Privacy Policy

Kroc Ads (“Kroc Ads”, “we”, “us”, “our”) respects your privacy and is committed to being transparent about how we collect, use, and protect personal data.

This Privacy Policy explains what data we collect, why we collect it, and what rights you have, in connection with our website krocads.com (the “Website”) and the advertising Services offered through it (together, the “Services”). Personal data is processed in line with generally applicable data protection principles, including those of the EU General Data Protection Regulation (“GDPR”) where relevant, regardless of where Kroc Ads is ultimately incorporated.

Please read this Policy carefully. For details on the cookies and similar technologies we use, see our Cookie Policy.

Categories of Data Subjects

This Policy addresses three categories of people whose data we may process:

• a. Advertisers — individuals or legal entities who register an account with Kroc Ads to run Campaigns or place Marketplace orders.
• b. Ad Viewers — people who see ads delivered by Kroc Ads on the websites of publishers in our delivery network. Kroc Ads does not have a direct relationship or account system with these individuals.
• c. Site Visitors — people who browse krocads.com without registering an account (e.g. to read about our Services or contact us).

The information relevant to each category is set out in Sections 1–3 below. Provisions that apply to all three categories are in Section 4.

Table of contents

1. Advertisers
2. Ad Viewers
3. Site Visitors
4. General Provisions
5. Contact
6. Changes to This Policy

1. Advertisers

1.1 What data we collect

To provide the Services to registered Advertisers, we collect:

• Account data: your email address, and — if you choose to provide it — your Telegram handle. Providing a Telegram handle is always optional.
• Authentication data: sign-in to Kroc Ads is handled by our authentication provider, Supabase Auth, via email/password or Google sign-in. Kroc Ads does not receive, process, or store your password — it is managed entirely within Supabase’s authentication system. If you sign in with Google, we receive only the basic profile information Google shares with us (typically your name, email address, and profile picture).
• Billing & transaction data: the cryptocurrency wallet address(es) you use to deposit funds (USDT TRC-20/ERC-20, BTC, ETH), transaction hashes, deposit amounts, and your resulting USD-equivalent account balance. We do not collect bank account details, payment card data, or government ID documents — Kroc Ads does not perform identity verification (KYC).
• Campaign & order data: the settings, targeting parameters, creative assets, landing pages, and other content you submit for Campaigns or Marketplace orders.
• Communications data: messages you send us via email, our support channels, or Telegram (if you’ve shared your handle), and your marketing communication preferences.
• Technical & usage data: IP address, browser type and version, device/operating system information, log-in history, and general usage data collected via cookies — see our Cookie Policy for details.

We do not knowingly collect sensitive personal data (e.g. health, biometric, or religious information) from Advertisers, and we ask that you do not include such data in any content or communications you send us.

1.2 How we use it

We use Advertiser data to:

• provide and operate the Services, including running your Campaigns and fulfilling Marketplace orders (legal basis: performance of a contract);
• process deposits, maintain your account balance, and keep accounting records (legal basis: contract performance and legal obligation);
• secure your account and investigate suspected fraud or abuse (legal basis: legitimate interest);
• respond to support requests and communicate with you about your account (legal basis: legitimate interest / contract performance);
• send you marketing emails and newsletters, only if you’ve opted in — you can withdraw this consent at any time (legal basis: consent);
• comply with applicable laws, including tax and accounting obligations (legal basis: legal obligation);
• analyze and improve our Services using aggregated or de-identified data (legal basis: legitimate interest).

1.3 Who we share it with

We may disclose Advertiser data to:

• Infrastructure & processors: Supabase (authentication and database hosting), our email delivery provider (for transactional and, where opted in, marketing emails), and Google Analytics (Website analytics).
• Our publisher/delivery network: only the campaign creative content and technical delivery parameters necessary to serve your ads (e.g. banner assets, target URL) — we do not share your account, billing, or identity information with publishers.
• Legal & compliance: where required to comply with a legal obligation, court order, or lawful request from a competent authority.
• Business transfers: if Kroc Ads is incorporated, restructured, acquired, or its assets are transferred, your data may be transferred as part of that transaction, subject to this Policy (or its successor).

We do not sell Advertiser personal data to third parties.

1.4 How long we keep it

• Campaign and Marketplace order data is retained for up to 1 year, consistent with our Terms & Conditions, after which it is deleted.
• Account data is retained for as long as your account is active, plus a reasonable period afterward to meet accounting, tax, and legal obligations (generally up to 7 years for financial/transaction records, in line with common accounting-retention practice).
• If your account is deleted or closed, we will delete or anonymize your personal data within a reasonable time, except where we’re required or entitled to retain it (e.g. for dispute resolution, fraud prevention, or legal compliance).

Note on blockchain data: deposits and transactions made via public blockchains (BTC, ETH, USDT on TRC-20/ERC-20) are recorded on public, immutable ledgers that Kroc Ads does not control. Wallet addresses and transaction records on these networks may remain publicly visible indefinitely and cannot be deleted or altered by us, regardless of any request made under this Policy.

2. Ad Viewers

This section applies to people who view ads served by Kroc Ads on the websites of publishers in our delivery network, and who do not have a Kroc Ads account.

2.1 What data we collect

We collect only what’s needed for basic ad delivery and performance measurement — we do not build cross-site behavioral or interest-based advertising profiles. This includes:

• IP address (used to determine general/approximate location, e.g. country or city, and for fraud/bot detection);
• device and browser type;
• the timestamp of an ad impression or click;
• the referring page and, where applicable, a session-based cookie identifier used to prevent duplicate counting of impressions/clicks.

2.2 How we use it

• To deliver ads and measure impressions, clicks, and campaign performance;
• To generate aggregated performance reports for Advertisers (e.g. click-through rate, geographic breakdown) — these reports do not identify individual Ad Viewers;
• To detect and prevent invalid, bot, or fraudulent traffic.

2.3 Who we share it with

Aggregated, non-identifying performance data may be shared with the Advertiser whose Campaign was served, and with analytics providers (e.g. Google Analytics) who help us measure delivery performance.

2.4 Retention

Ad delivery and performance data is retained for up to 1 year, after which it is deleted or aggregated in a way that no longer identifies an individual.

3. Site Visitors

This section applies to people who visit krocads.com without creating an account.

3.1 What data we collect

• Information you submit voluntarily, e.g. via a contact form or email inquiry (such as your name, email, and message content);
• Technical and cookie data: IP address, browser/device information, pages visited, referring page, and access times — see our Cookie Policy for details.

3.2 How we use it

• To respond to your inquiries (legal basis: legitimate interest / steps prior to entering a contract);
• To understand and improve how the Website is used, via Google Analytics (legal basis: consent, where required by applicable cookie law);
• To send you marketing materials, only if you’ve opted in (legal basis: consent).

3.3 Who we share it with

Google Analytics and our email provider, as described above, and any party required by law.

3.4 Retention

We retain Site Visitor inquiry data only as long as needed to address your inquiry and keep a reasonable record of it, and analytics data per the retention settings described in our Cookie Policy.

4. General Provisions

4.1 Security

We apply reasonable technical and organizational measures to protect the data we hold from loss, misuse, unauthorized access, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

4.2 International data transfers

Our infrastructure providers (including Supabase and our other processors listed above) may process data in countries other than your own, including outside the European Economic Area. Where this happens, we rely on the safeguards our providers have in place (such as standard contractual clauses or equivalent mechanisms) to protect your data consistently with this Policy.

4.3 Children

Kroc Ads’ Services are not directed at, and we do not knowingly collect data from, individuals under the age of 18, consistent with the eligibility requirements in our Terms & Conditions.

4.4 Your rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase your data, subject to our legal/accounting retention obligations and the blockchain limitation noted in Section 1.4;
• Restrict or object to certain processing, including marketing (you can also unsubscribe directly via any marketing email);
• Port your data to another provider, where technically feasible;
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, contact us at privacy@krocads.com. We may ask for information to verify your identity before actioning a request. We aim to respond within 30 days; complex requests may take longer, in which case we’ll let you know.

4.5 Cookies

We use cookies and similar technologies for essential site functionality, basic analytics, and ad-delivery/performance tracking as described in Sections 2 and 3 above. For full details on the cookies we use and how to manage your preferences, see our Cookie Policy.

5. Contact

Questions about this Privacy Policy or your personal data can be sent to:

Email: privacy@krocads.com

Kroc Ads is not yet incorporated as a legal entity; a registered business address and, where legally required, a designated Data Protection Officer, will be added to this Policy once incorporation is complete.

6. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be published on the Website, and if a change materially affects how we handle your data, we will make reasonable efforts to notify you in advance (e.g. by email or a notice on the Website). Continuing to use the Website or Services after an update takes effect constitutes acceptance of the revised Policy.