Privacy Policy

Welcome to (the "Site"), which is operated by XXX ("we", "us", "our"). We process both personal and non-personal (anonymous) data from our visitors to the Site ("you", "your"). This Privacy Policy aims to inform you about the personal data we process as you use the Site, and how we use that data. By accessing and using our Site, you agree to the terms outlined in this Privacy Policy.

1. About Us

Adltclub is a company based in the United States that primarily provides website traffic to our clients. If you have any questions regarding our Privacy Policy or wish to access, rectify, restrict, or erase your personal data, please contact our Data Protection Officer at

2. General

We prioritize your privacy and are committed to complying with relevant laws and regulations regarding personal data processing, including the General Data Protection Regulation ("GDPR") and the Dutch GDPR Implementation Act. Definitions used in this Privacy Policy should be read in accordance with Article 4 of the GDPR. Specifically:

Personal data refers to any information that relates to an identified or identifiable natural person. An identifiable natural person is someone who can be directly or indirectly identified by an identifier, such as a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity. Processing refers to any operation or set of operations performed on personal data, whether or not automated.

The GDPR does not apply to anonymous information, which is information that does not relate to an identified or identifiable natural person or personal data rendered anonymous such that the data subject is no longer identifiable. This includes processing anonymous data for statistical or research purposes. We process your personal data securely, protecting it against unauthorized or unlawful processing, accidental loss, destruction, or damage, using appropriate technical and organizational measures.

3. Legal Basis for Processing Personal

Data We process your personal data on one of the following lawful bases:

  • You have given consent to the processing of your personal data for one or more specific purposes (see ยง4);
  • Processing of your personal data is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • Processing is necessary for compliance with a legal obligation to which we are subject;
  • Processing is necessary to protect your or another person's vital interests;
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (such as preventing fraud or direct marketing), except where such interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

4. Purposes of Processing Personal Data

We process personal data for specific purposes, which are as follows:

  • To fulfill and perform a contract between you and us;
  • To offer you requested services and information tailored to your preferences;
  • To enable you to interact with our website features;
  • To process your requests, feedback, or reports;
  • To analyze and optimize our Site and services;
  • To analyze incoming and outgoing traffic (clicks) on our Site;
  • To conduct market research and gather information for product and service development;
  • To comply with applicable laws and regulations;
  • To prevent fraud or misuse of our services; and
  • To cooperate with law enforcement and government agencies.
We retain your personal data only for as long as necessary for the above-mentioned purposes or to comply with statutory storage obligations.

5. Cookies

We collect personal data passively through cookies and similar technologies, which are provided by you, your browser, or your device. We consider this data anonymous because it does not relate to an identifiable natural person. However, some parts of this information may be considered personal data under GDPR rules when combined with other information. We use cookies to analyze website traffic and enhance your browsing experience. We do not require consent for the placement of analytical and functional cookies, but your consent is automatically given when you perform a clear affirmative act, such as clicking on a website feature. You can withdraw your consent by clearing your cookies and adjusting your browser settings, although this may limit your use of our site. We use persistent cookies to recognize you and tailor our site to your preferences, and session-based cookies to optimize and adapt the site to your behavior. We use first-party and third-party analytical cookies, and store your language setting in a persistent cookie.

Personal Data Obtained Through Interactions:
We may temporarily process personal data provided by you when using specific website features or sending us (e-mail) messages. For example, you may provide your e-mail address when reporting malware or send us other (personal) data via message. We will only process this data to handle your request or feedback, and the retention period depends on the extent of your request and our legal obligations.

E-mails and Other Messages/Mediums:
We process personal data included in messages such as e-mail address, message content, and technical information for handling requests or feedback. We may use the customer service and ticketing system of Zendesk Inc. to process certain e-mails. Zendesk has appropriate safeguards in place for personal data processing.

Report Tool:
If there is an issue with content on our site, you can notify us by using our Report Tool. The information we process with such a report is stored temporarily and limited to technical data. Any personal (contact) information you voluntarily provide will be temporarily processed by us solely for processing your report and fraud prevention.

No Memberships, Subscriptions, Accounts, Profiles, etc.:
We do not provide memberships, subscriptions, accounts, profiles or any other means that lead to an agreement between you and us apart from your use of the website. In the event that you come across a feature on this site that requests your personal data for such a purpose, you should be aware that this is a request originating from a third party, not from us.

We provide an overview of the information (including personal data) that we process if you actively provide this information to us. The retention periods for personal data depend on the extent of your request and our legal obligations.

E-mails (or other messages)
Purpose of storage Storage period
E-mail address and/or username/account-name To process your request Deleted after 5 years *
Personal data included in your message (if you chose to provide this to us) To process your request Deleted after 5 years *

Report Tool
Purpose of storage Storage period
E-mail address (if you chose to provide this to us) To process your report Masked after 1 month
Any other (technical) information included in your report To process your report Deleted after 1 year
* The extent of your request might result in a longer (or shorter) storage period. This will be communicated to you if applicable.

6. Use of Personal Data

We use passively collected and aggregated information from cookies to conduct market research, improve our services, optimize user experience, track clicks to improve rankings, and analyze traffic to and from our site. Cookies allow us to personalize your experience by recognizing your language settings. We consider this data anonymous as it does not relate to an identified or identifiable natural person.

Other Personal Data:
Personal data you actively provide through the site is processed to fulfill your request, feedback, or report. We do not disclose your personal data or information on your use of our services or accessible site(s) to third parties unless strictly necessary at our discretion. We will disclose such information to satisfy legal regulations, legal requests, to identify, contact or take legal action against someone violating our Terms of Use, operate our services, process your request, or protect our site's visitors and the public. We reserve the right to disclose all information to law enforcement agencies in the event of a crime, suspected crime, or if legally obligated to do so.

7. Your Rights

Access, Rectification, Restriction, and Erasure:
You can contact us to request access, rectification, restriction, or erasure of your personal data. We cannot guarantee the retrieval of your personal data as most of it is anonymized and aggregated. In cases where we can retrieve data, we cannot rectify emails or messages but can delete them upon request. Legitimate interests may require us to continue processing your personal data.

Data Portability:
You have the right to receive your personal data in an interoperable format for transmission to another service provider. We cannot guarantee the availability of your personal data in such a format.

Withdrawing Consent:
You can withdraw your consent for any personal data provided via site interactions or cookies. We may have a legal obligation to retain your personal data to comply with applicable laws and regulations.

You have the right to lodge a complaint with a supervisory authority.

8. Data Security

We have implemented technical and organizational measures to prevent unauthorized or unlawful processing, inappropriate use, inaccuracy, accidental loss, destruction, and damage of (personal) data stored on our network and systems.

9. Third-Party Websites

This Privacy Policy does not apply to personal data processing by linked third-party websites. We cannot guarantee that such websites have implemented adequate technical and organizational measures for safeguarding your personal data.

10. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy. Please visit this page regularly to read the latest version of the Privacy Policy.

11. Contact Us

If you have questions about our Privacy Policy or your personal data, please contact our Data Protection Officer at