Privacy Policy
Controller: AdWave LTD
Company Number: HE 380370
Date of Incorporation: 23 February 2018
Registered Address: Eleftherias 113, 3042, Limassol, Cyprus
Website: https://adskill.com
Privacy Contact: info@adskill.com
Last Revised: 14 August 2026
This Privacy Policy describes how AdWave LTD, operating under the adskill brand (“AdWave”, “adskill”, “we”, “us” or “our”), collects and handles personal data in connection with adskill.com, our business communications and the advertising-account, campaign-support, consulting, partner and related services made available by adskill. It is intended to provide a practical and transparent explanation of the information that can come into our possession, the reasons for which it is used, the circumstances in which it can be disclosed, the periods for which it is kept and the rights available to individuals.
AdWave LTD is incorporated in Cyprus. For processing falling within the scope of European data-protection law, our principal framework is Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”) together with Cyprus Law 125(I)/2018 and other mandatory rules applicable to the relevant activity. Some interactions with clients, partners, platforms or individuals may also be subject to additional local requirements. Where those requirements apply to AdWave, we address them in the context of the relevant processing activity.
1. Controller, scope and relationship with other documents
AdWave LTD is the controller for personal data where it determines the purposes for which the information is used and the essential means of processing. This includes, in particular, the operation and security of the adskill website, management of enquiries and commercial relationships, client administration, billing, internal compliance, business communications, recruitment and the protection of our legal rights. The precise role of AdWave in relation to data available within a client advertising account or campaign environment is addressed separately in Section 6 below because that role depends on the service configuration and the instructions agreed with the client.
This Policy applies to processing carried out through the website and in the course of our business activities. It should be read together with the adskill Cookie Policy and with any privacy or data-processing provisions contained in a client agreement, order form, platform-specific terms or other written service documentation. Where AdWave processes personal data solely on behalf of a client under documented instructions, the terms governing that processing may contain more specific requirements and will apply to that processing in addition to this Policy.
The website and adskill services are primarily designed for business and professional audiences. They are not directed to children. We do not seek to collect personal data from children through ordinary website forms, sales communications or client onboarding processes.
2. Individuals and business relationships covered by this Policy
The individuals whose personal data may be processed under this Policy include representatives and personnel of current and prospective clients, representatives of advertising platforms and technology providers, business partners, participants in referral or cooperation programs, website visitors, newsletter or event contacts, suppliers and professional advisers, job applicants and other persons who communicate with adskill in a business context.
A person may interact with us in more than one capacity. For example, a company representative can first contact adskill through a project enquiry, later become an authorized user or operational contact under a client relationship, and subsequently participate in an event or receive service updates. We assess the purpose and legal basis of processing by reference to the particular interaction rather than treating every contact record as having a single purpose.
Where an organization provides us with information about its employees, contractors, customers, leads or other individuals, that organization is expected to ensure that the disclosure is lawful and that any notices, consents or other legal grounds required for its own collection and disclosure have been addressed. This does not reduce the obligations that apply to AdWave in respect of the processing we carry out.
3. How personal data reaches us
Personal data may be obtained directly from the individual, from the organization the individual represents, from a client or partner, from an advertising or technology platform, or through the technical operation of the website and our services. We may also receive business contact information through professional introductions, referral arrangements, industry events or publicly available professional sources where the use of that information is compatible with applicable law.
Direct collection occurs when a person completes a website form, contacts our sales, support, recruitment or other business teams, sends an email or message, joins a business discussion, requests information, participates in onboarding, gives an operational instruction, submits materials for review, applies for a role or otherwise communicates with adskill. Website and security systems can also generate technical records automatically when the website or a protected form is used.
In service delivery, information may also be generated or made visible within an advertising account, billing environment, campaign dashboard, support system or integration used for the client. The extent of this access depends on the advertising platform, account structure, permissions and service requested. Where data has not been obtained directly from an individual, we handle it in accordance with the transparency and other requirements that apply to the relevant processing, taking into account our role and the source of the information.
4. Categories of personal data we may process
The categories of data processed by adskill depend on the context. Business and contact information may include a name, job title, company, business address, email address, telephone number, country or market, Telegram or other messenger identifier, preferred language and details showing a person’s authority or role within the organization represented.
Commercial and relationship information can include the subject of an enquiry, correspondence history, meeting records, project requirements, intended advertising platforms, target markets, expected or actual budgets, service selections, commercial terms, account status, support history, operational instructions and other information needed to understand and administer a business relationship. For partner and referral relationships, this can also include information relevant to the introduction, referral status, cooperation terms and communications concerning referred business.
Technical and website information can include IP address, browser and device characteristics, operating system, language settings, approximate location derived from technical signals, referring pages, timestamps, pages viewed, interaction with forms, security events, session information and cookie or similar identifiers used by technologies enabled on the website. The current use of cookies and comparable technologies is described more specifically in the Cookie Policy.
Billing and transaction information can include billing contacts, invoice details, payment status, transaction references, currency and amount information, account-funding records, reconciliation data and related correspondence. Where a payment is handled by a bank, payment institution or other independent financial provider, that provider may collect additional information under its own legal duties and privacy documentation.
Recruitment information can include a CV, contact details, employment and education history, professional qualifications, portfolio or work samples, links to professional profiles, compensation expectations, interview notes, communications and other information voluntarily supplied in connection with an application. We do not request special categories of personal data as a routine part of ordinary website, client or recruitment processes. If such information becomes genuinely necessary in a specific situation, it is handled only where an appropriate legal basis and safeguards are available.
5. Advertising accounts, campaign environments and service data
A core part of the adskill business involves agency advertising accounts, support for advertising activity and related operational services. Depending on the platform and service selected, AdWave personnel may have access to information associated with the relevant advertising account or campaign environment. This may include platform and account identifiers, user permissions, account settings, campaign configuration, creatives and landing-page references, moderation or verification status, budget and spend information, billing status, performance metrics, platform notifications, support history, conversion or attribution information and technical details used to establish, maintain, fund, troubleshoot or optimize the advertising environment.
Some information visible in an advertising environment may qualify as personal data even when it does not contain a person’s name. Online identifiers, account identifiers, device-related information, attribution records or sufficiently granular event data may fall within data-protection rules depending on the circumstances. The fact that information is described by a platform as campaign, technical or statistical data does not by itself determine its legal status.
adskill does not require clients to provide raw databases of end-user personal data as a standard condition of obtaining an agency advertising account. If a particular service or technical arrangement requires the client to make personal data available to AdWave, the data should be limited to what is necessary for the agreed purpose. Clients must not provide special-category data, unlawfully obtained audience information or personal data that they are not authorized to disclose. Where a platform permits audience uploads, conversion integrations or similar functions, responsibility for the lawfulness of the client’s underlying data collection and campaign use remains allocated in accordance with the applicable agreement and law.
6. Our role in service-related processing and client responsibilities
The legal role of AdWave can vary across processing activities. AdWave acts as a controller for its own client-management, billing, security, compliance, business-development and legal functions because we determine why those activities are carried out and how the corresponding records are managed. Within a client-controlled campaign or advertising environment, AdWave may act on the client’s behalf where our access to personal data is limited to performing documented instructions connected with the agreed service.
Where AdWave acts as a processor, the relevant processing is governed by the applicable client agreement, data-processing agreement or other contractual data-protection terms. Those arrangements define the service context and the obligations applicable to the parties. We use personal data made available in that capacity for the agreed purposes, apply appropriate security and confidentiality measures, and handle retention, deletion and assistance requests in accordance with the contract and applicable law.
Clients remain responsible for the purposes for which they use their advertising accounts and campaigns, the legality of the data and audiences they supply to advertising platforms, the notices and legal grounds required for their own processing, and the instructions they give to adskill. A client must also ensure that its advertising materials, landing pages, tracking configuration and requested targeting practices comply with applicable law and the requirements of the advertising platforms it uses. Where the allocation of data-protection roles differs for a particular service, the actual processing arrangement and the applicable written terms will determine the respective responsibilities.
7. Purposes of processing and legal bases
We process personal data for specific purposes connected with the operation of adskill and select a legal basis appropriate to the relevant activity. Under the GDPR, these bases can include taking steps requested before entering into a contract, performance of a contract with the individual, compliance with a legal obligation, consent and legitimate interests pursued by AdWave or another party where those interests are not overridden by the rights and freedoms of the individual.
Enquiry and client-management data is used to respond to requests, assess proposed projects, prepare commercial terms, verify the authority of client contacts, conduct onboarding, administer access to services, coordinate account provision, provide support and consulting, manage platform-related communications and maintain the commercial relationship. Depending on the person and context, this processing is necessary for steps preceding a contract, performance of a contract or our legitimate interest in managing a business relationship with the organization that the person represents.
Operational and technical information is used to maintain service continuity, investigate technical issues, support account access, document instructions, detect misuse or fraud, manage security and platform risks, maintain audit trails, improve service processes and protect adskill, our clients and our infrastructure. We carry out these activities on the basis of legitimate interests in secure and effective business operations, and where an activity is required by law we rely on the corresponding legal obligation.
Billing, transaction and corporate records are used for invoicing, reconciliation, accounting, tax administration, audit, sanctions or other compliance checks where applicable, record-keeping, dispute management and the establishment, exercise or defence of legal claims. Legal obligations apply to part of this processing, while legitimate interests support activities such as internal financial controls, evidence preservation and the protection of contractual rights.
Recruitment data is used to review applications, assess qualifications and suitability, arrange interviews, communicate with candidates and manage the recruitment process. Where appropriate and permitted, limited applicant information may also be retained for a reasonable period to consider the person for future opportunities. The legal basis depends on the stage and nature of the recruitment activity and can include steps taken at the request of the candidate, legal obligations and legitimate interests in recruitment and workforce planning.
If information is required to enter into or administer a client relationship, complete a payment, satisfy a platform or legal requirement, or respond to a request, failure to provide the necessary information can mean that we are unable to complete the relevant step or provide the requested service. Where provision is optional, the person may choose whether to provide the information unless a separate legal or contractual requirement applies.
8. Direct marketing, newsletters and relationship communications
adskill may communicate with clients, prospective clients and professional contacts about services, platform developments, events, educational materials, partner opportunities and other matters that are reasonably connected with our business. We distinguish ordinary service or relationship communications from promotional communications. Messages needed to administer an active account, respond to a request, provide support, communicate a material service change or address a compliance or security matter are sent as part of the relevant business relationship.
Promotional communications are sent in accordance with the rules applicable to the recipient and the communication channel. Where consent is required, we rely on consent. Where the law permits business-to-business marketing or relevant relationship-based communications on another basis, we may rely on a legitimate interest after considering the context, the nature of the relationship and the reasonable expectations of the recipient.
A recipient can stop marketing communications at any time by using the unsubscribe option provided in the message where available or by contacting info@adskill.com. We may retain a limited suppression record after an opt-out so that the preference can be respected and the person is not inadvertently added back to the same marketing stream. An opt-out from marketing does not prevent us from sending operational, contractual, security or legally required communications that remain necessary for an existing relationship.
9. Website data, cookies and similar technologies
The adskill website uses technical mechanisms needed to deliver pages, protect forms and sessions, maintain security and support the functions made available to visitors. Depending on the technologies enabled at a given time, cookies, local storage, tags, pixels, scripts or comparable tools may also be used for measurement, functionality or other purposes. The Cookie Policy identifies the technologies currently used, their purposes and the controls available to visitors.
Where applicable law requires prior consent for a non-essential website technology, that technology is intended to operate only after the required choice has been obtained through the relevant consent mechanism. Consent choices can be changed through the available preference controls where provided. Browser settings can also be used to restrict or delete many cookies, although blocking technologies necessary for security or core functions may affect the operation of parts of the website.
Technical records generated by the website may be used for security monitoring, diagnostics, traffic analysis, prevention of abuse and improvement of website performance. The legal basis depends on the technology and purpose. Essential security and operational processing may rely on legitimate interests, while technologies requiring consent are used on that basis where the consent requirement applies.
10. Recipients, service providers and disclosures
Personal data is disclosed only where there is a business, service, legal or compliance reason for the recipient to receive it. Within AdWave, access is limited to personnel and authorized contractors whose responsibilities require the relevant information. Access is managed with regard to the nature of the data and the function being performed.
In the course of providing services, relevant information may be shared with the advertising platform or network concerned, account and technology partners, hosting and cloud providers, communications and support systems, customer-relationship management providers, security and fraud-prevention vendors, measurement or integration providers and other suppliers that support the operation of the requested advertising environment or our internal business systems. The information made available to a provider is limited, where reasonably possible, to what is required for the function performed.
Banks, payment institutions, accountants, auditors, insurers, lawyers and other professional advisers may receive information where necessary for payments, accounting, assurance, risk management or professional advice. Courts, regulators, law-enforcement authorities and other public bodies may receive information where disclosure is required or permitted by law or where it is necessary to establish, exercise or defend legal rights. Information can also be disclosed in connection with a proposed or completed financing, restructuring, merger, acquisition or sale of business or assets, subject to appropriate confidentiality and data-protection arrangements.
Where a recipient processes personal data on our behalf, we use contractual and organizational measures appropriate to the service and the legal role of the provider. Providers acting as processors are expected to handle personal data only for authorized purposes, protect confidentiality and implement appropriate security. Some recipients, such as banks, advertising platforms or public authorities, may act as independent controllers for parts of their processing and will be responsible for their own legal obligations in that capacity.
AdWave does not make its client, prospect or contact databases available to unrelated third parties for those third parties to conduct their own independent direct marketing. Disclosures connected with the advertising services are made for service delivery, account operation, platform interaction, support, payment, security, compliance or another purpose described in this Policy or the applicable agreement.
11. International transfers of personal data
adskill works with international clients, advertising platforms and technology providers. Personal data may therefore be accessed from, hosted in or otherwise processed in countries outside the European Economic Area. A transfer outside the EEA is carried out only where a transfer basis or safeguard recognized by applicable data-protection law is available for the relevant circumstances.
Where the European Commission has adopted an adequacy decision for the destination, we may rely on that decision. For other transfers, appropriate safeguards may include the European Commission’s Standard Contractual Clauses or another legally recognized contractual mechanism. Where required, we assess the circumstances of the transfer and consider additional technical, contractual or organizational measures that may be appropriate to protect the information. Derogations available under Article 49 GDPR are used only where the conditions for the particular derogation are satisfied and the transfer is suitable for that mechanism.
The countries involved can differ depending on the advertising platform, infrastructure provider, client configuration and business system used for the service. A person may contact info@adskill.com to request information about the safeguards relevant to a transfer of that person’s personal data. We may provide the information in summarized form where necessary to protect confidential commercial information, security arrangements or the rights of another person.
12. Retention, deletion and anonymization
We do not keep personal data for a single uniform period. Retention is determined by the reason for which the information is held and by the legal, contractual and operational context. Relevant factors include the duration of a client or business relationship, the time needed to complete account administration or reconciliation, statutory accounting and tax duties, platform and payment records, limitation periods, security and fraud-prevention requirements, dispute or investigation needs and the need to demonstrate compliance with legal obligations.
Client and contractual records are generally kept for the life of the relevant relationship and for an appropriate period afterwards. Enquiry and prospective-client records are reviewed and removed when they are no longer reasonably connected with an active or realistically continuing business discussion, subject to any need to preserve correspondence for legal or compliance purposes. Marketing information is kept while the communication remains relevant and until an opt-out, withdrawal or other reason to stop the processing is recorded. Recruitment information is retained for the recruitment process and, where appropriate, for a limited period afterwards. Technical, security and support records are kept for periods proportionate to their operational and evidentiary purpose.
Personal data processed solely on behalf of a client is retained, returned or deleted in accordance with the applicable agreement, the client’s lawful instructions and any legal obligation that requires AdWave to keep particular information. When identifiable information is no longer needed, we delete it, securely dispose of it or anonymize it where appropriate. Information that has been effectively anonymized so that an individual is no longer identifiable may be used for statistical, operational or analytical purposes outside the scope of the GDPR, provided the anonymization is maintained.
13. Security and personal-data incidents
AdWave uses technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other forms of misuse. The measures applied are selected with regard to the nature of the information, the systems involved, the purpose of processing and the level of risk.
Depending on the relevant system and activity, safeguards can include role-based access restrictions, authentication controls, secure transmission, encryption where appropriate, logging and monitoring, backup and recovery arrangements, supplier reviews, confidentiality obligations, internal access procedures, security updates and incident-management processes. We review and adapt measures as systems, risks and business operations change. No internet service or technical environment can eliminate every risk, so security is managed as an ongoing process rather than as a guarantee of absolute protection.
If a personal-data incident occurs, we assess the nature and scope of the event, take reasonable steps to contain and remediate it, preserve relevant evidence and evaluate the risks to affected individuals. Where the GDPR or another applicable rule requires notification to a supervisory authority or communication to affected individuals, the required steps are taken within the applicable legal framework. Where an incident concerns data processed for a client, we also follow the incident-notification obligations contained in the relevant agreement.
14. Your rights, requests and complaints
Where the GDPR applies and its conditions are met, an individual may request confirmation as to whether AdWave processes personal data concerning that individual and may obtain access to the data and the information required by law. The individual may also request correction of inaccurate data, completion of incomplete data, deletion, restriction of processing or portability in the circumstances provided by the GDPR. A person may object to processing based on legitimate interests and has the right to object at any time to processing of personal data for direct-marketing purposes. Where processing is based on consent, consent can be withdrawn for future processing without affecting the lawfulness of processing carried out before withdrawal.
The GDPR also provides protections in relation to certain decisions based solely on automated processing, including profiling, where the decision produces legal effects or similarly significantly affects the individual. If processing carried out by AdWave falls within those rules, the rights and safeguards required by applicable law will apply. The existence of ordinary campaign optimization, platform analytics, fraud checks or technical automation does not by itself mean that an individual is subject to a decision falling within Article 22 GDPR; the legal assessment depends on the actual processing and its effect.
Requests can be sent to info@adskill.com. Please provide sufficient information for us to understand the request and identify the relevant relationship or record. We may request additional information where reasonably necessary to verify identity or authority and to protect personal data from unauthorized disclosure. Requests are handled within the time limits prescribed by applicable law. A right can be subject to statutory conditions or exceptions, including where information must be retained for a legal obligation, the protection of another person or the establishment, exercise or defence of legal claims.
Where the requested information is processed by AdWave solely on behalf of an advertiser client, the client will normally be responsible for determining the response to the data-subject request. In that situation, we may refer the request to the relevant client and provide the assistance required under the applicable agreement and law. Individuals also have the right to lodge a complaint with a competent supervisory authority. For processing for which AdWave LTD is the controller in Cyprus, the supervisory authority is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.
15. External services, policy changes and contact details
The adskill website and our communications may contain links to advertising platforms, social networks, messaging services, payment providers, partner websites or other third-party resources. When an individual chooses to use an independent third-party service, that provider may collect and use information under its own terms and privacy documentation. This Policy describes processing for which AdWave is responsible and does not replace the privacy information that an independent provider is required to give for its own processing.
We may update this Privacy Policy when our services, website, technology, business processes or legal obligations change. The current version will be published on adskill.com and will state the date of its latest revision. If a material change requires a separate notice, renewed consent or another action under applicable law, we will take the required step before the relevant change is relied upon for the affected processing.
Questions about this Policy, requests concerning personal data and privacy-related complaints can be sent to info@adskill.com. Written correspondence may be addressed to AdWave LTD at Eleftherias 113, 3042, Limassol, Cyprus. When contacting us about a privacy matter, please provide enough context for the request to be directed to the appropriate team without including unnecessary sensitive information.
AdWave LTD
Company Number: HE 380370
Eleftherias 113, 3042, Limassol, Cyprus
Brand: adskill
Website: https://adskill.com
Privacy Contact: info@adskill.com