Privacy Policy

Effective Date: November 22, 2025

This Privacy Policy (“Policy”) is issued by Abacus Global Internet Services Ltd. (AGIS), a corporation registered in the Republic of Cyprus, and Abacus Global Holdings Ltd., a Cayman Islands intellectual property holding entity (collectively, “we,” “us,” or “the Company”). This Policy applies to all AdultDataLink-operated platforms, APIs, mobile services, and affiliated products (“Platform”).

1. Acceptance & User Responsibility

By accessing or using the Platform, you acknowledge and agree that:

• You are solely responsible for providing accurate, complete, and truthful information.
• You assume full responsibility for your actions, data submissions, device security, and network configurations when accessing the Platform.
• You agree to indemnify and hold harmless AGIS, its subsidiaries, officers, employees, and contractors from any claims arising from your use of the Platform, your privacy requests, or any misuse of your personal information by third parties.
• The Platform is provided “AS IS” and “AS AVAILABLE” without any warranty of accuracy, availability, or uninterrupted service.

2. Categories of Data We Collect

We may collect the following categories of information, depending on user interactions:

• Technical identifiers: IP addresses, user-agent strings, device metadata.
• Usage logs: page views, clicks, timestamps, API interactions.
• Cookies and tracking data: session tokens, preference cookies, analytics cookies.
• Account information (if applicable): email, username, authentication records.
• Behavioral analytics data: search behavior, content engagement metrics, referral tracking, and system performance data.
• Security data: anti-fraud identifiers, rate limit metrics, abuse detection logs.

We do not intentionally process data of minors. Misrepresentation of age is the user’s sole responsibility.

3. Purpose of Data Processing

We process data for the following purposes:

• Service delivery, platform functionality, and performance optimization.
• Fraud detection, abuse prevention, and security monitoring.
• Personalization of content, analytics, algorithmic recommendations, and user-experience improvements.
• Legal compliance, regulatory obligations, and operational recordkeeping.
• Enforcement of Terms of Service and intellectual property protections.

4. Legal Basis for Processing (GDPR & UK GDPR)

Where GDPR or UK GDPR applies, we process data based on:

• Legitimate interest: security, analytics, service operation.
• Contractual necessity: account services and platform access.
• Consent: cookies, optional features, marketing communications.
• Legal compliance: regulatory, tax, audit, law enforcement requests.

5. Cookies & Tracking Technologies

The Platform uses cookies for session management, authentication, analytics, and personalization. Users may opt-out via browser settings; doing so may limit functionality.

Third-party analytics providers may deploy tracking technologies independently. The Company is not liable for third-party cookies or data collection.

6. Data Sharing & Disclosure

We may share data with the following categories of recipients:

• Affiliates and subsidiaries under AGIS corporate structure.
• Hosting providers, cloud infrastructure vendors, DDoS protection services.
• Analytics partners, anti-fraud systems, CDN providers.
• Professional advisers (legal, compliance, cybersecurity).
• Law enforcement agencies, where legally required, including under 18 U.S.C. § 2257, DMCA, GDPR, CPRA, and equivalent regulations.

We do not sell personal information without explicit consent where required by law (e.g., CCPA/CPRA).

7. International Data Transfers

Where data is transferred outside your jurisdiction, we rely on mechanisms such as:

• EU Standard Contractual Clauses (SCCs)
• UK International Data Transfer Addendum
• Legitimate interest assessments
• Cross-border corporate governance policies

Transfers may involve servers in the EU, United States, Canada, Singapore, or other regions.

8. Data Security Measures

We utilize layered security including AES-256 encryption, hashed credentials, firewalls, access controls, logging, segmentation, and regular security audits.

Despite these measures, no system is 100% secure. You acknowledge and accept that:

• Data transmission involves inherent risks.
• The Company cannot guarantee absolute security.
• The Company is not liable for breaches caused by user negligence, third-party providers, force majeure events, or unauthorized access beyond our control.

9. Data Retention

We retain personal data only as long as necessary for:

• Platform operations and account maintenance.
• Fraud prevention and security monitoring.
• Compliance with 18 U.S.C. § 2257, tax, legal, or regulatory obligations.
• Corporate records required under AGIS compliance frameworks.

10. Data Subject Rights

Depending on your jurisdiction, you may have the following rights:

• GDPR/UK GDPR: access, rectification, erasure, portability, restriction, objection.
• CCPA/CPRA: opt-out of sale/sharing, deletion, correction, access.
• LGPD: confirmation, access, correction, anonymization, portability.
• PIPEDA: access and correction rights.
• PDPA (various jurisdictions): access, correction, withdrawal.

To submit requests, email [email protected]. Verification may be required. Unverifiable or abusive requests may be denied.

11. No Liability & Indemnification

To the maximum extent permitted by law, you agree that the Company is not liable for:

• User misconfiguration of devices, browsers, VPNs, or privacy tools.
• Third-party data practices beyond our control.
• Unauthorized access resulting from user negligence.
• Service interruptions, technical issues, or data unavailability.
• Actions of advertisers, affiliates, or external platforms.

You agree to indemnify and hold harmless the Company against any claims resulting from your use of the Platform, including privacy-related disputes.

12. Changes to This Policy

This Policy may be updated at any time. The updated version becomes effective upon posting. Continued use of the Platform constitutes acceptance of the updated Policy.

13. Contact Information

Data Protection Officer (DPO):
[email protected]