Privacy Policy

Section 1. General Provision
Who we are

Spalah is a venture builder engaged in the creation, support, and development of technology businesses in the areas of AdTech, MarTech, Publishing and Mobile App Development.

As a venture builder, Spalah provides co-founders with operational support, including technology, HR, recruiting, legal, and financial infrastructure. This covers the management of administrative processes, human resources, legal matters, financial accounting, and other operational aspects necessary for the functioning and growth of a business.

This Privacy Policy
This Privacy Policy outlines how Moveads LTD , with registered office Suite 23050 8 Shepherd Market, Mayfair, London, United Kingdom, W1J 7JY (“Spalah” “we,” “our,” or “us”) collects, uses, discloses, and safeguards personal data obtained through your interaction with our website and digital services. It applies to all users who access or use our website, regardless of their location, and governs the data practices related to information collected directly from you or through automated means (e.g., cookies and tracking technologies).

We are committed to handling your personal data responsibly and in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA/CPRA), and similar privacy frameworks in jurisdictions where we operate.

If you have questions about this policy or your personal data, you may contact our Data Protection Officer (DPO) at legal@spalah.tech.

Section II. Personal Information Collected

When you access and browse our website, we may collect certain personal information either automatically or voluntarily.

Cookie Data

When you visit and browse our website, we, along with certain trusted third-party partners, automatically collect information using small data files called "cookies" and similar tracking technologies. These technologies are crucial for how modern websites function and help us remember details about your visit.

What Exactly are Cookies and How Do They Work?

Cookies are small text files placed on your device (such as a computer, smartphone, or tablet) when you visit a website. They do not run programs or carry viruses. Instead, cookies act as unique identifiers that help websites recognize your browser across multiple visits.

Think of cookies as memory tags for your browser. When you visit our website for the first time, we may place a cookie on your device. The next time you return, your browser sends this cookie back to us, allowing us to recall your preferences or actions from your previous session.

We use cookies for a variety of legitimate purposes, all aimed at improving your experience, ensuring the website functions properly, and helping us enhance our services. Below is an explanation of the different types of cookies we use:

Essential/Strictly Necessary Cookies

These cookies are absolutely fundamental for our website to operate correctly. Without them, core functions simply wouldn't work. They enable features like navigating between pages, accessing secure areas (like your account login), remembering items in a shopping cart during your session, or making sure the website loads properly for your device.

You usually can't turn these cookies off in our systems because they're essential for the site's basic operation. If you block them through your browser settings, parts of the website may become unusable.

Functionality Cookies

Functionality cookies remember choices you’ve made (such as language preferences or login details) and provide enhanced, more personalized features. They make your visit smoother by storing settings and preferences. Disabling these cookies may require you to re-enter information every time you visit the site. Disabling them might mean you have to re-enter your preferences each time you visit.

Technical Information

During your visit to our site, we may collect non-identifiable technical information such as IP address, operating system, browser type, and referral sources. This data is used to diagnose issues, maintain site security, and optimize our services. While this data is not currently linked to personally identifiable information, we reserve the right to do so if necessary for legal or security reasons.

!! Our website uses only cookies that are strictly necessary to ensure its proper operation, security, and accessibility. These cookies support essential functions such as enabling core site features, maintaining session stability, and protecting forms from automated misuse. We do not use cookies for analytics, advertising, or profiling purposes.

Contact Forms Data

When you fill out a contact form on our website, we process the information you provide to respond to your inquiry.

Data	Purpose of Processing	Legal Basis	Retention Period
Name	To address you personally	Legitimate interest	Up to 1 year from the date of submission
Email address	To reply to your inquiry	Legitimate interest	Up to 1 year from the date of submission
Phone number	To contact you directly if necessary	Legitimate interest	Up to 1 year from the date of submission
Message content	To understand and respond to your request	Legitimate interest	Up to 1 year from the date of submission
Candidate CV	Recruitment and selection	Legitimate interest	Up to 1 year from the date of submission
Address (for candidates)	To assess the candidate’s ability to work in or relocate to the required location	Legitimate interest	Up to 1 year from the date of submission

Who Can Access Your Personal Data

We may share the collected information with third parties in the following situations:

To service providers, contractors, or third parties who work on our behalf.
To government institutions that may request access to your personal data;
To comply with legal obligations, such as subpoenas or court orders.
To protect our rights and safety, as well as the rights and safety of others.

We have a separate Candidate Policy that applies to individuals who have expressed interest in exploring potential collaboration with Spalah.

Candidate`s policy is available here.

Section III. Data Transfers Outside the European Economic Area (EEA)

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including to jurisdictions that may not provide the same level of data protection as your home country. This may occur when we work with service providers or partners located in other countries, or when using cloud-based platforms.

Whenever we transfer your personal data outside the EEA, we ensure that appropriate safeguards are in place to protect your data. These may include:

Transferring data only to countries that the European Commission has deemed to provide an adequate level of data protection.
Implementing Standard Contractual Clauses (SCCs) approved by the European Commission or other appropriate legal mechanisms that require recipients to protect your data in accordance with EU data protection laws.
Conducting Transfer Impact Assessments where applicable to ensure the legality and security of cross-border data flows.

By using our website or submitting your personal data, you acknowledge and agree to the transfer, processing, and storage of your information outside the EEA, in accordance with this Privacy Policy.

Applicability

This section applies to data subjects located in the EU and EEA whose data is processed by us, regardless of whether the processing takes place within or outside the EU. If you are located in the United Kingdom or Switzerland, similar rights may apply under UK GDPR or the Swiss Federal Act on Data Protection (FADP), respectively.

International Data Transfers

As an international company, Spalah may transfer and process your personal data across international borders, including to and from countries within the European Economic Area (EEA). By accessing and using our Site, you acknowledge and consent to such transfers. We implement appropriate safeguards to ensure that your data is protected in accordance with applicable data protection laws during any cross-border transfer.

If you are a resident of the European Union (EU) or the European Economic Area (EEA), you are entitled to a series of privacy rights under the General Data Protection Regulation (Regulation (EU) 2016/679 – "GDPR"). These rights are designed to give you control over how your personal data is collected, used, stored, and shared.

What Are Your Rights?

You have the following rights:

Right of Access: You have the right to request confirmation as to whether or not personal data concerning you is being processed, and if so, to access such data. This includes information on the purposes of the processing, the categories of data involved, the recipients of the data (especially those in third countries), the data retention period, and your associated rights.
Right to Rectification: You have the right to request correction of inaccurate personal data or to complete incomplete data. We are obligated to make these changes without undue delay.
Right to Erasure ("Right to Be Forgotten"): In certain circumstances, such as when the data is no longer necessary for the purposes it was collected, you may request the deletion of your personal data. This right may be limited where processing is necessary, for example, to comply with a legal obligation or for the establishment, exercise, or defense of legal claims.
Right to Restriction of Processing: You may request that we restrict the processing of your data under specific conditions—for example, if the accuracy of the data is contested or the processing is unlawful and you oppose the erasure of the data.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible and when the processing is based on consent or a contract.
Right to Object: You have the right to object, on grounds relating to your particular situation, to the processing of your personal data that is based on our legitimate interests or for direct marketing purposes. We will stop processing your data unless we demonstrate compelling legitimate grounds that override your interests or for legal claims.
Right to Withdraw Consent: If you have provided consent for data processing, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or the location of the alleged infringement if you believe your data protection rights have been violated.

UK Data Subject Rights

If you are located in the United Kingdom, you are entitled to certain rights under the UK General Data Protection Regulation (UK GDPR). These include the right to access, correct, erase, restrict, or object to the processing of your personal data, as well as the right to data portability and to withdraw consent at any time.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk if you believe your data rights have been violated.

To exercise your rights or ask questions, please contact our Data Protection Officer at legal@spalah.tech or use the Your Privacy Choices link in the website footer.

Policy Towards Children

Our website and services are not intended for, nor directed to, children under the age of 18 (or the minimum legal age in your jurisdiction). We do not knowingly collect, use, or disclose personal data from children without verifiable parental consent. If we discover that we have inadvertently collected personal information from a child without proper consent, we will take immediate steps to delete the data from our records.

If you are a parent or legal guardian and believe that your child has provided personal information to us without your consent, please contact us at legal@spalah.tech. We will promptly review and address the concern in accordance with applicable laws.

Section IV. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, SPALAH, ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AND PARTNERS SHALL NOT BE HELD LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, OR ANY OTHER DAMAGES WHATSOEVER, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, REVENUE, DATA, OR USE, ARISING OUT OF OR RELATED TO YOUR ACCESS TO, USE OF, OR INABILITY TO USE OUR WEBSITE OR SERVICES. THIS INCLUDES DAMAGES RESULTING FROM ERRORS, OMISSIONS, INTERRUPTIONS, DEFECTS, DELAYS IN OPERATION OR TRANSMISSION, COMPUTER VIRUSES, OR OTHER HARMFUL COMPONENTS.

WHILE WE STRIVE TO PROVIDE ACCURATE, SECURE, AND TIMELY INFORMATION, WE MAKE NO WARRANTIES OR REPRESENTATIONS REGARDING THE COMPLETENESS, RELIABILITY, ACCURACY, OR AVAILABILITY OF THE WEBSITE OR ANY CONTENT THEREIN. YOUR USE OF THE WEBSITE AND RELIANCE ON ANY INFORMATION FOUND HERE IS STRICTLY AT YOUR OWN RISK.

SPALAH SHALL NOT BE RESPONSIBLE FOR ANY UNAUTHORIZED ACCESS TO OR ALTERATION, THEFT, OR DESTRUCTION OF YOUR DATA, COMMUNICATIONS, OR OTHER INFORMATION TRANSMITTED VIA OUR WEBSITE. WE RECOMMEND THAT YOU TAKE APPROPRIATE PRECAUTIONS TO PROTECT YOUR DATA AND DEVICES.

THIS LIMITATION OF LIABILITY APPLIES REGARDLESS OF THE LEGAL THEORY UNDER WHICH A CLAIM MAY BE BROUGHT, INCLUDING CONTRACT, TORT, NEGLIGENCE, OR STRICT LIABILITY, AND REGARDLESS OF WHETHER SPALAH HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Section V. Changes to This Privacy Policy

Spalah may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make changes, we will revise the “Last Updated” date at the top of this policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information. Continued use of our website after any updates constitutes your acceptance of the revised policy.

If we make material changes that significantly affect your rights or how we handle your personal data, we will provide a more prominent notice, such as an email notification or a notice on our website, before those changes take effect.