Last updated: 08/10/2026 Effective from: 08/07/2020
1. Introduction
This Privacy Policy explains how Adtorque ("Adtorque", "we", "us", "our") collects, uses, shares and protects personal information.
It applies to:
- Visitors to our website
- Prospective clients who contact us or request a proposal
- Clients who engage our digital marketing and advertising services
- Recipients of our emails and marketing communications
Adtorque is an independent digital marketing and advertising service provider. We are not an employee, agent, partner or representative of Meta Platforms, Google, TikTok or any other advertising platform.
If you do not agree with this policy, please do not use our website or submit information to us.
2. Who We Are
Business name: [Registered legal entity name] Trading as: Adtorque Registered address: [Full address] Email: [privacy@yourdomain.com] Phone: [Contact number]
For data protection questions, contact us at the email address above.
3. Information We Collect
3.1 Information you give us directly
When you contact us, request an audit, book a call, subscribe to our updates or become a client, we may collect:
- Name and job title
- Business or company name
- Email address and phone number
- Business address
- Website address
- Information about your business, products, pricing and market
- Details of your marketing goals, budget and previous activity
- Any other information you choose to send us
3.2 Information collected automatically
When you visit our website, we may automatically collect:
- IP address and approximate location (city or region level)
- Browser type, device type and operating system
- Pages viewed, time spent and navigation paths
- Referring website or advertisement
- Date and time of access
This is collected through cookies and similar technologies. See Section 7.
3.3 Information from clients during an engagement
To deliver our services, clients grant us access to systems that contain data belonging to them and to their customers. This may include:
- Advertising accounts (Meta Business Manager, Google Ads, TikTok Ads)
- Analytics accounts (Google Analytics, Google Tag Manager)
- Pixels, datasets and conversion tracking systems
- Website or store administrative access
- CRM systems and customer lists
- Email marketing platforms
Our role in relation to this data is explained in Section 5.
3.4 Information from third parties
We may receive information about you from:
- Advertising and analytics platforms
- Publicly available business sources
- Referrals from existing clients or partners
4. How We Use Your Information
We use personal information to:
- Respond to enquiries and provide proposals or quotations
- Deliver the services set out in our Services Agreement
- Set up, manage and optimise advertising campaigns
- Implement and troubleshoot tracking and analytics
- Produce performance reports and analysis
- Issue invoices and process payments
- Communicate about your account, services or changes to terms
- Send marketing communications where you have consented or where permitted by law
- Improve our website, services and internal processes
- Comply with legal, tax and regulatory obligations
- Establish, exercise or defend legal claims
We do not sell personal information.
5. Our Role: Controller and Processor
This distinction matters and we state it plainly.
5.1 Where we act as a controller
For information about our own website visitors, prospective clients, client contacts and our own marketing activity, Adtorque determines how and why the data is used. We are the controller of that information, and this policy governs it.
5.2 Where we act as a processor
When we manage advertising accounts, analytics systems, customer lists or tracking on behalf of a client, we handle personal data belonging to that client's customers and audiences. In those circumstances the client is the controller and Adtorque acts as a processor, following the client's instructions.
In that role:
- We process such data only to perform the agreed services
- We do not use client customer data for our own purposes
- We do not sell, rent or share it except as needed to deliver the services
- The client remains responsible for having a lawful basis to collect and use that data, and for its own privacy notices, cookie consent and data protection compliance
This reflects Section 11 of our Services Agreement, which places responsibility for the client's own privacy, cookie, data protection and consumer protection compliance with the client.
If you are an individual whose data is held by one of our clients and you wish to exercise your rights, please contact that business directly. We will assist them in responding.
6. Legal Bases for Processing
Where data protection law requires a legal basis, we rely on:
| Purpose | Legal basis |
|---|---|
| Responding to enquiries | Steps prior to entering a contract |
| Delivering services to clients | Performance of a contract |
| Invoicing and payment | Contract and legal obligation |
| Website analytics and improvement | Consent, or legitimate interests |
| Marketing emails | Consent, or legitimate interests where permitted |
| Advertising and remarketing | Consent |
| Record keeping and tax | Legal obligation |
| Defending legal claims | Legitimate interests |
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal.
7. Cookies and Tracking Technologies
Our website uses cookies and similar technologies, including pixels, tags and local storage.
Categories we use:
- Strictly necessary — required for the site to function. These cannot be switched off.
- Analytics — help us understand how the site is used (for example, Google Analytics).
- Advertising — allow us to measure advertising performance and show relevant ads (for example, Meta Pixel, Google Ads tags, LinkedIn Insight Tag).
- Functional — remember preferences such as language.
Where required by law, we request your consent before setting non-essential cookies. You can change your preferences at any time through [our cookie settings / your browser settings].
Blocking cookies may affect how parts of the site work.
Do Not Track: our website does not currently respond to Do Not Track browser signals.
8. Sharing Your Information
We share personal information only where necessary, with:
Advertising and analytics platforms — Meta Platforms, Google, TikTok, LinkedIn and similar, where campaigns or measurement require it. These platforms are independent third parties operating under their own privacy policies, which we do not control.
Service providers — hosting, email delivery, CRM, project management, accounting and payment processing providers acting on our instructions.
Professional advisers — lawyers, accountants and auditors where reasonably required.
Authorities — where required by law, regulation, court order or to protect our legal rights.
Business transfers — if Adtorque is involved in a merger, acquisition or sale of assets, information may be transferred as part of that transaction. We will notify affected individuals where required.
We require third parties handling personal data on our behalf to protect it appropriately and to use it only for the purposes we specify.
9. International Transfers
Adtorque works with clients and platforms across multiple markets, including India, Saudi Arabia, the United Arab Emirates, other Middle Eastern markets, the United Kingdom, the United States, Canada, Australia and Europe.
As a result, personal information may be transferred to, stored in or accessed from countries other than your own, including countries whose data protection laws differ from those where you live.
Where such transfers take place, we take reasonable steps to ensure appropriate safeguards are in place, which may include standard contractual clauses or equivalent mechanisms recognised under applicable law.
10. Data Retention
We retain personal information only as long as necessary for the purposes it was collected for.
Indicative periods:
- Enquiries that do not become clients: [12–24] months
- Client records and correspondence: duration of the engagement plus [X] years
- Invoices, tax and accounting records: as required by applicable law in the relevant jurisdiction
- Marketing contacts: until you unsubscribe or withdraw consent
- Website analytics: as configured in the relevant platform, typically [14] months
When information is no longer needed, we delete it or anonymise it.
11. Security
We apply reasonable technical and organisational measures to protect personal information, including access controls, encryption in transit, restricted account permissions and staff confidentiality obligations.
No method of transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security.
If a data breach occurs that is likely to result in a risk to your rights, we will notify you and the relevant authority where required by applicable law.
12. Your Rights
Depending on where you live, you may have the right to:
- Access the personal information we hold about you
- Correct information that is inaccurate or incomplete
- Delete your information in certain circumstances
- Restrict or object to certain processing
- Withdraw consent where processing is based on consent
- Data portability — receive your data in a structured, machine-readable format
- Complain to a supervisory authority
To exercise any of these rights, contact us at [privacy@yourdomain.com]. We will respond within the timeframe required by applicable law, and may ask you to verify your identity first.
Note on client data: if your information is held by one of our clients and we process it on their behalf, we will direct your request to that client, who is responsible for responding.
Regional notes:
- India: rights under the Digital Personal Data Protection Act apply where relevant, including the right to grievance redressal.
- Saudi Arabia: rights under the Personal Data Protection Law apply to data subjects in the Kingdom.
- UK and EEA: rights under UK GDPR and EU GDPR apply, including the right to lodge a complaint with your local supervisory authority.
13. Marketing Communications
If you subscribe to our updates or become a client, we may send you marketing emails about our services, insights and offers.
You can unsubscribe at any time using the link in any email, or by contacting us directly. We will still send service-related messages necessary to manage your account.
14. Third-Party Links
Our website and reports may contain links to third-party websites and platforms. We are not responsible for the privacy practices or content of those sites. We encourage you to read their privacy policies.
15. Children
Our website and services are intended for businesses and are not directed at children. We do not knowingly collect personal information from children. If you believe a child has provided us with information, contact us and we will delete it.
16. Changes to This Policy
We may update this policy from time to time to reflect changes in our practices, technology or legal requirements.
The date at the top shows when it was last revised. Material changes will be notified by email or a prominent notice on our website where required.
17. Contact Us
Questions, requests or complaints about this policy or how we handle your information:
Adtorque Email: [privacy@yourdomain.com] Phone: [Contact number] Address: [Full registered address]
We aim to respond to all enquiries within [X] business days.
NOTES FOR ADTORQUE — DELETE BEFORE PUBLISHING
What you must fill in
Every [square bracket] needs a real value. The ones that matter most legally:
- Registered legal entity name and address. A privacy policy with no identifiable entity behind it fails the basic transparency requirement in every jurisdiction you operate in.
- A working privacy contact email. It must be monitored — rights requests have statutory deadlines.
- Retention periods. Replace the indicative ranges with what you actually do.
- Response timeframe in Section 17.
What the source PDF was, and wasn't
The document you sent is a Digital Marketing & Advertising Services Agreement — a client contract. It is not a privacy policy and does not substitute for one. The two documents do different jobs:
- Services Agreement — your commercial terms with clients: scope, fees, no-guarantee clauses, account access, liability, refunds.
- Privacy Policy — a public statement about personal data, required by law in most markets you operate in.
You need both, and you likely also need:
- Terms of Service for the website itself
- Cookie Policy (can be a section of this, or separate)
- Data Processing Agreement (DPA) — see below
The DPA gap — worth attention
Section 5 of this policy identifies that you act as a processor when managing client ad accounts, pixels and customer lists. That's accurate and it's the right way to describe it.
But a privacy policy isn't the instrument that governs it. Under GDPR Article 28 and equivalent provisions in India's DPDP Act and Saudi's PDPL, a controller-processor relationship generally requires a written data processing agreement with specific mandatory terms — subject matter, duration, nature and purpose, types of data, obligations, sub-processors, and so on.
Your current Services Agreement doesn't contain one. Section 11 places data protection compliance on the client, which is reasonable as a commercial position, but it doesn't discharge your own obligations as a processor.
For a client in the UK, EU, or increasingly Saudi Arabia, their legal or compliance team is likely to ask for a DPA before granting account access. Having one ready is both a compliance matter and a sales advantage.
One honest caveat
I'm not a lawyer and this isn't legal advice. This is a well-structured starting point built from your actual operations, but you have a genuinely complex jurisdictional footprint — India, Saudi Arabia, UAE, UK, EU, US, Canada, Australia — each with its own regime.
Before publishing, have it reviewed by a lawyer qualified in your primary jurisdiction. The specific points worth their time:
- Which law governs, and whether you need separate notices per market
- Whether your India/Saudi operations trigger registration or local representative requirements
- The DPA question above
- Whether your cookie consent mechanism meets EU/UK standards if you serve those markets