Privacy Policy

Propeller Ads Limited (Cyprus), Propeller Ads s.r.o. (Czech Republic), Propeller Ads Limited (Isle of Man), Propeller Ads HK Limited (Hong Kong) and Adtech Agency FZ-LLC (United Arab Emirates) (referred to as “Monetag” 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 Monetag 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 www.monetag.com.
when we refer to the “API” we mean the application programming interface(s) made available by Monetag enabling programmatic access to your Publisher account and to the Service;
when we refer to a “Connected AI Agent” we mean any AI system, software agent, large language model, MCP server or client, automated assistant or other software that you authorise or connect (including through an MCP Connector) to access the API or your account on your behalf.

Who we are

Propeller Ads Ltd is a company registered in the Republic of Cyprus, under registration number HE353513 as a limited liability company having its registered office at Zinonos Rossidi 11, 3082, Limassol, Cyprus.

Propeller Ads Limited is a company registered in the Isle of Man, under registration number 011883V as a limited liability company having its registered office at First Floor, Jubilee Buildings, Victoria Street Douglas, Douglas IM1 2SH, Isle of Man.

Propeller Ads s.r.o. is a company registered in the Czech Republic, under registration number 08732469 as a limited liability company having its registered office at Plzeňská 3350/18, Smíchov, 150 00 Praha 5.

Adtech Agency FZ-LLC, is a company registered in the United Arab Emirates, under the license number 100357 as a limited liability company having its registered office at 16-SD158, Ground Floor, Bldg 16-Co Work, Dubai Internet City, Dubai, UAE

Propeller Ads HK Limited is a company registered in Hong Kong, under business registration number 80320836 as a limited liability company having its registered office at RM 5003, 5/F Yau Lee Centre 45, Hoi Yuen Road, Kwun Tong, Hong Kong.

This Privacy Policy will apply to Propeller Ads Ltd in Cyprus, Propeller Ads Limited in the Isle of Man, Propeller Ads s.r.o. in Czech Republic, Propeller Ads HK Limited in Hong Kong and Adtech Agency FZ-LLC in United Arab Emirates.

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).
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).
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).

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 dpo@monetag.com.

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 registration form, which is available on our Website,
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.
when you interact with our AI-powered features and tools, or with our chatbots (e.g. Telegram, WhatsApp or within the Monetag Platform), and
when you, or a Connected AI Agent or third-party application you authorise, access your account or our services programmatically through the API or otherwise.

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	Purpose	Legal basis of processing
Data about your use of our Website. User ID, 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 includes your contact details, your payment method details and the transaction details (reference/payment ID, etc.).	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. Legitimate interest.
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 (including AI-assisted communications). The communication content and metadata associated with the communication, including any instructions, prompts and requests submitted to our AI-powered features or transmitted through the API (whether directly or through a Connected AI Agent you authorise), the resulting outputs, and interaction and access logs and related metadata, as well as messages exchanged with us via our bots in messengers or through the Platform, including your full name, messenger user ID, username and related chat metadata.	The proper performance of our contractual obligation before you, including to provide and administer our services, communicate with you about your use of the services, enable you to use, manage and optimize monetization through your account and through the API, maintain records of your communications and of the actions performed through your account, and ensure the security, integrity and reliable operation of our services, the API and related communication channels.	Consent. Performing the contract we have with you. Where applicable (e.g. security, abuse prevention and service reliability), our legitimate interests.
	To improve our services and AI systems (including quality assurance of our AI-powered features and of the API). Monetag does not use personal data to train AI models; we use aggregated, anonymised or otherwise non-personal information for this purpose.	Our legitimate interests. You may object to this processing at any time (the right to object – see Section 5).
	To maintain internal records of our business communications and to manage our sales and customer relationships, including AI-assisted logging, summarisation and analysis of such communications to prepare internal reports and account overviews, with the use of AI-powered instruments subject to human review.	Our legitimate interests. You may object to this processing at any time (see Section 5).
Any of your personal data identified in this policy	Exercise or defence 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.
Any of your personal data identified in this policy	Analysis and evaluation of the performance of the contract we have with you, including communicating with you to obtain feedback regarding our services.	Our legitimate interests. Performing the contract we have with you.

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 Propeller to comply with its legal and regulatory requirements.

4.5 Partners, contractors and/or vendors in order to perform/analyse and evaluate the performance of the contract we have with you. This category shall include, inter alia, partners/contractors/vendors assisting with obtaining feedback from you regarding our services (e.g. Trustpilot and other similar platforms). This category also includes service providers supporting our communication tools and AI-powered features, including our chatbots within the Monetag Platform (if applicable) or in social networks – e.g. Telegram, WhatsApp or other messengers. In particular, where you communicate with us via our chatbots or use AI-powered features of our Platform, we may disclose limited correspondence and interaction data (such as your full name and username or user ID in the relevant messenger, the content of chat messages, the prompts and instructions submitted to such features, and related information) to providers of AI services/models (e.g. OpenAI, Anthropic, etc) acting on our behalf and under appropriate contractual safeguards, used to generate automated replies and outputs and to support the operation, security and quality of such features, only to the extent necessary for the purposes described in this Privacy Policy. Such service providers implement appropriate technical and organisational measures to protect your personal data.

4.6 Advertising Platforms for Audience Matching. Where you have previously provided your consent to the relevant third party from whom we receive the information in question, we may share your hashed email address with third-party advertising platforms, including but not limited to those listed below, for the purpose of audience matching and targeted advertising in a pseudonymous form (SHA-256 hash):

Platform	Data Processing Terms
Google Ads	https://privacy.google.com/businesses/processorterms/
Meta Ads	https://www.facebook.com/legal/terms/dataprocessing
LinkedIn Ads	https://legal.linkedin.com/dpa
Reddit Ads	https://advertising.reddithelp.com/en/categories/policy-guidelines/data-processing-addendum-custom-audiences
X (Twitter) Ads	https://gdpr.x.com/en/controller-to-controller-transfers.html

Each of these platforms acts as an independent data controller with respect to their own users’ data. They process the uploaded hashed email addresses under their own privacy policies and data-processing terms (linked above). International transfers of data to these platforms (where applicable) are conducted on the basis of, at least, Standard Contractual Clauses (SCCs), as implemented by those platforms under their respective data-processing terms. Users whose data is shared with advertising platforms for audience-matching purposes may exercise their right to object and opt out at any time by contacting us at dpo@monetag.com.

4.7 Sub-processors and service providers that support the operation of our Platform, the API and our AI-powered features, including providers of artificial-intelligence, machine-learning, analytics, security and cloud-hosting services, who process personal data on our behalf and under appropriate contractual safeguards, solely for the purposes set out in this policy.

4.8 Where you connect a Connected AI Agent or otherwise authorise a third-party application or AI provider to access your account or the API, we will make available to that agent, application or provider the account and related data necessary to perform the operations you request. Such disclosure is made on your instruction and at your direction; you are responsible, as controller or otherwise, for that recipient’s subsequent processing of the data, including where the recipient is located outside the EEA. Monetag does not control, and is not responsible for, any Connected AI Agent or its provider, and their processing of your data is governed by their own terms and privacy policies.

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	Monetag is 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 complain	Monetag takes 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 (http://www.dataprotection.gov.cy).
The right to withdraw consent	Where our processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

We endeavour to address all of your requests promptly.

Your right to object applies in particular to processing based on our legitimate interests, including the sharing of hashed identifiers for audience matching described in clause 4.6, the improvement of our services and AI systems, and the AI-assisted analysis of our internal business communications. To exercise any of these rights, please contact us at dpo@monetag.com.

6. International Transfers of Your Personal Data

6.1 Your personal data may be transferred to, or accessed from, countries outside the European Economic Area (EEA), including (a) within our group of companies, in particular to Propeller Ads Limited in the Isle of Man, Propeller Ads HK Limited in Hong Kong and Adtech Agency FZ-LLC in the United Arab Emirates; and (b) to our sub-processors and service providers, including but not limited to providers of AI services/models located in the United States (such as OpenAI and Anthropic), cloud-hosting, analytics and security providers, and the third-party advertising platforms listed in clause 4.6.

6.2 Where such transfers take place, we ensure that an appropriate transfer mechanism and safeguards are in place in accordance with applicable data-protection law, namely an adequacy decision of the European Commission (which, in respect of the Isle of Man, the European Commission has determined provides adequate protection for the privacy rights of individuals) and/or Standard Contractual Clauses, together with supplementary technical, organisational and contractual measures where required. Transfers to Hong Kong and to the United Arab Emirates, for which no adequacy decision is currently in place, are carried out on the basis of Standard Contractual Clauses. You may contact us at dpo@monetag.com for further information on the safeguards applied.

6.3 Where you direct a transfer of your data to a Connected AI Agent, to a third-party AI provider of your choosing or to any other third-party application you authorise to access the API, you are responsible for ensuring an appropriate transfer mechanism for that onward transfer, and clause 4.8 applies.

6.4 In the event that one or more recipients of your personal data are located outside the European Economic Area (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.

7.3 Access and interaction logs relating to the use of the API and/or any Connected AI Agent are retained for the purposes of security, abuse prevention, audit and dispute resolution, for no longer than necessary for those purposes and in accordance with clause 7.1.

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 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.

8.4. End users’ personal data is not made available to Connected AI Agents through the API. Data available through the API relates to the Publisher’s account, sites, ad units and aggregated performance statistics.

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.

9.4 These obligations apply equally to any API credentials issued to or generated by you: you are responsible for keeping them confidential, for storing them securely in your own local environment, for not sharing them with any third party other than a Connected AI Agent acting on your behalf, and for notifying us promptly of any suspected compromise. You may revoke your API credentials at any time in your account settings.

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. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy at https://monetag.com/cookies-policy/

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: dpo@monetag.com