This Privacy Policy (the “Policy”) explains how Digital Pro EOOD, a company duly incorporated and existing under the laws of Bulgaria, with its registered office at 24B Hadji Dimitar, Sofia, Bulgaria, operating under the brand D8ads (hereinafter referred to as “D8ads”, “we”, “us”, or “our”), processes personal data in connection with the operation of the D8ads affiliate marketing network and related services.
1. Role of D8ads in Data Processing
D8ads operates an affiliate marketing network providing technical, tracking, reporting, and related infrastructure services that facilitate performance-based advertising campaigns between advertisers and publishers. In the context of personal data processed through the D8ads network, D8ads acts solely as a data processor within the meaning of Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and processes personal data exclusively on behalf of and in accordance with the documented instructions of its advertising clients (the Advertisers), who act as the data controllers.
D8ads does not determine the purposes or essential means of processing personal data of end users who interact with Advertisers’ websites, applications, or dating platforms. All decisions relating to the collection of personal data, the identification of lawful bases for processing, the provision of privacy notices, the obtaining of valid consents, the definition of retention periods, and the exercise of data subject rights are made solely by the relevant Advertiser acting as data controller.
The processing activities performed by D8ads are strictly limited to what is necessary to provide affiliate network services, including tracking and attribution of Traffic, reporting and reconciliation of Campaign performance, fraud prevention and detection, technical troubleshooting, and maintenance of network security and integrity. D8ads does not process personal data for its own independent marketing, profiling, or commercial purposes and does not combine personal data processed on behalf of one Advertiser with data processed on behalf of another Advertiser, except where technically required to operate the network in accordance with documented instructions.
Nothing in this Privacy Policy shall be construed as creating a joint controllership relationship between D8ads and any Advertiser. Unless expressly agreed in a separate written data processing agreement, D8ads does not act as a data controller or joint controller in respect of personal data processed through the D8ads network.
2. Categories of Personal Data Processed
In the course of providing its affiliate network services, D8ads may process certain categories of personal data on behalf of Advertisers, strictly in accordance with their documented instructions and solely to the extent technically necessary for the operation of Campaigns, tracking, attribution, reporting, fraud prevention, and network security.
The categories of personal data processed by D8ads may include online identifiers and technical identifiers such as IP addresses, cookie identifiers, mobile advertising identifiers, device identifiers, and similar identifiers used for attribution and tracking purposes. D8ads may also process technical and usage data relating to user interactions with advertising materials, including timestamps, referral URLs, campaign identifiers, conversion or event identifiers, browser type, operating system, device characteristics, language settings, and other technical metadata generated in the course of user interaction with Campaigns.
Depending on the technical configuration of a Campaign and the information transmitted by the Advertiser, D8ads may process limited event-based or conversion-related data indicating that a specific action has occurred, such as a registration, subscription, purchase, or other predefined event. Such data is processed solely for attribution, reporting, and billing purposes and does not include the substantive content of user communications or profiles.
D8ads does not intentionally process special categories of personal data within the meaning of Article 9 GDPR, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, biometric data, or data concerning a natural person’s sex life or sexual orientation. To the extent that personal data processed by Advertisers in connection with dating or social discovery services may be considered sensitive by nature or context, D8ads processes such data only to the extent technically unavoidable for the provision of its services and strictly under the control and instructions of the relevant Advertiser.
D8ads does not require, request, or collect personal data such as names, email addresses, telephone numbers, payment details, or the content of messages exchanged between users of dating platforms, unless such data is incidentally included in tracking parameters by the Advertiser, in which case D8ads processes such data solely as instructed and without independent use.
The scope and categories of personal data processed may vary depending on the specific Campaign, tracking setup, and instructions provided by the Advertiser. Advertisers remain solely
3. Purposes of Processing
D8ads processes personal data solely for specific, explicit, and legitimate purposes strictly related to the provision and operation of the D8ads affiliate marketing network and in accordance with the documented instructions of the relevant Advertiser acting as data controller. Personal data is processed only to the extent necessary to enable the technical functioning of Campaigns and the performance of D8ads’ contractual obligations.
The purposes of processing include enabling and maintaining affiliate tracking and attribution, recording and validating Traffic and conversion events, generating performance reports, reconciling Campaign activity for billing and payment purposes, detecting and preventing fraud, abuse, and prohibited practices, ensuring the security, integrity, and stability of the D8ads network, and providing technical support and troubleshooting in connection with Campaign operations.
D8ads may also process personal data where necessary to comply with applicable legal obligations, respond to lawful requests from competent authorities, enforce contractual rights, investigate potential violations of the Terms, protect the legitimate interests of D8ads, Advertisers, and Publishers, and maintain audit trails and records required for compliance, accounting, or dispute resolution purposes.
D8ads does not process personal data for its own independent marketing, advertising, profiling, or behavioral targeting purposes and does not use personal data to make automated decisions producing legal or similarly significant effects on data subjects. Any profiling, targeting, or user segmentation activities relating to dating or social discovery services are determined and carried out solely by the relevant Advertiser acting as data controller.
Personal data processed by D8ads shall not be further processed in a manner that is incompatible with the purposes described in this Section. Any change in the purposes of processing shall require updated documented instructions from the relevant Advertiser and, where applicable, corresponding updates to this Privacy Policy or related data processing documentation.
4. Legal Basis for Processing
D8ads processes personal data solely as a data processor on behalf of Advertisers and strictly in accordance with their documented instructions. The identification, establishment, and documentation of a valid legal basis for the processing of personal data under applicable data protection laws, including Article 6 of the GDPR, is the sole responsibility of the relevant Advertiser acting as data controller.
Depending on the nature of the Dating Offer, the user interaction, and the applicable jurisdiction, the lawful bases relied upon by Advertisers may include, without limitation, the data subject’s consent, the necessity of processing for the performance of a contract to which the data subject is a party, compliance with a legal obligation, or the legitimate interests of the Advertiser, provided that such interests are not overridden by the rights and freedoms of the data subject. D8ads does not independently assess, determine, or validate the appropriateness of any legal basis relied upon by an Advertiser.
The Advertiser remains solely responsible for ensuring that all required information is provided to data subjects in accordance with applicable transparency obligations, that valid and freely given consent is obtained where required, that any consent mechanisms comply with applicable legal standards, and that records of consent or other lawful bases are maintained as required by law. D8ads shall not be responsible for any failure by an Advertiser to establish or document a valid legal basis for processing.
Where D8ads processes personal data based on the Advertiser’s instructions, the Advertiser warrants that such instructions are lawful and comply with applicable data protection and privacy laws. The Advertiser further warrants that the scope of personal data transmitted to D8ads is limited to what is necessary for the purposes communicated and that no excessive or unlawful data is provided.
D8ads shall not be required to process personal data in a manner that it reasonably believes would violate applicable data protection laws. In such cases, D8ads reserves the right to suspend or refuse the relevant processing activity until lawful instructions are provided by the Advertiser.
5. Cookies and Tracking Technologies
In the course of providing its affiliate network services, D8ads utilizes and enables the use of cookies, pixels, postback URLs, SDKs, server-to-server integrations, and other similar tracking and attribution technologies (collectively, “Tracking Technologies”) strictly for the purpose of enabling campaign attribution, performance measurement, fraud prevention, reporting, and network security.
Tracking Technologies implemented through the D8ads network are deployed on behalf of and in accordance with the documented instructions of Advertisers acting as data controllers. D8ads does not independently determine whether or how Tracking Technologies are placed on end-user devices and does not control the design, configuration, or operation of cookie consent mechanisms, banners, or preference management tools implemented by Advertisers on their websites, applications, or platforms.
The responsibility for ensuring that the use of cookies and other Tracking Technologies complies with applicable laws and regulations, including the GDPR, the ePrivacy Directive, and any national implementing legislation, rests solely with the relevant Advertiser. This includes, without limitation, the obligation to provide clear and comprehensive information to end users regarding the use of cookies and Tracking Technologies, to obtain valid consent where required, to allow users to manage their preferences, and to honor withdrawals of consent.
D8ads processes data collected through Tracking Technologies solely as a data processor and only to the extent necessary to perform tracking, attribution, reporting, fraud detection, and related technical functions. D8ads does not use Tracking Technologies for its own independent marketing, profiling, behavioral advertising, or analytics purposes and does not place cookies or similar identifiers on end-user devices for its own standalone purposes.
Depending on the technical configuration of a Campaign, Tracking Technologies may collect or transmit online identifiers and technical information such as cookie identifiers, mobile advertising identifiers, IP addresses, timestamps, referral data, and event or conversion identifiers. D8ads does not access or process the substantive content of communications, user profiles, or payment information through Tracking Technologies.
End users seeking information about or control over the use of cookies and Tracking Technologies are advised to review the privacy and cookie notices of the relevant Advertiser, as such notices describe the specific Tracking Technologies used, their purposes, retention periods, and available user choices. D8ads does not maintain a separate end-user-facing cookie management interface and does not respond directly to cookie preference requests, except to the extent required to support Advertisers in complying with their legal obligations.
Where required by applicable law or regulatory guidance, D8ads may assist Advertisers, upon request and to the extent technically feasible, in implementing or modifying Tracking Technologies to support compliance with consent, opt-out, or other legal requirements. Such assistance does not alter the allocation of responsibilities set forth in this Policy.
6. Data Sharing and Disclosure
In the course of providing its affiliate network services, D8ads may disclose or make available personal data processed on behalf of Advertisers to third parties strictly to the extent necessary to perform its contractual obligations and in accordance with the documented instructions of the relevant Advertiser acting as data controller.
Such disclosures may include the sharing of personal data with Advertisers for the purposes of attribution, reporting, billing, and Campaign performance analysis, as well as with Publishers to the extent technically required to enable tracking, attribution, and reconciliation of Campaign activity. D8ads may also disclose personal data to its hosting providers, cloud infrastructure providers, analytics and fraud prevention service providers, and other subprocessors engaged to support the operation, security, and integrity of the D8ads network, provided that such disclosures are limited to what is necessary and subject to appropriate contractual safeguards.
D8ads does not disclose personal data to third parties for its own independent marketing, advertising, or commercial purposes and does not sell personal data. Any sharing of personal data for purposes beyond the provision of affiliate network services requires the explicit instruction and authorization of the relevant Advertiser.
Where required by applicable law, regulation, court order, or binding request from a competent authority, D8ads may disclose personal data to public authorities, regulators, courts, or law enforcement bodies. In such cases, D8ads shall, where legally permitted, notify the relevant Advertiser of such request and cooperate reasonably to limit the scope of disclosure and to seek protective measures, such as confidentiality or sealing orders.
D8ads may also disclose personal data where necessary to investigate, prevent, or take action in relation to suspected fraud, prohibited practices, security incidents, violations of the Terms, or other activities that may expose D8ads, Advertisers, or Publishers to legal, regulatory, or reputational risk. Such disclosures shall be limited to what is reasonably necessary for such purposes and shall be carried out in accordance with applicable law.
D8ads ensures that any third party to whom personal data is disclosed or made available as part of its services is bound by contractual obligations that provide an appropriate level of data protection, confidentiality, and security, consistent with applicable data protection laws and this Privacy Policy.
7. International Data Transfers
In the course of providing its affiliate network services, D8ads may process and transfer personal data on behalf of Advertisers to recipients located in jurisdictions outside the European Economic Area (“EEA”), including where such transfers are necessary for the operation, hosting, maintenance, security, monitoring, fraud prevention, or technical support of the D8ads network. Any such international data transfers are carried out solely in accordance with the documented instructions of the relevant Advertiser acting as data controller and in compliance with applicable data protection laws.
Where personal data is transferred outside the EEA to a country that has not been recognized by the European Commission as providing an adequate level of data protection, D8ads ensures that appropriate safeguards are implemented in accordance with Chapter V of the GDPR. Such safeguards may include the use of standard contractual clauses adopted by the European Commission, or other lawful transfer mechanisms recognized under applicable data protection law. D8ads does not rely on derogations for occasional transfers unless expressly instructed by the Advertiser and permitted by law.
The Advertiser acknowledges and agrees that it remains solely responsible for assessing the lawfulness of international data transfers in the context of its Campaigns, including the identification of appropriate transfer mechanisms, the assessment of third-country laws where required, and the provision of any required disclosures to data subjects. D8ads does not independently assess the adequacy of data protection regimes in third countries and does not assume responsibility for the Advertiser’s transfer impact assessments or equivalent evaluations.
D8ads undertakes to implement reasonable technical and organizational measures designed to protect personal data transferred internationally against unauthorized access, disclosure, or misuse, consistent with its role as a data processor. Any subprocessors engaged by D8ads that are located outside the EEA shall be subject to contractual obligations ensuring an appropriate level of data protection and confidentiality in accordance with applicable law.
Where required by applicable law or requested by the Advertiser, D8ads shall provide reasonable information regarding the safeguards applied to international data transfers, subject to confidentiality and security considerations.
8. Data Retention
D8ads processes and retains personal data solely for as long as necessary to perform its obligations as a data processor and strictly in accordance with the documented instructions of the relevant Advertiser acting as data controller. D8ads does not independently determine retention periods for personal data and does not retain personal data for longer than is required for the purposes of providing affiliate network services, unless retention is required by applicable law or expressly instructed by the Advertiser.
The retention periods applicable to personal data processed through the D8ads network are determined by the relevant Advertiser based on the nature of the Dating Offer, the purposes of processing, applicable legal and regulatory requirements, and the disclosures made to data subjects. The Advertiser remains solely responsible for defining lawful retention periods, communicating such periods in its privacy notices, and ensuring that personal data is not retained longer than permitted under applicable data protection laws.
D8ads may retain certain personal data, including technical logs, transaction records, and audit trails, for limited periods where such retention is necessary to comply with legal obligations, resolve disputes, enforce contractual rights, prevent fraud, ensure network security, or comply with accounting, tax, or regulatory requirements. In such cases, retention shall be limited to what is strictly necessary and proportionate for the relevant purpose and shall be subject to appropriate security and access controls.
Upon termination of a Campaign or the contractual relationship with an Advertiser, or upon receipt of documented instructions from the Advertiser, D8ads shall, within a reasonable timeframe and subject to applicable legal obligations, delete or anonymize personal data processed on behalf of the Advertiser or return such data to the Advertiser, as instructed. Any personal data retained for compliance, legal, or legitimate business purposes shall remain subject to the confidentiality and security obligations set out in this Privacy Policy.
D8ads does not retain personal data for its own independent purposes and does not use retained data to create profiles, analytics, or insights unrelated to the provision of services to Advertisers.
9. Data Security
D8ads implements and maintains appropriate technical and organizational measures designed to ensure a level of security appropriate to the risk associated with the processing of personal data, taking into account the nature, scope, context, and purposes of processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons. Such measures are intended to protect personal data processed on behalf of Advertisers against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
As a data processor, D8ads processes personal data solely in accordance with the documented instructions of Advertisers and restricts access to personal data to authorized personnel and subprocessors who have a legitimate need to access such data for the performance of their duties and who are subject to confidentiality obligations consistent with applicable data protection laws.
D8ads’ security measures are designed to include, as appropriate, access controls, logical and physical security safeguards, monitoring and logging mechanisms, incident detection and response procedures, and measures intended to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services. D8ads may update, enhance, or modify its security measures from time to time in response to evolving security risks, technological developments, or legal and regulatory requirements.
In the event of a personal data breach affecting personal data processed on behalf of an Advertiser, D8ads shall notify the relevant Advertiser without undue delay after becoming aware of the breach, to the extent required by applicable data protection laws. Such notification shall include information reasonably necessary to enable the Advertiser to assess the breach and comply with its own legal obligations, including notification obligations toward supervisory authorities or data subjects, where applicable. D8ads shall cooperate reasonably with the Advertiser in connection with the investigation and remediation of any such breach.
The Advertiser acknowledges that no security measures can guarantee absolute protection and agrees that D8ads does not warrant or guarantee that personal data will be immune from unauthorized access, disclosure, or misuse. The Advertiser remains responsible for implementing appropriate security measures within its own systems, platforms, and environments and for ensuring that its instructions to D8ads do not require processing in a manner that would compromise data security.
10. Data Subject Rights
Under applicable data protection laws, including the GDPR, data subjects may have certain rights in relation to the processing of their personal data, including rights of access, rectification, erasure, restriction of processing, objection, and data portability. The responsibility for enabling, assessing, and responding to any such requests rests solely with the relevant Advertiser acting as data controller.
As a data processor, D8ads does not independently determine the purposes or means of processing personal data and does not make substantive decisions regarding the exercise of data subject rights. Accordingly, data subjects are instructed to direct any requests relating to their personal data, including requests to exercise their rights, to the relevant Advertiser whose website, application, or dating platform they interacted with.
Where D8ads receives a data subject request directly, D8ads shall not respond to such request on its own behalf unless required by applicable law. Instead, D8ads shall, where legally permitted and practicable, promptly forward the request to the relevant Advertiser and provide reasonable assistance to enable the Advertiser to respond to the request in accordance with applicable data protection laws. Any such assistance shall be limited to what is technically feasible and consistent with D8ads’ role as a data processor.
The Advertiser remains solely responsible for verifying the identity of data subjects, assessing the validity and scope of requests, determining applicable exemptions or limitations, responding within statutory deadlines, and maintaining records of data subject requests and responses. D8ads shall not be liable for any failure by an Advertiser to comply with its obligations relating to data subject rights.
D8ads may refuse to act on instructions from an Advertiser that would require D8ads to process personal data in a manner that violates applicable data protection laws or infringes the rights of data subjects. In such cases, D8ads shall inform the Advertiser of the issue without undue delay.
11. Children’s Data
The D8ads affiliate network is intended exclusively for adult-oriented advertising and is not designed for use by, or targeting of, children or minors. D8ads does not knowingly process personal data relating to individuals under the age of eighteen (18) or under the applicable age of majority in the relevant jurisdiction, whichever is higher.
Advertisers operating dating, social discovery, or relationship-oriented services are solely responsible for ensuring that their websites, applications, platforms, and Campaigns are directed exclusively at adult users and that appropriate age-gating, age-verification, and access control mechanisms are implemented in accordance with applicable laws and regulatory requirements. The Advertiser remains solely responsible for preventing minors from accessing, interacting with, or providing personal data through its services and for ensuring that all required disclosures and safeguards are in place.
As a data processor, D8ads processes personal data strictly on the documented instructions of Advertisers and does not independently verify the age of end users or determine eligibility criteria for access to Advertisers’ services. D8ads shall not be liable for any failure by an Advertiser to implement or enforce appropriate age restrictions or for any unlawful processing of children’s data resulting from the Advertiser’s actions or omissions.
Where D8ads becomes aware that personal data relating to a child or minor may have been processed in connection with a Campaign in violation of applicable laws or these Terms, D8ads reserves the right to take appropriate remedial measures, including notifying the relevant Advertiser, suspending or terminating the affected Campaign, and deleting or restricting access to the relevant data, to the extent required or permitted by applicable law.
Advertisers remain solely responsible for complying with all applicable laws relating to the processing of children’s data, including enhanced consent requirements, parental consent obligations, and restrictions applicable to dating or adult-oriented services. Any processing of children’s data in connection with Campaigns operated through the D8ads network shall constitute a material breach of the applicable terms and may result in suspension or termination of the relationship.
12. Changes to This Privacy Policy
D8ads reserves the right to amend, update, or otherwise modify this Privacy Policy from time to time in order to reflect changes in applicable laws or regulatory requirements, guidance from supervisory authorities, developments in industry practices, technological changes, or modifications to the operation of the D8ads affiliate network.
Any updated version of this Privacy Policy shall become effective upon publication on the D8ads website. The date of the most recent update shall be indicated at the top of this Privacy Policy.
The Advertiser remains responsible for reviewing this Privacy Policy on a regular basis and for ensuring that its own privacy notices, disclosures, and data protection practices remain consistent with applicable law and with the current version of this Privacy Policy. Continued use of the D8ads network or continued participation in Campaigns following the effective date of any changes to this Privacy Policy shall constitute acknowledgment of the updated Policy.
Nothing in this Section shall be construed as limiting the Advertiser’s obligations as a data controller or expanding the role or responsibilities of D8ads beyond those expressly set out in this Privacy Policy and the applicable contractual arrangements between the Parties.
13. Contact Information
For any questions, inquiries, or requests relating to this Privacy Policy or the processing of personal data in connection with the D8ads affiliate network, Advertisers, Publishers, or other parties may contact D8ads using the details set out below.
Digital Pro EOOD d/b/a D8ads
Registered address: 24B Hadji Dimitar, Sofia, Bulgaria
Email: privacy@d8ads.com(or such other contact details as may be designated and published by D8ads from time to time).
D8ads processes personal data solely in its capacity as a data processor and does not act as a data controller in relation to end-user data. Accordingly, data subjects seeking to exercise their rights under applicable data protection laws should direct their requests to the relevant Advertiser acting as data controller. Where D8ads receives a request directly, it may forward such request to the relevant Advertiser in accordance with applicable law and its contractual obligations.