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Privacy Policy — Euro Cabinet Service

Version v1.0 — Last updated 2026-04-26

This Privacy Policy describes how [OPERATOR_LEGAL_NAME] (operator of ADSLY.pro, hereinafter “ADSLY”) collects, uses, stores, and discloses personal data in the context of the Euro-cabinet self-service ordering service. It complements the Terms of Service.

1. Who We Are

Data Controller: [OPERATOR_LEGAL_NAME], registered in [JURISDICTION].

Contact for privacy matters: hello@adsly.pro (subject: “Privacy” or “DPO”).

2. Data We Collect

For the Euro-cabinet service, we collect the minimum data required to deliver the service. We do NOT request KYC documents, government IDs, proof of address, or business registration documents from the Client.

2.1. Provided by you

• Telegram contact (username or handle) — for support, credential delivery, and service notifications;
• Advertised URL or Telegram resource — for niche verification and cabinet setup;
• Declared niche category and short description of advertised content — for tier-pricing and compliance review;
• Target geo — for cabinet configuration;
• Email address (optional) — if you choose to provide one for receipts.

2.2. Collected automatically

• Payment metadata: USDT-TRC20 wallet address used for payment, transaction hash, on-chain confirmation timestamp, paid amount;
• Technical logs: IP address, user-agent, browser fingerprint, timestamps, referrer URL — for fraud prevention and security auditing;
• Cookies: essential session cookies and analytics cookies (see §8).

3. Purposes of Processing

1. Service delivery — opening the cabinet, configuring it, transferring access to the Client;
2. Niche verification & compliance — AI-based and manual review against Telegram Ads policy and our internal compliance list;
3. Payment processing — verifying USDT-TRC20 transactions and matching them to invoices;
4. Fraud prevention — detecting abuse, multi-account fraud, sanctioned-entity attempts;
5. Legal compliance — tax, accounting, anti-money-laundering obligations applicable to ADSLY in [JURISDICTION];
6. Internal analytics — service improvement, conversion-funnel analysis, capacity planning;
7. Support communication — responding to questions, resolving issues.

4. Legal Basis (GDPR Art. 6)

• Performance of a contract (Art. 6(1)(b)) — for service delivery, payment processing, and credential transfer;
• Legitimate interest (Art. 6(1)(f)) — for fraud prevention, security, and aggregated analytics;
• Legal obligation (Art. 6(1)(c)) — for tax records and AML retention;
• Consent (Art. 6(1)(a)) — for non-essential analytics cookies and any optional marketing communications.

5. Sharing of Data

We do not sell or rent personal data. We share data only with:

• Heleket (or our then-current crypto-payment processor) — for processing USDT-TRC20 invoices. Heleket processes wallet-address and transaction data under its own privacy policy;
• Telegram Ads platform (ads.telegram.org) — data needed to register and operate the cabinet (advertised URL, geo settings, campaign content) flows to Telegram’s systems by virtue of how the platform works;
• EU-based hosting and infrastructure providers — under data-processing agreements;
• Tax and accounting auditors — only data legally required for compliance;
• Competent authorities — only when legally compelled by valid court order or regulator request.

We do not share data for third-party marketing.

6. Retention

• Order & invoice records: 5 (five) years after the order, for accounting and tax purposes;
• Cabinet access tokens / credentials: while the cabinet is active, plus 1 (one) year after deactivation, for support continuity;
• Technical logs (IP, user-agent): typically 12 months, longer if needed for an active fraud investigation;
• Support correspondence: up to 3 years from the last message;
• Aggregated analytics: indefinitely in anonymised form (no personal data).

7. Your Rights (GDPR Chapter III)

If you are in the EU/EEA, the UK, or a comparable jurisdiction, you have the right to:

• Access your personal data;
• Rectify inaccurate data;
• Erase data (“right to be forgotten”), subject to our legal-retention obligations;
• Restrict or object to processing based on legitimate interest;
• Portability — receive your data in a machine-readable format;
• Withdraw consent at any time, where consent is the legal basis;
• Lodge a complaint with your local data-protection authority.

Residents of California (CCPA/CPRA) have parallel rights to know, delete, correct, and opt out of “sale” (we do not sell personal data).

To exercise any right, write to hello@adsly.pro. We respond within 30 days.

8. Cookies

We use:

• Essential cookies: session identifiers required for the order form and authenticated panel access (cannot be disabled);
• Analytics cookies: internal funnel-tracking (own analytics stack, not Google Analytics or PostHog) and Yandex Metrica for anonymised traffic insights. You may opt out via your browser settings.

9. International Transfers

Primary processing takes place within the European Union. Where any sub-processor is located outside the EU/EEA, ADSLY relies on the European Commission’s Standard Contractual Clauses (SCCs) or an adequacy decision to ensure equivalent protection.

10. Security

We apply technical and organisational measures appropriate to the risk:

• TLS encryption for all traffic to ADSLY.pro;
• Parameterised SQL queries for all database operations — no string concatenation;
• No plain-text storage of payment-secret data; on-chain transaction hashes only;
• Cabinet credentials stored encrypted at rest;
• Logical isolation of the EU operating entity from other ADSLY systems;
• Access on a need-to-know basis, with audit logs.

11. Children

The service is intended for users aged 18 and older. We do not knowingly collect data from minors. If we discover such data, we delete it.

12. Changes to this Policy

We may update this Privacy Policy. Material changes are notified to active customers via the ADSLY.pro panel and, where an email address is provided, by email. The “Last updated” date at the top of this page reflects the current version.

13. Contact

• Privacy / DPO inquiries: hello@adsly.pro (subject: “Privacy”)
• Telegram channel: @adsly_pro
• Telegram support bot: @adslypro_bot
• Website: https://adsly.pro