LTD Net Socium (Georgia),(referred to as “Net Socium” or “we” or “us” or “our”) is committed to protecting and respecting your privacy and  handling your personal data in an open and transparent manner. The personal data that we collect and process may vary depending on the  service we provide to you.

This privacy policy:

provides an overview of how Net Socium collects and processes your personal data, and informs you about your rights under the EU  General Data Protection Regulation (“GDPR”) and any national law supplementing or implementing the GDPR, Contains important information about, among others, the collection and use of personal data; the legal grounds for the processing of  that data; disclosures of that personal data to third parties and the use of cookies on the Website.

For the purposes of this privacy policy:

when we refer to “personal data” we mean data which identifies or may identify you and which may include, for example, your name,  address, identification number, telephone number, date of birth, occupation and family status,

when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your  personal data, and

when we refer to our “Website” or our “Platform” we mean 

Who we are

LTD Net Socium is a company registered in Georgia, under registration number 402133767 as a limited liability company having its registered  office at Tsereteli ave.87 a bild 2 fl 19, Tbilisi, 0119, Georgia.

Our Data Protection Principles

We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:


Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).


Collected only for specified, explicit and legitimate purposes (Purpose Limitation).


Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation). 4.  

Accurate and where necessary kept up to date (Accuracy).


Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is  Processed (Storage Limitation).


Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised  or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality). 7.  

Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).


Made available to data subjects and data subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's  Rights and Requests).


We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

Privacy Policy

1. Data Controller

1.1 This privacy policy applies where we are acting as a data controller with respect to your personal data and therefore determine the purposes  and means of the processing of that personal data.

1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our Website.

1.3 Our Website incorporates privacy controls you can use to specify whether you would like to receive marketing, limit the publication or any  other use of your information. You can access such privacy controls via

2. How we collect your personal data

2.1 We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties.  Below is a list of ways in which we collect your personal data.

Personal data collected directly from you, including:

when you complete our Publisher or Advertiser registration forms,

when you enter and use our Website, and/or performing contractual obligations, and

when you contact us for any enquiries, complaints or for any other reason.

Personal data collected from other sources, including:

via third parties including our business partners, contractors and/or vendors in a manner that is permitted,

through tags in websites you use and/or manage or control.

3. Personal Data We Use, Purposes and Legal Grounds

We may collect the following personal data from you depending on the service we provide to you. We will only process your personal data when  the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Type of information


Legal basis of processing

Data about your use of our Website.

IP address, geographical location, browser  type and version, operating system, referral  source, length of visit, page views, website  navigation paths, timing, frequency, pattern  of your service use.

To analyse the operation of our Website and  services.

Legitimate interests in monitoring and  improving our Website and services.

Profile data

Your name, address, telephone number,  email address, gender, date of birth.

Operating our Website, providing our  services, communicating with you. Fulfilment  of KYC / AML procedures.

Legitimate interests in the proper  

administration of our Website.

Performing the contract we have with you.

Publication data 

Information that you post for publication on  our Website or through our services.

The publication data may be processed for  the purposes of enabling such publication  and administering our Website and services.

Legitimate interests for the proper  

administration of our Website and business. Performing the contract we have with you.

Inquiry data

The inquiry data may be processed for the  purposes of fulfilment of our KYC and AML  obligations. The proper performance of our  payment obligations to you.

Performing the contract we have with you.

Transaction data

The transaction data, your contact details,  your card details and the transaction details.

The transaction data may be processed for  the purpose of payments and keeping proper  records of those transactions.

Performing the contract we have with you.

Notification data

The notification data may be processed for  the purposes of sending you the relevant  notifications and/or newsletters.

Consent. Performing the contract we have  with you.

Correspondence data

The communication content and metadata  associated with the communication.

The proper performance of our contractual  obligation before you.

Consent. Performing the contract we have  with you.

Any of your personal data identified in this  policy

Exercise or defense of legal claims, whether  in court proceedings or in an administrative  or out-of-court procedure, the protection and  assertion of our legal rights, your legal rights  and the legal rights of others.

Our legitimate interests.

Any of your personal data identified in this  policy

The obtaining or maintaining insurance  coverage, managing risks, or obtaining  professional advice.

Our legitimate interests.

4. Information We May Provide to Third Parties

We may disclose your personal data to the third parties listed below. When we do so, we require those third parties to have appropriate technical  and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the  purposes described in this privacy policy, nor will we sell your personal data to anyone.

4.1 Any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as  reasonably necessary for the purposes, and on the legal bases, set out in this privacy policy.

4.2 To our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional  advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 Payment services providers we have chosen to support us with financial transactions relating to our Website. We will share transaction data  with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and  dealing with complaints and queries relating to such payments and refunds.

4.4 Governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by  such parties or in order to enable Net Socium to comply with its legal and regulatory requirements.

4.5 Partners, contractors and/or vendors in order to perform contract we have with you.

4.5 Partners, contractors and/or vendors in order to perform contract we have with you.

5. Your data protection rights

You have the following rights in terms of the personal data we hold about you:

The right to be informed

We are publishing this privacy policy to keep you informed as to what  we do with your personal data. You can ask us for information  regarding any data of yours that we keep at any time. This  information concerns, among other things, the data categories we  process, for what purposes we process them, the origin of the data if  we did not acquire them directly from you and, if applicable, the  recipients to whom we have sent your data.

The right to access

This enables you to receive a copy of the personal data we hold about  you and to check that we are lawfully processing it. You can obtain a  copy of your data from us free of charge. If you are interested in  other copies, we reserve the right to charge for the additional copies.

The right to correction (rectification)

You can request that we correct your data. We will initiate appropriate  measures to keep the data of yours that we continuously process  correct, complete, and up to date, based the latest information  available to us.

The right to erasure

(The right to be forgotten)

You can request that we delete your data provided the legal  requirements have been met. In accordance with Article 17 the GDPR,  this can be the case if:

the data are no longer required for the purposes they were  acquired or otherwise processed;

you revoke your consent, which is the basis of the data  processing, and there is no other legal basis for the processing; you object to the processing of your data and there are no  legitimate reasons for the processing or you object to data  processing for the purposes of direct advertising;

the data have been processed illegally.

Where the processing is not necessary:

To ensure adherence to a legal obligation that requires us to  process your data

In particular with regard to legal retention periods

To assert, exercise or defend against legal claims

The right to restrict processing

You can request that we restrict the processing of your data if

You dispute the correctness of the data - for the period of time  we need to check the correctness of the data;

The processing is illegal but you do not wish to have your data  deleted and request a restriction of use instead;

We no longer need your data, but you need them to assert,  exercise or defend against legal claims;

You have filed an objection to the processing, though it has not  yet been decided whether our legitimate grounds outweigh yours.

The right to data portability

At your request, we will transfer your data– where technically possible  – to another responsible entity.

However, this right only applies if the data processing is based on  your consent or is required to fulfil a contract. Instead of receiving a  copy of your data, you can ask us to send the data directly to another  responsible entity that you specify.

The right to object

You can object to the processing of your data at any time for reasons  that arise from your special situation provided the data processing is  based on your consent or our legitimate interest or that of a third  party. In this case, we will no longer process your data. The latter  does not apply if we are able to prove there are compelling,  defensible reasons for the processing that outweigh your interests or  we require your data to assert, exercise or defend against legal claims.

The right to withdraw consent

Withdraw the consent you gave us with regard to the processing of  your personal data for certain purposes, such as to allow us to  promote our products and services to you.

The right to complain

We take your rights very seriously. However, if you are of the opinion  that we have not dealt with your complaints adequately, you have the  right to submit a complaint to the data privacy protection authorities  responsible. You can visit their website to find out how to submit a  complaint (

We endeavor to address all of your requests promptly.

6. International Transfers of Your Personal Data

6.1 We do not envisage that any of your personal data will be transferred to countries outside the European Economic Area (EEA) as our offices,  facilities, subcontractors and other third parties with which we work are all located within the EEA.

6.2. In the event that this changes in the future and one or more recipients of your personal data are located outside the EEA, where data  protection laws may be of a lower standard than in the EEA, we will impose the same data protection safeguards that we deploy inside the EEA  to ensure that your personal data are always protected.

7. Retaining and Deleting Personal Data

7.1 We will keep your personal data for as long as is necessary for the purpose for which we initially collected them. Once such period has  ended, we will keep your personal data for the longest of the following periods: a) any retention period set out in our retention policy which is in  line with regulatory requirements relating to retention; or (b) the end of the period in which legal action or investigations might arise in respect  of the services provided.

7.2 Once the retention period of your personal data lapses, we will ensure that your personal data are either irreversibly anonymised or securely  destroyed.

8. Collection and Processing of End Users Data

8.1. We obtain your personal data through your browsing information archive files, as informed via the cookies policies of the websites of each of  our Publishers (websites which show our advertising banners or other ad formats). We obtain data as such: URL of the website displaying our  ads, referral URL, IP, country, geographical area, browser and operating system, etc.

8.2. We may collect and process your data depending on the service we provide to each Publisher. We may use your personal data to show ads  relevant to you in the context of the Publisher’s website you are visiting at any time and with the legitimate interest to identify any possible fraud  of our clients.

8.3. We will only process your personal data when the law allows us to and when expressly authorized through an agreement with our  Publishers, who have informed you of our collection of your personal data, with the aim of showing ads relevant to you.

9. Confidentiality and Security

9.1 We deploy various security measures such as encryption and authentication tools in line with the current state of the art to protect and  maintain the security, integrity and availability of your personal data.

9.2 100% protection against unauthorised access in the case of data transfers across the internet or a website cannot be guaranteed, but we  and our service providers and business partners do our utmost to protect your personal data in line with the prevailing data protection legislation  by means of physical and electronic physical precautions. Among other things, we use the following measures:

Strict criteria for authorisation to access your personal data on a “need-to-know” basis only and exclusively for the specified purpose; Transfer of acquired data in secured form;

Storage of confidential data in our secure servers;

Firewall safeguarding of IT systems to provide protection against unauthorised access, and

Continuous monitoring of access to IT systems to detect and prevent the misuse of personal data.

9.3 If you have received a password from us in order to be able to access certain parts of our Website, you are responsible for keeping this  password confidential and for compliance with all other security procedures which we make you aware from time to time. We ask you not to  share your password with anyone.

10. Cookies

10.1 Our Website uses cookies to distinguish you from other users of the Website and provide contractual obligations in a high quality level. This  helps us to ensure its smooth operation in order to improve your experience.

11. Changes to this privacy policy

11.1 We may update this privacy policy from time to time by publishing a new version on our Website.

11.2 We will notify you appropriately when we make changes to the privacy policy and we will amend its revision date so that you know when  we last amended it. We do however encourage you to review this statement periodically so as to always be informed about how we are  processing and protecting your personal information.

11.3 We may notify you of changes to this policy by email or through the private messaging system on our Website.

12. Contacts

12.1 If you have any questions about our privacy policy or wish to obtain more details in relation to the personal data we process about you or  wish to exercise any of your rights set out in Section 5, please contact us via email at: , phone +9955777105654