Privacy Policy

Privacy Policy – Sovaunion.com

This Privacy Policy outlines how Sova Agency Sp. z o.o., a company registered in Poland (hereinafter “Sova”, “we”, “our” or “us”), collects, processes, and protects personal data through its website sovaunion.com and associated services.


1. Definitions

1.1 Personal Data

Personal data refers to any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as name, identification number, location data, network identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.


1.2 Non-Personal Data

Non-personal data is any information that cannot be directly linked to your identity and, therefore, cannot be classified as personal data. Examples include information about browser types, operating systems, domain names, dates and times of access, URLs visited, online transactions, and search activities.


1.3 Processing

Processing refers to any operation or set of operations performed on such data, including collection, recording, organization, structuring, storage, adaptation or alteration, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.


2. Collection and Processing of Personal Data

The purposes and scope of the collection and processing of personal and non-personal data about you depend on how you interact with us and our technologies and services:

  • If you are a visitor of www.sovaunion.com;
  • If you are a publisher (providing services to us) or an advertiser (purchasing our services);
  • If you are a user of websites of our publishing or advertising partners.

With this Privacy Policy, we inform you about what information we collect and use at each stage, as well as your responsibilities when using the sova union system. We use personal data solely for the administration and provision of our technologies and services. We store personal and any other data strictly in accordance with applicable data protection and confidentiality legislation, as well as our contractual obligations. We take reasonable measures to prevent unauthorized access to your data. We do not share your data with third parties unless you have given your explicit consent, or if the transfer is required by government authorities based on mandatory national legislation or other recipient categories specified in section 3.


2.1 If you are a visitor of www.sovaunion.com

Purposes of data processing:

  • Submitting a request for sova union services. If you visit www.sovaunion.com, no personal data is collected unless you provide it voluntarily (e.g. through a survey). Nevertheless, we record the following non-personal data to ensure security and site stability:
  • IP address of the requesting device;
  • Date and time of your visit;
  • Browser and operating system specifications;
  • Referring website (Referrer URL).

This information is stored in a log file until it is automatically deleted.


Personal data is collected and processed for the following purposes:

  • To respond to inquiries and facilitate communication
  • To analyse and improve website performance and usability
  • To monitor, attribute, and optimise marketing and affiliate campaigns
  • To comply with applicable legal obligations and regulatory requirements

2.1.1 Cookies

Cookies are small data files stored on the user’s device which assist in enhancing user experience and enabling core functionalities. Cookies used on this website include:

  • Strictly necessary cookies – essential for proper site operation
  • Analytical cookies – used for collecting usage metrics and performance insights
  • Affiliate tracking cookies – deployed to attribute referrals and marketing effectiveness

Users may manage or disable cookies at any time by adjusting browser settings or through the cookie consent banner, where applicable. Disabling certain cookies may affect website functionality.


We use cookies to improve and optimize your experience using our website. Cookies do not harm your device, do not contain viruses or other malicious software. They store information related to your device but do not reveal your identity.


Browsing our website is possible without cookies. Most browsers accept cookies automatically. You can change your browser security settings to stop accepting and storing cookies on your device, allow it only for selected websites, or receive notifications before cookies are stored. Please note that disabling cookies may negatively affect the usability of the website and other online services. You can delete cookies stored in your browser at any time. Information stored in such cookies will also be deleted from your device.


2.1.2.2 Google Analytics

We use Google Analytics (Google Inc., USA) to analyze how users interact with our website and optimize its functionality. The tool uses cookies and pseudonymized identifiers, including browser type, operating system, referring URL, and more — stored on Google’s servers. We activate IP anonymization (IP masking) so that your IP address is shortened within the European Union or EEA before storage.

Google may also use this information for advertising (e.g. remarketing), but your full IP is never stored together with other data.

Due to the activation of IP anonymization (IP masking), Google will truncate and thus anonymize your device’s IP address within the European Union or the European Economic Area.

Google analyzes your use of this website to generate reports on our website’s activity and to provide us with additional services related to website usage and the internet in general. We also use Google Analytics for marketing purposes — this allows us to display ads on third-party sites (including Google) to previous visitors of our site.

The IP address transmitted by your browser will not be merged with any other data held by Google. This information may be transferred to third parties if required by law or if such third parties process data on behalf of Google.

You can prevent the storage of cookies on your device by appropriately adjusting your browser settings.

Please note that changing these settings may negatively affect your user experience on our website.


2.2 If you are a publisher or an advertiser

Purposes of processing:

  • To configure and operate the sova union service within the scope of this Policy and/or a contract signed with sova union for the provision of services.

2.2.1 Registration in the sova union system

To access our technologies and services, you must register in our system. After that, in addition to the data described in section 2.1, we collect and process:

  • Personal data provided by you during registration, such as your name, country, email address, etc.;
  • Data you provide while using the sova union system, such as your phone number, postal address.

This processing of personal data is necessary for the performance of a contract, in accordance with Article 6(1)(b) of the GDPR.

Processing of personal data is conducted under the following legal grounds in accordance with GDPR and UK GDPR:

  • Consent (Article 6(1)(a)) for voluntary submissions and cookie-based tracking
  • Legitimate interest (Article 6(1)(f)) for performance monitoring and internal analytics
  • Contractual necessity, where applicable

We do not collect or use any other personal data except that which you provide voluntarily.


2.2.2. Analytics Tools

We use Google Analytics on the account page. More detailed information is available in sections 2.1.2.2–2.1.2.3.


By registering in the sova union system, you — as a publisher or advertiser — agree to the terms of the offers (advertiser orders) that are assigned to you as an advertiser or which you choose to perform as a publisher.

As a publisher or advertiser, you agree to maintain the confidentiality (not disclose to third parties) of the terms contained in the sova union system, including offer conditions.

For all offers, the following requirements apply to publishers and their platforms when publishing materials related to the advertiser:

  • Compliance with the applicable laws and regulations of the country or region where the offer is targeted;
  • No publicly available negative information about the publisher’s platform. In case of non-compliance with these requirements — including any suspicions thereof — the advertiser agrees that sova union may apply the following measures to preserve business integrity and reputation:
  • Impose a penalty on the publisher equal to 100% of the compensation received for the services associated with the previous violation, within a 12-month period;
  • Reevaluate the volume of services provided for a 12-month period in relation to the non-compliance or suspicion thereof by the publisher or their platform.

2.3 If you are a user of websites and platforms of publishers, affiliate networks, or advertisers — our partners

2.3.1 Cookies

We store cookies on the devices of users who visit websites/platforms and use online services of publishers, affiliate networks, and advertisers who are our partners. These cookies store information about:

  • When and on which device a click on an ad occurred;
  • The advertiser’s affiliate program;
  • The publisher;
  • The exact time of the user’s activity;
  • Actions on the site.

During tracking, we may also collect information about the device used to complete the conversion, such as its operating system or browser.

The purpose of this data processing is to track conversions (interests and sales, such as app installations or purchases in an online store) and take this into account when fulfilling agreements with advertisers, publishers, and affiliate networks — in accordance with Art. 6(1)(f) GDPR.

⚠️ Please note: although we carefully select our core partners and clients, we are not responsible for the privacy policies of websites and mobile applications operated by third parties.

You should review the privacy policies of the websites and applications you visit to understand how they process data using our services and technologies, as well as their legal basis for doing so and what personal data they may collect from you.


2.3.2 Information About Cookie Files and Third-Party Cookies

The publisher must inform users of their websites not only about their own cookie files but also about third-party cookies, including those placed by sova union — such as their names, purposes, and the ways users can prevent such cookies from being stored on their devices. The user must give their consent to the use of both first-party and third-party cookies on the publisher’s website before the cookie is stored.


3. Data Protection and Third-Party Transfers

Sova union applies all necessary technical and organizational security measures to protect your personal data from loss, unauthorized disclosure, or any other forms of misuse.

Data is stored in a secure environment that is not open to the public. In some cases, your personal data may be encrypted before transmission (e.g., during login). This means that, with your browser’s support, the connection between your device and our servers includes recognized encryption protocols.

Our staff are trained in handling data and information they access in a responsible and confidential manner.

Please note: if you contact us via email, the confidentiality of information in your message cannot be guaranteed. Third parties may gain access to the content of your email.

Where applicable, data transfers to third countries are conducted in accordance with GDPR-compliant mechanisms.


3.1 Transfer of Data to Third Parties

sova union may share your data with:

  • Service providers, in order to help facilitate or deliver services that we provide to our clients, but only when those providers are contractually appointed to process data on our behalf. Both we and our subcontractors ensure that service providers comply with applicable data protection laws, including those of the European Union and European Economic Area;
  • Affiliated or controlled companies, and their subsidiaries, for the purpose of fulfilling our contractual obligations, provided such companies operate under this Privacy Policy or similar confidentiality principles ensuring at least an equivalent level of data protection;
  • Government authorities, only when required by mandatory national legislation.

We do not transfer your personal data to third parties without your explicit consent.

In the event that sova union is acquired or merged with a third party, we reserve the right to transfer any data we have collected from you as part of such merger, acquisition, sale, or transfer of control. In the unlikely event of our bankruptcy, insolvency, reorganization, or assignment of assets for the benefit of creditors, we may not be able to control how your data is processed, transferred, or used.


4. User Rights

You have the following rights regarding our processing of your personal data:

  • Right of access;
  • Right to rectification;
  • Right to erasure;
  • Right to restrict processing;
  • Right to data portability;
  • Right to object (based on your specific situation) to the processing of your personal data based on our legitimate interests (e.g., direct marketing);
  • Right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • Right to lodge a complaint with a supervisory authority.

You may exercise your rights by contacting us at privacy@sovaunion.com.

In accordance with applicable data protection legislation, we will delete your data without any action on your part if retaining it is no longer necessary for the original purpose and there is no legal reason to retain it.

Where full deletion is not permitted by law (e.g., legal obligations to retain data), we may restrict its processing instead.


5. Amendments

We may update this Privacy Policy and our data protection provisions at any time, especially when new laws or regulations come into effect or when we deem the changes reasonable.

The most current version of this Policy will always be available on our website at: www.sovaunion.com


6. Questions / Contact

If you have any questions or For all data protection inquiries, please contact our privacy team at privacy@sovaunion.com.

Data controller: Sova Agency, Poland.