure the security of personal data, taking into account the available technology, implementation costs, and the specific goals of the processing. If the subprocessor becomes aware of any security breach, they must immediately notify the data controller.
Additionally, if a third party requests access to personal data, the subprocessor must notify the controller and respond only under their instructions. All subprocessor’s employees and affiliates must maintain confidentiality regarding the data, and this obligation continues even after the termination of the agreement.
Data Controller’s Responsibilities
The data controller confirms they are responsible for the lawful use of personal data, including obtaining necessary permissions and notifications to relevant authorities. The user must have a legal basis for processing data and explicit consent for processing when using the Software, which can be withdrawn at any time, leading to the termination of the service. The controller is responsible for the accuracy, integrity, and reliability of the data sent to the processor, as well as for fulfilling all legal obligations related to personal data processing. The controller must also maintain a precise list of the categories of data being processed.
Data Transfer and Subprocessor Agreement
To provide Services to the Controller, the Processor uses subprocessors. These subprocessors may include third-party providers both within and outside the EU/EEA. The Data Processor ensures that all subprocessors comply with the obligations and requirements of this agreement, particularly ensuring that their data protection levels meet the standards required by relevant data protection laws. If the jurisdiction is outside the EU/EEA and not on the European Commission’s list of approved adequate data protection levels, a special agreement will be concluded between AdBooks and the subprocessor to ensure the maintenance of all personal data.
This Agreement constitutes the Controller’s specific and explicit prior consent for the Data Processor to use data processors, which may sometimes be located outside the EU/EEA or in territories approved by the European Commission.
The Controller may withdraw this consent at any time, but doing so will terminate the agreement, and the Data Processor will no longer be able to provide the Service.
If the Subprocessor is established or stores personal data outside the territory approved by the EU/EEA or the European Commission, the Subprocessor is responsible for ensuring the transfer of personal data to a third country on behalf of the Controller. This includes the use of the European Commission’s standard contractual clauses or other special measures previously approved by the European Commission.
The Data Controller must be notified before the Processor changes its subprocessors. The Controller may then object to the new subprocessor processing their personal data on behalf of the Processor, but only if the Processor does not process the data in accordance with relevant data protection laws. The Processor can demonstrate compliance by allowing the Controller access to the data protection assessment carried out by the Processor.
If the Data Controller continues to object to the use of the subprocessor, they may immediately terminate their subscription to AdBooks’ services and ensure that their personal data is not processed by the unwanted subprocessor.
Termination of Agreement
In the event of subscription termination, the Subprocessor will delete all personal data, except for data that must be retained in accordance with applicable legal provisions. In such cases, the data will be retained according to the technical and organizational guarantees provided by AdBooks.
The Data Controller has full access to download all their personal data from the Software. If the Data Controller requests assistance with downloading their data, the associated costs will be determined by mutual agreement between the parties and will depend on the complexity of the requested process and the time needed to complete it in the chosen format.
Annexes:
Annex A – Categories of Personal Data and Typical Processing Categories
A. Categories of Personal Data (Non-exhaustive list)
i. Last name
ii. Address
iii. Phone numbers
iv. Email addresses
v. Mailing addresses
vi. Any account number(s) and/or banking information
B. Common Categories of Processing (Non-exhaustive list)
i. Employees of the Controller
ii. Contact persons of the data Controller (phone/email/address, etc.)
iii. Customers of the Controller
iv. Banking details of the data Controller
v. Employees of their clients
vi. Contacts of their clients (phone/email/address, etc.)
vii. Customers of their customers
viii. Banking information of their clients
AdBooks Application Ownership and Legal Entity
The AdBooks application is owned by:
Admonet LLC
Address: 30 N Gould St Ste R, Sheridan, WY 82801, United States
EIN Number: 30-1290301
As AdBooks is owned by Admonet LLC, all references to the AdBooks application and its policies apply equally to Admonet LLC.
