I. GENERAL INFORMATION

This Cookie Policy explains how ADSPARX EOOD uses cookies and similar technologies when you visit and use www.adsparx.com.

The purpose of this Policy is to provide you with clear information about:

1. What cookies are;

2. What categories of cookies and similar technologies may be used;

3. The purposes for which they are used;

4. Which technologies require prior consent;

5. How you can accept, reject or change your choices;

6. How the use of certain technologies may involve the processing of personal data.

This Policy applies together with the Privacy Policy of www.adsparx.com.

II. WHO OPERATES THE WEBSITE?

The website www.adsparx.com is operated by:

ADSPARX EOOD

UIC: 207674217

Registered office and management address: 19 Lavski Rid St., Vitosha District, Sofia, Bulgaria

Email: hello@adsparx.com

Website: www.adsparx.com

Hereinafter, the company may be referred to as “ADSPARX”, the “Company”, “we”, “us” or “our”.

III. WHAT ARE COOKIES?

Cookies are small files or pieces of information that may be stored on your device, such as a computer, smartphone or tablet, when you visit a website.

Cookies allow a website or certain website functionalities to recognise your device, remember particular settings, support the normal operation and security of the website and, where you have provided the relevant consent, assist in analysing website usage or measuring advertising campaigns.

Not all cookies contain information that can directly identify you. In certain circumstances, however, information contained in cookies or other online identifiers may constitute personal data or may be combined with other information in a way that allows an individual to be identified.

IV. WHAT ARE SIMILAR TECHNOLOGIES?

The rules set out in this Policy are not limited to traditional HTTP cookies.

www.adsparx.com may also use other technologies for storing or accessing information on your device, such as:

1. Local Storage;

2. Session Storage;

3. Pixels and tags;

4. Online identifiers;

5. Analytics and measurement scripts;

6. Other similar technologies.

Where applicable law requires prior consent for the use of such a technology, the same principles applicable to non-essential cookies shall apply.

V. WHAT IS THE LEGAL BASIS FOR USING COOKIES?

Cookies and similar technologies are used in accordance with:

1. Art. 4a of the Bulgarian Electronic Commerce Act;

2. Regulation (EU) 2016/679 – the General Data Protection Regulation (“GDPR”);

3. The Bulgarian Personal Data Protection Act;

4. Directive 2002/58/EC concerning privacy and electronic communications (“ePrivacy Directive”);

5. Other applicable Bulgarian and European legislation.

Information may be stored on your device or accessed from your device after clear information has been provided to you and, where required by law, after your prior consent has been obtained.

Strictly necessary cookies and technologies do not require prior consent where they are necessary for the transmission of a communication over an electronic communications network or for providing a service or functionality explicitly requested by the visitor.

Non-essential analytics, marketing, advertising and other tracking technologies are activated only where an appropriate legal basis exists and, where required, after your prior consent has been obtained.

VI. WHAT CATEGORIES OF COOKIES MAY WE USE?

1. Strictly Necessary Cookies

These cookies are necessary for the normal and secure operation of www.adsparx.com.

They may be used, for example, for:

1. The basic technical operation of the website;

2. Security and prevention of abuse;

3. Saving your cookie preferences;

4. Correct loading of pages and website functionality;

5. Maintaining technical sessions;

6. Other functionalities explicitly requested by the visitor.

These cookies cannot be disabled through the consent management mechanism where the website or requested functionality cannot operate properly without them.

They may be blocked through your browser settings, but doing so may cause certain parts of the website to function incorrectly.

2. Functional Cookies

Functional cookies allow the website to remember certain choices or preferences you have made.

They may be used, for example, for:

1. Remembering preferences;

2. Improving the user experience;

3. Saving settings for certain website components;

4. Enabling additional functionality.

Where a particular functional cookie is not strictly necessary for providing an explicitly requested service, it shall only be activated where the required consent has been obtained.

3. Analytics and Statistics Cookies

Analytics and statistics technologies may help us understand how visitors use www.adsparx.com.

They may collect information relating to, for example:

1. Pages visited;

2. Duration of visits;

3. Navigation through the website;

4. Device or browser used;

5. Source of the visit;

6. Interactions with certain website elements;

7. Technical performance of pages.

This information may be used to analyse and improve the structure, content, performance and user experience of the website.

Analytics technologies that are not strictly necessary will not be activated before the required consent has been provided.

4. Marketing and Advertising Cookies

Marketing and advertising technologies may be used to measure the effectiveness of advertising campaigns and, where applicable, to create audiences or provide more relevant advertising.

They may assist with:

1. Measuring advertising conversions;

2. Determining whether a particular action was completed following interaction with an advertisement;

3. Analysing the effectiveness of advertising campaigns;

4. Limiting repeated display of particular advertisements;

5. Creating audiences where supported by the relevant advertising platform;

6. Personalising advertising content where you have provided the required consent.

Such technologies are activated only after prior consent, where such consent is required by applicable law.

5. Third-Party Cookies and Technologies

Certain functionalities of www.adsparx.com may be provided through external service providers.

Depending on the integrations active at a particular time, such providers may offer services relating to:

1. Website traffic analytics;

2. Advertising campaign measurement;

3. Embedded video or other external content;

4. Maps or other interactive components;

5. Protection against abuse and automated requests;

6. Other digital functionalities.

Where an external provider places its own cookies or receives information from your device, that provider may also process information in accordance with its own privacy policy.

Non-essential technologies provided by third parties shall be loaded in accordance with your choices in the cookie consent management mechanism.

VII. FIRST-PARTY AND THIRD-PARTY COOKIES

Depending on who creates and manages the cookie, it may be classified as:

1. First-party cookie

A cookie placed directly by the www.adsparx.com domain.

2. Third-party cookie

A cookie or similar technology managed by another provider in connection with a functionality or service used on our website.

The possibility of using a third-party cookie does not automatically mean that it will be activated before you have made the required choice.

VIII. SESSION AND PERSISTENT COOKIES

Depending on their duration, cookies may be classified as:

1. Session cookies

These are stored temporarily and are generally deleted when the browser session ends or when the browser is closed.

2. Persistent cookies

These remain on your device for a predefined period or until you delete them.

The duration of each cookie depends on its specific purpose and technical configuration.

Where applicable, information about the specific duration of cookies used on the website may be available through the “Cookie Settings” panel on www.adsparx.com.

IX. HOW DO WE OBTAIN YOUR CONSENT?

When you first visit www.adsparx.com, or where your choices need to be requested again, a cookie consent management panel may be displayed.

Through this panel, you may:

1. Accept all non-essential categories;

2. Reject non-essential cookies;

3. Make an individual choice by category;

4. Obtain additional information about the technologies used.

Failure to make a choice, continuing to browse the website or closing the panel does not in itself constitute consent to the use of non-essential cookies.

Where consent is required, the relevant technology will only be activated following an action that clearly indicates your choice.

X. HOW CAN YOU CHANGE OR WITHDRAW YOUR CONSENT?

You may change your choices regarding non-essential cookies at any time.

To do so, use the “Cookie Settings” button or panel available on www.adsparx.com.

Through this mechanism, you may, for example:

1. Withdraw previously provided consent;

2. Enable an additional category;

3. Disable a particular non-essential category;

4. Review current information about the technologies used.

Withdrawal of consent is free of charge and should be possible in a manner comparable in ease to the way in which consent was originally provided.

Withdrawal of consent does not affect the lawfulness of the use of technologies or processing carried out on the basis of valid consent before its withdrawal.

XI. BROWSER SETTINGS

In addition to the cookie management mechanism available on www.adsparx.com, you may manage certain cookies through the settings of your browser.

Most browsers allow you to:

1. View stored cookies;

2. Delete individual or all cookies;

3. Block cookies from particular websites;

4. Block third-party cookies;

5. Automatically delete cookies when the browser is closed;

6. Restrict certain tracking technologies.

Please note that blocking strictly necessary cookies through your browser may cause certain website functionalities to operate incorrectly.

Browser settings do not always replace choices made through the website consent management mechanism, particularly where technologies other than traditional cookies are used.

XII. GOOGLE CONSENT MODE AND CONSENT SIGNALS

Where www.adsparx.com uses Google services, the website may communicate information about a visitor’s choices regarding analytics and advertising functionalities to the relevant Google technologies.

Such consent signals allow the behaviour of the relevant Google services to be adapted according to the consent granted or refused by the visitor.

The use of a consent signalling mechanism does not replace the requirement to obtain valid consent where such consent is required by law.

Where the visitor has not provided the required consent, non-essential technologies should be restricted or blocked in accordance with the website configuration and applicable legislation.

XIII. DO COOKIES PROCESS PERSONAL DATA?

Certain cookies and similar technologies may be associated with information such as:

1. IP address;

2. Online identifier;

3. Device or browser identifier;

4. Information about visits;

5. Website interactions;

6. Source of the visit;

7. Other technical information.

Where such information constitutes personal data, it shall be processed in accordance with the GDPR and our Privacy Policy.

The Privacy Policy provides further information regarding:

1. Legal grounds for processing;

2. Retention periods;

3. Recipients of personal data;

4. International transfers;

5. Your rights;

6. How to exercise those rights.

XIV. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Certain technology providers may use infrastructure located outside the European Economic Area (“EEA”).

Where information obtained through cookies or similar technologies constitutes personal data and is transferred outside the EEA, such transfer shall take place only where an appropriate mechanism under Chapter V of the GDPR is available.

Such mechanisms may include:

1. An adequacy decision adopted by the European Commission;

2. Standard Contractual Clauses;

3. Another mechanism permitted under the GDPR.

Further information regarding international data transfers is available in our Privacy Policy.

XV. CURRENT LIST OF COOKIES USED

The specific cookies and technologies used by www.adsparx.com may change as a result of:

1. Website updates;

2. Changes to WordPress components and plugins;

3. Addition or removal of analytics services;

4. Addition or removal of advertising integrations;

5. Changes to third-party services;

6. Technical or legal developments.

For this reason, up-to-date information regarding available categories and, where technically applicable, specific cookies, their providers, purposes and duration may be provided through the “Cookie Settings” panel on www.adsparx.com.

This approach allows the information provided to reflect the technologies actually active at a particular time rather than relying on a static list that may become outdated.

XVI. YOUR RIGHTS

Where the use of cookies or similar technologies involves the processing of your personal data, you may have the right to:

1. Access your personal data;

2. Rectify inaccurate personal data;

3. Request deletion where the applicable conditions are satisfied;

4. Restrict processing;

5. Data portability, where applicable;

6. Object to certain processing;

7. Withdraw consent;

8. Lodge a complaint with the competent supervisory authority.

Detailed information about these rights and how to exercise them is available in our Privacy Policy.

XVII. CHANGES TO THIS COOKIE POLICY

ADSPARX may periodically update this Cookie Policy, including in the event of:

1. Changes to applicable legislation;

2. Changes to the technologies used;

3. Addition or removal of website functionalities;

4. Changes to service providers;

5. Changes to the manner in which consent is managed;

6. A need to provide clearer or more detailed information.

The current version of this Policy will be published on www.adsparx.com.

Where a change requires new consent to be obtained, the cookie consent management mechanism may ask you to make a new choice.

XVIII. CONTACT DETAILS

If you have any questions regarding the use of cookies and similar technologies on www.adsparx.com, you may contact us at:

ADSPARX EOOD

UIC: 207674217

Address: 19 Lavski Rid St., Vitosha District, Sofia, Bulgaria

Email: hello@adsparx.com

Website: www.adsparx.com