Privacy Policy
_Last updated: 9 June 2025_
1. Introduction
Welcome to The Cyan Zenith SL ("we", "us", "our"). We operate the ConstellAds contest platform (the "Service") where creators submit advertising videos for brand competitions. Protecting your privacy is central to our mission. This Privacy Policy explains what personal information we collect, how we use it, and the choices you have.
By accessing or using the Service, you acknowledge that you have read this Policy.
2. Data Controller
The Cyan Zenith SL
Rambla de Catalunya 38, 8º 1ª, 08007 Barcelona, Spain
Email: support@constellads.com
3. Categories of Personal Information We Collect
| Category | Examples | Source |
|---|---|---|
| Account data | Name, e‑mail address, phone number, PayPal address, chosen password | Provided by you |
| KYC / tax data (only if required for payouts) | Government ID number, date of birth, postal address, tax form (e.g., W‑9, W‑8BEN) | Provided by you |
| Submission data | Video files, thumbnails, captions, metadata | Provided by you |
| Usage data | Log files, IP address, browser type, pages visited, time spent | Collected automatically |
| Analytics & ad‑tracking data | Cookie ID, device ID, events (page‑view, button‑click), conversion data | Collected via cookies / pixels (see §6) |
| Communication data | Support requests, e‑mail messages, phone recordings (where lawful) | From your communications |
We do not knowingly collect data from persons under 18 years of age.
4. Purposes & Legal Bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Account registration & authentication | (b) Contract performance |
| Administering competitions & paying prizes | (b) Contract performance; (c) Legal obligation (tax/KYC) |
| Customer support & service communications | (b) Contract performance; (f) Legitimate interests |
| Analytics (Service improvement) | (f) Legitimate interests |
| Advertising tracking & attribution | (a) Consent (via cookie banner) |
| Marketing e‑mails (newsletters, competition invites) | (a) Consent; you may opt out any time |
| Compliance, fraud prevention & security | (c) Legal obligation; (f) Legitimate interests |
5. How We Share Your Information
We do not sell or rent your personal information.
We share data only with:
- Service providers acting under written data‑processing agreements (e.g., hosting, cloud storage, email delivery, analytics, payment processors).
- Advertising platforms (Meta, TikTok, Google, Reddit) to run and measure ad campaigns and competitions.
- Legal or regulatory authorities when required by law or to protect our rights.
- Brands that sponsor a competition, but only aggregated or anonymised performance data—not your personal contact details—unless required for prize fulfilment or legal compliance.
6. Cookies, Pixels & Similar Technologies
We use first‑party cookies and third‑party tags to operate the Service, analyse traffic and measure advertising effectiveness.
6.1 Analytics Tools
- Plausible Analytics — page views, events, user flows.
Opt‑out: https://plausible.io/docs/excluding-localstorage or by simply clicking here.
More info: https://plausible.io/data-policy
6.2 Advertising & Attribution Pixels
- Meta Pixel (Facebook/Instagram)
- TikTok Pixel
- Google Ads Conversion Tag
- Google Tag Manager Tag
- Reddit Ads Tag
- Plausible Analytics Tag
These tools place cookies or other identifiers that may track your activity across sites and devices to attribute conversions and optimise campaigns. We rely on your explicit consent obtained through our cookie banner before these cookies are activated.
You can withdraw consent at any time by adjusting Cookie Settings in the footer or clearing cookies in your browser.
7. International Data Transfers
Your data may be processed outside the European Economic Area ("EEA") by our service providers or partners (e.g., servers in the U.S.). When we transfer data internationally, we rely on:
- Adequacy decisions (Art. 45 GDPR) where applicable;
- Standard Contractual Clauses (Art. 46 GDPR) with additional safeguards.
8. Data Retention
We keep personal information only as long as necessary:
- Account data — while your account is active plus five (5) years for audit and tax purposes.
- KYC/tax records — seven (7) years (statutory requirement).
- Submissions — indefinitely, as copyright has been assigned to us (§5 Rules).
When retention lapses, data is deleted or anonymised.
9. Your Rights (GDPR & Other Laws)
- Access — obtain a copy of your data.
- Rectification — correct inaccurate data.
- Erasure — request deletion (may be limited by legal obligations or ongoing competitions).
- Restriction — ask us to suspend processing.
- Portability — receive data in a machine‑readable format.
- Objection — object to processing based on legitimate interests.
- Withdraw consent — at any time for analytics/marketing cookies.
- Lodge a complaint — with the Spanish Data Protection Authority (AEPD) or your local authority.
10. Security Measures
We employ technical and organisational safeguards such as encryption in transit (TLS 1.2+), firewall‑protected networks, role‑based access controls, and regular security audits. No system is 100 % secure; you also play a role by choosing a strong password and keeping it confidential.
11. Communications
We may contact you via:
- E‑mail — account updates, competition status, marketing (if you opt in).
- Phone/SMS — verification, urgent competition matters, payout issues.
You can change communication preferences in Account Settings or by contacting us.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will post the revised version and, if changes are material, notify you via e‑mail or prominent notice on the Service. Continued use after the effective date constitutes acceptance.
13. Contact Us
For privacy questions or requests, e‑mail support@constellads.com or write to:
Attn: Privacy Officer, The Cyan Zenith SL, Rambla de Catalunya 38, 8º 1ª, 08007 Barcelona, Spain.