PRIVACY & COOKIE POLICY

Last updated: 1 September 2026

  1. ABOUT ADORA.NETWORK

This Privacy & Cookie Policy explains how Mariia Drozdova, autónoma, operating under the business name Adora.network (“Adora.network”, “Adora”, “we”, “us” or “our”) processes personal data in connection with its advertising technology, programmatic advertising, real-time bidding (“RTB”), publisher monetisation, advertiser services and website.

Controller

Mariia Drozdova, autónoma, operating under the business name Adora.network
Bassegoda 39, 2-3
08028 Barcelona, Spain
Email: mariia@adora.network

Depending on the particular service and processing activity, Adora.network may act as a data controller, joint controller, processor or other service provider. The applicable role depends on the nature of the processing and the relevant contractual and technical arrangements.

  1. SCOPE OF THIS POLICY

This Policy applies to:

  • visitors to the Adora.network website;
  • advertisers and agencies using Adora.network services;
  • publishers and website or application operators using Adora.network monetisation services;
  • users of publisher websites or applications where Adora.network technology is integrated;
  • advertising technology and RTB partners;
  • persons who communicate with Adora.network;
  • other persons whose personal data may be processed in connection with Adora.network’s services.
  1. INFORMATION WE PROCESS

3.1 Users of publisher websites and applications

When Adora.network technology is used on a publisher website or application, information may be processed in connection with an advertising request, auction, advertisement, measurement or security event.

Depending on the technical integration, this may include:

  • IP address;
  • User-Agent;
  • browser type and version;
  • operating system and version;
  • device type and technical characteristics;
  • language and time zone;
  • approximate geographic location inferred from IP address;
  • cookie identifiers;
  • advertising identifiers;
  • other online identifiers;
  • information contained in an RTB bid request;
  • website, application and contextual information;
  • advertising placement information;
  • information concerning advertisements served, viewed or clicked;
  • consent or privacy signals;
  • frequency and timing information;
  • technical and security information;
  • information received from advertising partners where legally permitted.

Some of this information may constitute personal data under applicable data-protection legislation.

Adora.network does not generally require a person’s name, postal address, telephone number or email address to serve programmatic advertising.

3.2 Advertisers and agencies

Where you register for or use Adora.network’s advertiser services, we may process:

  • name;
  • contact person’s name;
  • company name;
  • business email address;
  • telephone number;
  • business address;
  • country;
  • VAT number or company registration information;
  • account information;
  • campaign information;
  • advertising materials;
  • billing and payment information;
  • communications with Adora.network;
  • technical and security information.

We use this information to administer accounts, provide services, communicate with customers, process payments, measure campaigns, provide support, prevent fraud and comply with legal obligations.

3.3 Publishers

Where you use Adora.network’s publisher or monetisation services, we may process:

  • name;
  • contact person’s name;
  • company name;
  • business email address;
  • telephone number;
  • business address;
  • country;
  • VAT number or company registration information;
  • website or application information;
  • account information;
  • traffic and monetisation information;
  • payment and payout information;
  • communications with Adora.network;
  • technical and security information.

3.4 Visitors to the Adora.network website

When you visit the Adora.network website, we may process:

  • IP address;
  • browser information;
  • operating system;
  • device information;
  • pages visited;
  • requested resources;
  • referring website;
  • date and time of access;
  • technical log information;
  • cookies and similar technologies where used.

The Adora.network website is operated using WordPress and hosted using IONOS.

The actual information processed through the website depends on the WordPress configuration, installed plugins and services, and the IONOS hosting configuration.

  1. ADORA.NETWORK’S PROGRAMMATIC ADVERTISING ACTIVITIES

Adora.network operates within the programmatic advertising ecosystem.

Programmatic advertising can involve automated communication between publishers, advertising technology providers, exchanges, DSPs, advertisers, agencies and other participants.

In an RTB transaction, information associated with an advertising opportunity may be transmitted to eligible participants in order to facilitate an advertising auction.

Depending on the applicable integration, this information may include:

  • IP address;
  • User-Agent;
  • device and browser information;
  • approximate location;
  • advertising or cookie identifiers;
  • contextual information;
  • publisher website or application information;
  • advertising placement information;
  • consent signals;
  • campaign and auction information.

Adora.network seeks to limit information to what is necessary for the relevant advertising, technical, measurement or security purpose.

  1. PURPOSES OF PROCESSING

Adora.network may process personal data for the following purposes, depending on the service involved:

Advertising delivery

To facilitate the selection, allocation and delivery of advertisements.

Real-time bidding

To facilitate RTB auctions and communication between participants in the advertising ecosystem.

Contextual and geographic advertising

To support contextual, geographic and technical advertising parameters where legally permitted.

Personalised advertising

Where legally permitted and where the required legal basis, including consent where applicable, has been obtained.

Frequency capping

To help control how frequently advertisements are displayed to a browser or device.

Campaign measurement

To measure impressions, clicks, conversions and other advertising performance indicators.

Reporting

To provide advertisers, agencies, publishers and other business partners with relevant reporting and statistics.

Fraud and invalid-traffic prevention

To identify and prevent fraudulent, automated, malicious or otherwise invalid advertising activity.

Security

To protect Adora.network’s systems, services and partners against abuse, attacks and unauthorised activity.

Technical operation

To operate, troubleshoot and maintain Adora.network’s technology and website.

Account administration

To create and manage advertiser and publisher accounts.

Customer support

To communicate with advertisers, publishers, partners and other persons who contact Adora.network.

Payments and accounting

To process invoices, payments and publisher payouts and comply with accounting obligations.

Legal compliance

To comply with applicable laws, regulatory requirements, court orders and lawful requests from public authorities.

  1. ADORA.NETWORK’S TECHNOLOGY AND SERVICE PROVIDERS

Adora.network currently uses the following principal technology and infrastructure providers.

Provider

Role

Main purpose

AdKernel

Advertising technology / SaaS provider

Provides the underlying advertising technology and infrastructure used by Adora.network for programmatic advertising and related advertising operations.

WordPress

Website / CMS

Provides the content-management platform used for the Adora.network website.

IONOS

Hosting / infrastructure

Provides hosting and related technical infrastructure for the Adora.network website.

These providers are described below.

6.1 AdKernel

Adora.network uses AdKernel as its advertising technology and SaaS provider.

AdKernel’s platform may support advertising functions including ad serving, programmatic advertising and related advertising operations.

Depending on the services and configuration used by Adora.network, AdKernel’s technology may process information associated with:

  • advertising requests;
  • advertisements;
  • publishers;
  • advertisers;
  • browsers;
  • devices;
  • IP addresses;
  • User-Agent information;
  • advertising or cookie identifiers;
  • contextual information;
  • consent or privacy signals;
  • advertising interactions;
  • security and fraud-prevention information.

AdKernel’s own privacy documentation states that its platform and related partners may use cookies, web beacons, tags, scripts, advertising identifiers and similar technologies, and that its ecosystem may involve processors, sub-processors and third-party partners.

The precise data processed by AdKernel on behalf of or in connection with Adora.network depends on the services and technical configuration actually enabled for Adora.network.

Adora.network does not represent that every feature described in AdKernel’s public documentation is enabled or used by Adora.network.

6.2 WordPress

Adora.network uses WordPress as the content-management system for its website.

WordPress provides website-management functionality and may involve cookies or similar technologies depending on the WordPress installation, theme, plugins and services used.

WordPress documentation confirms that WordPress websites may use both first-party and third-party cookies, and that the actual cookies depend on the services and configuration of the website.

Adora.network will therefore maintain its cookie inventory based on the actual WordPress installation and the plugins and third-party services currently enabled.

6.3 IONOS

Adora.network uses IONOS for website hosting and related infrastructure.

IONOS states that its web-hosting products may process technical information relating to website visitors, including information such as requested resources, browser type, operating system, device type, access time, referrer and IP information, depending on the applicable hosting product.

The exact processing applicable to Adora.network depends on the specific IONOS hosting product and configuration used.

  1. OTHER ADVERTISING PARTNERS AND RECIPIENTS

Adora.network may communicate or make relevant information available to participants in the advertising ecosystem.

These may include:

  • DSPs;
  • SSPs;
  • ad exchanges;
  • advertisers;
  • advertising agencies;
  • media-buying companies;
  • RTB technology providers;
  • measurement and attribution providers;
  • fraud and invalid-traffic prevention providers;
  • analytics providers;
  • consent-management providers;
  • security providers;
  • hosting and infrastructure providers;
  • payment providers;
  • professional advisers;
  • customer-support providers;
  • competent authorities where legally required or permitted.

The identity of advertising counterparties may vary depending on the publisher, campaign, auction, geographic market, advertising opportunity and technical integration.

For this reason, Adora.network uses named providers where their role is stable and known, such as AdKernel, WordPress and IONOS, while describing changing advertising counterparties by category.

Adora.network will not represent a company as an Adora.network partner merely because that company is part of the wider programmatic advertising ecosystem.

  1. DATA SHARING IN RTB

Where technically and legally necessary, Adora.network may transmit relevant information to advertising ecosystem participants for the purpose of facilitating an advertising transaction.

The information shared depends on the relevant integration and may include:

  • IP address;
  • User-Agent;
  • device information;
  • advertising identifiers;
  • contextual information;
  • geographic information;
  • consent signals;
  • advertising placement information;
  • campaign and auction information.

Adora.network seeks to limit such information to what is relevant to the applicable advertising transaction and permitted under applicable law.

  1. COOKIES AND SIMILAR TECHNOLOGIES

Adora.network may use cookies and similar technologies, including:

  • browser cookies;
  • local storage;
  • pixels;
  • web beacons;
  • tags;
  • scripts;
  • advertising identifiers;
  • server-side identifiers;
  • similar technical technologies.

These technologies may be used for:

  • technical functionality;
  • security;
  • fraud prevention;
  • remembering privacy choices;
  • advertising delivery;
  • frequency capping;
  • advertising measurement;
  • analytics;
  • other purposes described in this Policy.

The actual technologies used depend on the relevant website, advertising service and technical configuration.

  1. COOKIE CATEGORIES

Strictly necessary technologies

Technologies necessary for the website or service to function, maintain security or provide a functionality specifically requested by the user.

Where an applicable legal exemption exists, these technologies may be used without consent.

Advertising technologies

Technologies used for advertising delivery, targeting, frequency capping or related advertising functions.

Where consent is legally required, these technologies will only be used following valid consent.

Measurement and analytics technologies

Technologies used to measure traffic, advertising performance or technical operation.

Security and fraud-prevention technologies

Technologies used to detect suspicious activity, invalid traffic, abuse or security threats.

  1. COOKIE CONSENT

Where applicable law requires consent for cookies or similar technologies, Adora.network will seek valid consent before activating those technologies.

Consent must be:

  • freely given;
  • specific;
  • informed;
  • based on a clear affirmative action;
  • capable of being withdrawn.

For users in Spain, AEPD guidance states that applicable cookie consent must be valid and informed and that the options to accept and reject should be presented at the same time, at the same level and with the same visibility.

Continued browsing alone will not be treated as consent where valid consent is required.

  1. CONSENT MANAGEMENT PLATFORM

The consent-management solution used by Adora.network, if any, may be provided by a third party.

If a CMP is introduced or enabled, Adora.network will update its vendor and cookie inventory to identify the relevant provider.

Where Adora.network’s technology operates on a publisher’s website or application, the publisher may be responsible for operating the applicable consent-management mechanism and transmitting the relevant consent or privacy signal.

  1. COOKIE AND IDENTIFIER INVENTORY

The following table identifies the currently known technology providers. It deliberately does not invent specific cookie names or retention periods that have not been verified against Adora.network’s actual production configuration.

Provider / technology

Purpose

Technology type

Retention

Consent

AdKernel

Programmatic advertising / ad serving / related advertising functions

Cookies, identifiers or similar technologies where enabled

Configuration-dependent

Depends on purpose and applicable law

WordPress

Website functionality

Cookies / similar technologies where enabled

Configuration-dependent

Depends on purpose and applicable law

IONOS

Hosting and technical operation

Server-side technical processing / logs

Product/configuration-dependent

Depends on applicable law

Other WordPress plugins/services

Function-specific

Configuration-dependent

Configuration-dependent

Configuration-dependent

Adora.network will maintain an internal technical inventory containing the actual cookie or identifier name, provider, purpose, duration and consent status.

  1. ADVERTISING CHOICES

Depending on the relevant website, application and technology, users may be able to control advertising-related processing through:

  • a consent-management interface;
  • browser settings;
  • device advertising settings;
  • available advertising-industry opt-out mechanisms;
  • other mechanisms made available by Adora.network or its partners.

Because some advertising identifiers and cookies are browser- or device-specific, deleting cookies or changing browser settings may affect the persistence of privacy choices.

  1. LEGAL BASES

Depending on the processing activity, Adora.network may rely on:

  • consent;
  • performance of a contract;
  • legitimate interests;
  • compliance with a legal obligation;
  • another lawful basis recognised by applicable law.

Where consent is legally required for advertising cookies or similar technologies, Adora.network will not treat legitimate interests as a replacement for that required consent.

Adora.network’s legitimate interests may include operating and securing its business, preventing fraud, maintaining technical infrastructure, providing requested services, measuring service performance and defending legal claims, provided that the applicable legal requirements are satisfied.

  1. PROFILING AND AUTOMATED PROCESSING

Programmatic advertising involves automated processing.

Systems may automatically evaluate information associated with an advertising opportunity and determine whether an advertisement or bid is eligible for an auction.

Factors may include:

  • geographic information;
  • device characteristics;
  • browser characteristics;
  • contextual information;
  • advertising identifiers;
  • frequency information;
  • campaign parameters;
  • security and fraud indicators.

This processing is generally used to facilitate advertising, measurement, optimisation, security or fraud prevention.

Adora.network does not intend such processing to produce legal or similarly significant effects concerning individuals.

  1. DATA MINIMISATION

Adora.network seeks to process information that is relevant and proportionate to the purposes described in this Policy.

Adora.network does not intentionally seek to collect special categories of personal data for ordinary programmatic advertising purposes.

Advertisers, publishers and other partners should not transmit unnecessary sensitive personal data through Adora.network’s advertising technology.

  1. DATA RETENTION

Adora.network retains personal data only for as long as reasonably necessary for the relevant purpose.

Retention periods may depend on:

  • the type of data;
  • the purpose of processing;
  • technical requirements;
  • contractual obligations;
  • fraud and security requirements;
  • accounting requirements;
  • legal obligations.

Different systems and providers may therefore have different retention periods.

Adora.network does not adopt the retention periods of AdKernel, IONOS, WordPress or any other provider as its own unless those periods actually apply to Adora.network’s processing.

  1. INTERNATIONAL DATA TRANSFERS

Some technology, advertising or service providers used by Adora.network may process information outside Spain or the European Economic Area.

Where personal data is transferred outside the EEA, Adora.network will use an appropriate legal transfer mechanism where required, including, where applicable:

  • an adequacy decision;
  • Standard Contractual Clauses;
  • another lawful transfer mechanism recognised under applicable law.

Appropriate safeguards will be considered where required.

  1. SECURITY

Adora.network takes reasonable technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • accidental loss;
  • destruction;
  • misuse;
  • alteration;
  • unauthorised disclosure.

Security measures may include access controls, authentication, confidentiality obligations, system monitoring, secure infrastructure and appropriate technical safeguards.

No internet-based service can be guaranteed to be completely secure.

  1. CHILDREN

Adora.network’s services are not directed specifically at children.

Adora.network does not knowingly seek to create advertising profiles of children for its ordinary advertising activities.

Because Adora.network’s technology may operate on third-party websites and applications, Adora.network may not always be able to independently determine the age of every person who encounters an advertisement.

Publishers and advertising partners remain responsible for complying with applicable requirements concerning children and age-restricted audiences.

  1. ADVERTISER AND PUBLISHER ACCOUNTS

For advertiser and publisher accounts, Adora.network may process registration, contact, contractual, campaign, technical, billing and payment information.

This information may be used to:

  • create and administer accounts;
  • provide services;
  • communicate with customers;
  • provide support;
  • process invoices and payments;
  • prevent fraud;
  • comply with legal obligations.
  1. PAYMENTS AND PAYOUTS

Where Adora.network makes or receives payments or publisher payouts, relevant information may be processed by Adora.network and applicable payment providers, banks or financial institutions.

Payment providers may process personal data under their own privacy notices and contractual terms.

Adora.network will seek to avoid unnecessarily storing payment-card information where payment processing can be performed securely by a specialised provider.

  1. YOUR DATA PROTECTION RIGHTS

Depending on applicable law, you may have the right to:

  • access your personal data;
  • request rectification;
  • request erasure;
  • request restriction of processing;
  • object to processing;
  • request data portability;
  • withdraw consent;
  • object to direct marketing;
  • exercise applicable rights concerning automated decision-making;
  • lodge a complaint with a supervisory authority.

Requests may be submitted to:

mariia@adora.network

Adora.network may request reasonable information necessary to verify the identity of the requester before responding.

  1. RIGHT TO OBJECT

Where Adora.network processes personal data based on legitimate interests, you may have the right to object to such processing.

You may also have rights to object to direct marketing.

Where advertising technology operates through a publisher website or application, additional choices may be available through that publisher’s consent-management system or other applicable advertising-choice mechanism.

  1. RIGHT TO ERASURE

You may request deletion of personal data where applicable.

Deletion may be limited where Adora.network has a legal obligation to retain information or where retention is necessary to establish, exercise or defend legal claims, prevent fraud, maintain security or comply with another lawful requirement.

  1. THIRD-PARTY WEBSITES AND SERVICES

Adora.network’s website and advertising services may interact with third-party websites, applications, platforms and services.

Those third parties may have their own privacy policies and terms.

Adora.network is not responsible for the independent privacy practices of third parties that operate outside Adora.network’s control.

  1. CHANGES TO THIS POLICY

Adora.network may update this Privacy & Cookie Policy from time to time to reflect:

  • changes to its services;
  • changes to its technology;
  • changes to its providers;
  • changes to applicable law;
  • changes to its business operations.

The latest version will be published on the Adora.network website.

The “Last updated” date indicates the date on which this Policy was most recently revised.

  1. CONTACT

For questions regarding this Privacy & Cookie Policy or the processing of personal data by Adora.network, please contact:

Mariia Drozdova
Adora.network
Bassegoda 39, 2-3
08028 Barcelona
Spain

Email: mariia@adora.network

  1. VENDOR AND TECHNOLOGY INVENTORY

Adora.network’s current confirmed principal technology providers are:

AdKernel

Role: Advertising technology / SaaS provider.

Purpose: Programmatic advertising and related advertising technology infrastructure.

WordPress

Role: Website content-management system.

Purpose: Operation and management of the Adora.network website.

IONOS

Role: Website hosting and infrastructure provider.

Purpose: Hosting, technical infrastructure and website operation.

Adora.network may additionally use advertising ecosystem participants including DSPs, SSPs, ad exchanges, advertisers, agencies, measurement providers, fraud-prevention providers and other RTB vendors.

The identity of these participants may change depending on the advertising transaction and technical integration.

Adora.network will maintain its internal vendor inventory and update this Policy where a material change in providers materially affects the processing of personal data.

  1. IMPORTANT TECHNICAL NOTE

The descriptions in this Policy are intended to accurately describe Adora.network’s services without claiming that a particular cookie, identifier, advertising partner, retention period or technical feature is used when this has not been verified.

The final technical cookie/vendor inventory should be reconciled against the actual production configuration of:

  • AdKernel;
  • WordPress;
  • installed WordPress plugins;
  • IONOS hosting;
  • any analytics tools;
  • any consent-management platform;
  • any advertising or measurement integrations.

This ensures that the published Policy remains consistent with the actual processing performed by Adora.network.