PRIVACY POLICY

Last updated: January 30, 2026


This Privacy Policy explains how Cyclone Ads Limited (Reg. No. C 109615, Date of Registration: 24.09.2024) ("we," "us," or "our") collects, uses, stores, and protects your personal information when you use our website - https://approyal.io.

This Privacy Policy is drafted in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and reflects principles of lawfulness, fairness, transparency, data minimisation, purpose limitation, and security.

If you do not agree with this Privacy Policy, please do not use the Website.

1. GENERAL PRINCIPLES
We collect and process personal data only to the extent strictly necessary for the operation of the Website and communication with users. We do not collect excessive or irrelevant data and do not engage in covert tracking, profiling, or resale of personal information.

The Website is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

2. PERSONAL DATA WE COLLECT
2.1 DATA PROVIDED DIRECTLY BY YOU
We may collect the following personal data when you voluntarily provide it:
  • Full Name;
  • Company name;
  • Email;
  • Phone number.
Any information you include in messages sent via contact forms or email correspondence.

2.2 AUTOMATICALLY COLLECTED TECHNICAL DATA
When you access the Website, we may automatically process limited technical information strictly necessary for security and functionality, including:
  • Browser type and version;
  • Operating system;
  • IP address (processed transiently for security purposes);
  • Session identifiers and strictly necessary cookies.
We do not collect special categories of personal data under Article 9 GDPR.

3. LEGAL BASES FOR PROCESSING
We process your personal data under the following legal bases:
  • Performance of a contract – when necessary to provide you with requested information or services.
  • Legal obligation – when required to comply with applicable laws.
  • Legitimate interest – to maintain website functionality and security.

4. PURPOSES OF PROCESSING
Your personal data is processed solely for the following purposes:
  • Operating, maintaining, and securing the Website;
  • Responding to inquiries and communications;
  • Providing requested information or services;
  • Preventing fraud, abuse, and unauthorised access;
  • Complying with legal and regulatory obligations.
We do not use personal data for unsolicited marketing, behavioural profiling, or automated decision-making with legal or similarly significant effects.

5. DATA RETENTION
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law.
  • If you contact us, we store your data for up to 12 months after our last communication, unless legal requirements demand longer storage.
  • After the retention period expires, your data will be securely deleted or anonymized.

6. DATA SHARING
We do not sell or rent your personal data. We may share it only in the following limited circumstances:
  • With service providers who assist us in operating our website (under confidentiality agreements)
  • If required by law or court order

7. INTERNATIONAL DATA TRANSFERS
We store and process your data within the European Economic Area (EEA). If a transfer outside the EEA becomes necessary, we will ensure appropriate safeguards (such as EU Standard Contractual Clauses) are in place.

8. HOW WE PROTECT YOUR INFORMATION
We use technical and organizational security measures to protect your data from unauthorized access, disclosure, alteration, or destruction. However, no system is 100% secure.

9. YOUR GDPR RIGHTS
Under GDPR, you have the right to:
  • Access your personal data
  • Rectify inaccurate data
  • Erase your data (“right to be forgotten”)
  • Restrict processing
  • Object to processing at any time
  • Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
  • Request data portability
To exercise your rights, contact us at: info@approyal.io. We will respond within the statutory period.

10. COOKIES AND SIMILAR TECHNOLOGIES
The Website uses strictly necessary cookies only. These cookies are essential for:
  • secure navigation;
  • session continuity;
  • load balancing;
  • protection against malicious activity.
These cookies do not enable tracking for analytics, advertising, or profiling purposes.

Under Article 5(3) of the ePrivacy Directive and relevant case law (Planet49, C‑673/17), strictly necessary cookies do not require prior user consent. You may disable cookies in your browser settings; however, this may impair Website functionality.

11. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The “Last updated” date at the top will reflect the latest revision. Significant changes will be posted on this page.

12. CONTACT INFORMATION
If you have questions about this Privacy Policy or your personal data, please contact:

Data Controller: Cyclone Ads Limited
Registered Address: 64, Excalibur, Triq B. Bontadini, Birkirkara, BKR 1737, Malta
Email: info@approyal.io