Privacy Policy (PPCJuice)

1) Who this Policy applies to

This Policy applies to:

• Website visitors
• People who contact us (sales, support, partnerships)
• Clients and authorised client users (e.g., people who share access to ad accounts/analytics)
• Affiliate partners and applicants (where applicable)

Our Services are intended for business/professional users and are not directed to children.

2) Controller vs. Processor roles (important)

2.1 When we are a controller

We act as a data controller for personal data relating to:

• Website and cookie data (where applicable)
• Contact forms, enquiries, and sales conversations
• Contracting, billing, and account administration
• Security, fraud prevention, and abuse prevention
• Marketing communications and preferences

2.2 When we are a processor

When providing marketing services, we may process data inside your systems (e.g., Google Ads, Microsoft Advertising, GA4, tag managers, CRM exports) on your instructions. In that context:

• You are the controller of that data; and
• We act as a processor to deliver the Services.

If you need a Data Processing Agreement (DPA), download it here.

3) Personal data we collect

We collect different categories of data depending on your interaction with us.

3.1 Data you provide directly

• Contact details: name, email, company, role/title, phone (if provided)
• Enquiry content: information you send via forms, email, or calls (including budgets, markets, goals, problems)
• Contracting/billing details: business name, address, VAT number (if provided), invoicing contact details
• Affiliate partnership applications (if applicable): company/team details, offer/deal information, payout preferences or related commercial details (as provided)

3.2 Data we may process when delivering Services (client data)

Depending on access you grant, we may process:

• Ad account data (campaigns, keywords/search terms, ads, bids, budgets, audiences)
• Performance and conversion data (clicks, conversions, conversion values, cost, ROAS, CPA/FTD signals)
• Analytics data (e.g., GA4 events, attribution settings, landing page performance)
• Technical measurement data (tagging, pixels, tracking parameters, server-side tagging configurations)
• Limited identifiers in logs or tracking (e.g., click IDs) where present in your systems

Important: We do not need or request player names, emails, or sensitive personal data to run PPC. If you provide or expose personal data to us inside your systems, you confirm you have the right to do so and that it is necessary for the Services.

3.3 Automatically collected website/technical data

When you visit our site we may collect:

• IP address and approximate location derived from IP
• Device/browser type, OS, language
• Pages viewed, referral source, timestamps, diagnostic logs
• Cookie identifiers or similar technologies (see Section 9)

3.4 Data from third parties

We may receive limited data from:

• Payment providers (payment status and transaction metadata)
• Analytics providers (aggregated website performance)
• Scheduling/communication tools (delivery status, meeting confirmations)

4) How we use personal data

We use personal data to:

4.1 Provide and operate our website and Services

• Respond to enquiries and provide support
• Evaluate fit for audits/consulting/growth engagements or affiliate partnerships
• Deliver contracted marketing services (where you provide access/instructions)
• Manage billing, invoices, and contracts

4.2 Improve and secure our operations

• Maintain website performance and reliability
• Prevent fraud, spam, abuse, and unauthorised access
• Maintain logs for security and troubleshooting

4.3 Communications

• Send service communications (e.g., replies, scheduling, operational updates)
• Send marketing communications where permitted by law or with consent (you can opt out anytime)

4.4 Legal and compliance

• Meet legal obligations (tax/accounting)
• Enforce agreements and protect our rights

5) Legal bases for processing (GDPR / UK GDPR)

Where GDPR/UK GDPR applies, we rely on:

• Contract: to perform Services and manage client relationships
• Legitimate interests: to run and improve our business, secure our systems, and communicate with businesses
• Consent: for non-essential cookies and certain marketing where required
• Legal obligation: accounting/tax and lawful requests

You can withdraw consent at any time (this does not affect prior lawful processing).

6) How we share personal data

We do not sell personal data.

We may share data with:

6.1 Service providers (sub-processors)

Trusted providers for hosting, analytics, email delivery, CRM/helpdesk, invoicing, and security. They may process personal data only as necessary to provide services to us and are bound by confidentiality and data protection obligations.

6.2 Platforms and tools you use (as part of Services)

If you authorise access, data may be processed within or shared through third-party platforms such as Google Ads, Microsoft Advertising, Google Analytics, tag management tools, call tracking tools, or other vendors you choose. Their use of data is governed by their own policies and your agreements with them.

6.3 Legal requirements and protection

We may disclose data if required by law or to protect rights, safety, and security (e.g., fraud prevention, legal claims).

6.4 Business transfers

If we are involved in a merger, acquisition, or sale of assets, data may be transferred as part of that transaction subject to appropriate safeguards.

7) International transfers

We are based in Malta (EU). Some service providers may process data outside the EEA/UK. Where required, we use appropriate safeguards such as:

• European Commission Standard Contractual Clauses (SCCs)
• Other lawful transfer mechanisms recognised under GDPR/UK GDPR

8) Data retention

We retain personal data only as long as necessary for the purposes described, including:

• Enquiries: retained as needed to respond and maintain business records
• Client data in our systems: retained for the duration of the engagement and a reasonable period thereafter for auditability, billing, and dispute resolution
• Invoices/accounting: retained for legally required periods
• Security logs: retained for a limited period for security and troubleshooting

When acting as a processor, retention is generally controlled by your instructions and the systems you use.

9) Cookies and tracking technologies

We may use cookies and similar technologies for:

• Strictly necessary functions (security, site functionality)
• Analytics (understanding performance and improving the site)
• Preferences (remembering settings)
• Marketing (if used) to measure effectiveness and attribution

Where required, we provide a cookie banner or consent mechanism for non-essential cookies. You can also control cookies through your browser settings.

10) Security

We implement appropriate technical and organisational measures to protect data, which may include:

• HTTPS/TLS encryption in transit
• Access controls and least-privilege permissions
• Internal confidentiality controls
• Monitoring and logging

No system is 100% secure. You are responsible for keeping credentials secure and limiting access to authorised users.

11) Children's privacy

Our services are not intended for individuals under 18 and we do not knowingly collect personal data from children. If you believe a child has provided data to us, contact us and we will take steps to delete it.

12) Your rights (GDPR/EEA/UK and similar jurisdictions)

Depending on your location, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Request deletion (where applicable)
• Restrict or object to processing (where applicable)
• Data portability (where applicable)
• Withdraw consent (where processing is based on consent)
• Lodge a complaint with a supervisory authority

To exercise rights, contact alexander@ppcjuice.com. We may request identity verification.

13) Supervisory authority (Malta)

Office of the Information and Data Protection Commissioner (IDPC)

Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta

Email: idpc.info@idpc.org.mt | Phone: +356 2328 7100

Website: https://idpc.org.mt/

14) Third-party links

Our website may link to third-party websites and platforms. We are not responsible for their privacy practices. Review their policies before providing personal data.

15) Changes to this Policy

We may update this Policy from time to time. We will post updates on this page and change the "Last updated" date. Material changes may be communicated via email or site notice.

16) Contact

Legal entity: OmniPro LTD (C 106467)

Registered address: Triq La Sengle 2, Marsaskala MSK 1202, Malta

Email: alexander@ppcjuice.com