PRIVACY POLICY

LAST UPDATED: April 13, 2026

TechCompass Limited respects your privacy and values the relationship we have with you. Ensuring a transparent process of personal data processing, which allows you to independently control such processing, holds great significance in building a trustworthy relationship with you. In this regard, the Privacy Policy (the “Privacy Policy”) is developed to provide you with up-to-date information on what we (referred to as “TechCompass Limited” or “we”, “us”, “our”) do with of personal data of our clients, website visitors, business partners, and all other individuals whose data we process (“you” or “users”).
We are committed to processing personal data lawfully, fairly and transparently in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Data Protection Act (Chapter 586 of the Laws of Malta) and other applicable data protection and privacy laws.
Personal Data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier (including an IP address), or to one or more factors specific to that person. Personal data may include, for example, contact details (such as an email address or telephone number) and, where applicable, certain technical data or online identifiers, including cookies, where these can be used to identify an individual.
This Privacy Policy applies to personal data processed by us when you:

• visit and use the website at https://compassads.online/ (the “Website”);
• contact us through the contact form available on the Website;
• communicate with us by email or otherwise in connection with the Website.

If you are located outside Malta and EU, please note that your personal data will be processed in accordance with this Privacy Policy and applicable Maltese law and GDPR. Where mandatory data protection laws in your jurisdiction apply, we will comply with such requirements to the extent applicable.
By using the Website or submitting personal data to us, you acknowledge that you have reviewed this Privacy Policy.
In this Privacy Policy, we have endeavored to answer the following questions as fully as possible in order to disclose all information about the processing of your personal data:
1.   About us
2.   How we collect your personal data?
3.   What personal data do we process, for what purposes, and on what legal basis?
4.   Retention of personal data
5.   Do we share your personal data with third parties?
6.   International transfers
7.   Cookies policy
8.   Your privacy rights
9.   Security measures
10. Are our services designed for children?
11. Changes to the Privacy Policy
12. Links to other websites
 
1. About us
TechCompass Limited, duly incorporated in and registered under the laws of the Republic of Malta, with company registration number C 106389, having a registered office at 64, 'Excalibur', B.Bontadini Street, Birkirkara BKR 1737, Malta, acts as a data controller. It means we determine the purposes and means of the processing of personal data.
Since we are registered under the law of the Republic of Malta, the personal data authority overseeing us regarding the personal data processing is Office of the Information and Data Protection Commissioner (IDPC). You always have the right to make a data protection related complaint at any time to a supervisory authority. You may also contact your local data protection authority. A list of local data protection authorities is available here.
If you have any questions regarding would like to exercise your data protection related rights you can submit your request to our e-mail: info@compassads.online.
2. How we collect your personal data?
We perform the following actions with your personal data: collection, storage, disclosure by transmission and otherwise process personal data as required to fullfill the purposes listed in the Privacy Policy.
We collect personal data in the following ways:
a. when you provide us with personal data.
In some cases, we collect your personal data directly from you. For example, when you fill out a form on our Website.
When you interact with our Website or contact us, we may collect the following categories of personal data:

• Contact information: full name, email address, name of company / organization;
• Communication data: content of messages submitted via our contact form, emails, or other correspondence.

b. when personal data is collected automatically.
There are tools that allow us to collect technical personal data about you when you use our Website. Using these tools, we collect some technical information, information about your use of the Services for such purposes as ensuring the normal functioning of the Website, finding bugs and fixing them, etc.
When you visit our website, we may automatically collect:

• Technical data: IP address, browser type and version, operating system, device identifiers;
• Cookie data: as described in Section 7 (Cookie policy) below.

We do not use your data for advertising, behavioural profiling, newsletter marketing, or analytics/tracking purposes. We do not obtain your personal data from data brokers for marketing purposes.
We do not knowingly collect or process any special categories of personal data (including, but not limited to, genetic data, biometric data, health data, racial or ethnic origin, religious or philosophical beliefs). Therefore, please do not share such personal data with us.

3. What personal data do we process, for what purposes, and on what legal basis?
We process your personal data only when it is necessary to achieve the purpose of the personal data processing and only to the extent necessary to achieve the purpose of the processing. Furthermore, we keep your personal data for a limited period of time and once the processing period has expired, we delete all existing copies of your personal data.
Below we have provided you with a full description of the data processing purposes of the users of the Website, what personal data we process, legal basis of data processing.
 
4. Retention of personal data
We will retain your personal data for as long as needed to provide you our services, unless we are required by law to delete or if we accept your request to delete the personal data pursuant to applicable law (for example in situation when you exercised the “right to be forgotten”). Please note that under certain circumstances, we may be required to retain your personal data for a longer period of time in accordance with applicable law or regulatory requirements. This may include but is not limited to, situations involving legal proceedings, investigations, or government inquiries. We will only retain your personal data for as long as necessary to comply with these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.
When we no longer require your personal data, we will look to delete, destroy, or anonymize it pursuant to our typical procedures. If this is not possible (for example, because your personal data has been stored in backup archives), then we will apply security measures to your personal data and isolate it from any further processing until deletion or destruction can occur pursuant to our typical procedures. If we anonymize your personal data (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

5. Do we share your personal data with third parties?
In certain cases, we may share your personal data with third parties. We do this only in the situations described in this Privacy Policy. In any case, we strive to transfer your personal data in a secure manner and, if required by applicable law, based on an agreement between us and each recipient. We will make all reasonable efforts to ensure that each recipient understands the principles of the data protection directive and complies with them in accordance with the law and/or the specific agreement.
We share your personal data to third-party as follows:
(i) to third parties as required by law
We may share your personal data in cases where we are required to do so by law, by court order, or in other situations where we have reasonable grounds to believe that the transfer of your personal data is necessary to initiate legal proceedings in the event of a violation any applicable laws. We may also share your personal data if we have reasonable grounds to believe that it is necessary to prevent fraud or other activities that are contrary to applicable law.
(ii) to accomplish the purposes set forth above
We always strive to improve our Services to provide you with the best user experience. In some cases, to achieve processing goals, we collaborate with partners who assist us in various aspects of our Services, thereby enhancing their quality.
In each case, we carefully select partners to collaborate with and ensure that such companies implement adequate legal, organizational, and technical measures to protect personal data from unauthorized access. However, despite our careful vetting of our partners, it is important to understand that we cannot guarantee absolute compliance with data protection laws in all cases.
We transfer your personal data to the following categories of recipients:
a. Hosting providers
We are diligent in safeguarding your personal data and only use trusted partners to store your personal data. Although hosting providers may have access to the personal data we store, we enter into personal data processing agreements with them that require them to treat it in accordance with relevant privacy laws and regulations.
b. Third parties providing website maintenance, security and technical support services
We engage carefully selected third-party service providers to ensure the proper functioning, security and ongoing maintenance of the Website. These providers may assist us in diagnosing technical issues, maintaining system performance, ensuring security, and providing technical support where required. In this context, they may have limited access to personal data strictly as necessary to perform their services on our behalf and are contractually bound to process such data only in accordance with our instructions and applicable data protection laws.
Each time before transferring your personal data to new counterparties, we:

• assess the level of adequacy of personal data protection by such third-party service providers;
• enter into a Data Processing Addendum with such third-party service providers.

Although we carefully screen our partners, it is important to recognize that we cannot guarantee absolute compliance with data protection legislation in all cases.
We do not sell personal data. We do not share personal data with advertising networks or newsletter/marketing platforms for promotional communications.

6. International transfers
We primarily store and process personal data within the European Economic Area (“EEA”). However, in the course of operating our Website and using certain service providers (for example, hosting, email, IT support, or security providers), personal data may be accessed from, transferred to, or stored in countries outside the EEA.
Where personal data is transferred to a country that is the subject of an adequacy decision adopted by the European Commission, we rely on that adequacy decision as the lawful transfer mechanism. The European Commission maintains and updates the list of jurisdictions and frameworks recognised as providing an adequate level of protection.
Where personal data is transferred to a country that is not covered by an adequacy decision, we will only transfer such data where appropriate safeguards are in place in accordance with Chapter V GDPR. Depending on the circumstances, these safeguards may include, in particular, the European Commission’s Standard Contractual Clauses (“SCCs”), and, where required, supplementary technical, contractual and organisational measures designed to ensure that the transferred personal data continues to benefit from a level of protection essentially equivalent to that guaranteed under EU law.
Before making a restricted transfer, we assess the nature of the transfer, the recipient, the destination country, and whether additional measures are required in light of the applicable legal and practical circumstances.
If you have any questions regarding a possible transfer of personal data outside of the EEA or would like to exercise your data rights in connection with such a transfer, please contact us at info@compassads.online.

7. Cookies policy
Like most websites, our Website uses cookies. Cookies are small text files stored in your web browser that allow us or third parties to enhance your experience on the Website. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Please note that not only cookies are used for these purposes. Therefore, this section also applies to any similar technologies that store or access information on your device.
The Website uses strictly necessary cookies and similar technologies only. These cookies are essential for the operation, security and core functionality of the Website and do not require consent under applicable rules where they are strictly necessary. Cookies categorized as “necessary” are essential for the proper functioning of the Website and for you to effectively use the features and services it provides. These cookies are crucial in enabling key functionalities such as security, network management, cookie preferences, and accessibility.
The list of necessary cookies are used on the Website:
We do not use:

• analytics cookies;
• performance cookies;
• preference/functionality cookies that are not strictly necessary;
• advertising cookies;
• social media tracking cookies;
• profiling or cross-site tracking technologies.

Below we have described how you can control your cookie settings:
(i) Remove cookies from your device
In order to delete all cookies from your device, you need to follow these steps:

• go to the browser settings on the device;
• clear history, including advanced settings.

Please note that clearing your history in this way will result in the loss of your preferences on other sites, including your saved login preferences and passwords, as well as other personalized website settings.
(ii)     Block cookies
Almost all browsers allow users to block the processing of cookies on all websites. However, a complete block will block, among other things, the processing of necessary cookies, which may lead to incorrect operation of the Website and other websites.
To disable cookies, each browser has its own set of controls available. Please refer to your browser’s help menu for further instructions:
·     Google Chrome
·     Internet Explorer
·     Mozilla Firefox
·     Safari (Desktop)
·     Safari (Mobile)
·     Opera
·     Opera Mobile

8. Your privacy rights
As a data subject, you have some rights associated with the personal data processing. We are committed to upholding these rights and ensuring that you can exercise them effectively, but please keep in mind that GDPR that current legislation, in particular the GDPR, imposes certain restrictions on the exercise of certain rights. For this reason, we will analyze the request to exercise the rights described below on a case-by-case basis for compliance with the law.
Below, you can find the information regarding your rights as a data subject under GDPR:
a. Right of access
You have the right to obtain from us the confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data, as well as other supplementary information.
Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information (or in a commonly used electronic form).
Please note that in some cases, we may charge you a reasonable fee for providing this information based on administrative costs. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.
b. Right to restrict processing
You have the right to restrict processing of your personal data if (a) the accuracy of the personal data is contested by you, (b) the processing is unlawful and you oppose the erasure of the personal data, (c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, and (d) you have objected to processing pending the verification whether the legitimate grounds override this.
We will not process your data (except for storage) unless it is based on consent, or to assert, exercise, or contest legal claims and actions, or to protect the rights of another person or entity, or for reasons of important public interest.
c. Right to erasure of personal data
You can request the deletion or destruction of your personal data in certain circumstances, such as:

• the personal data are no longer required in relation to the purposes for which it was gathered or processed in another way;
• you withdraw your consent concerning processing subject to consent;
• you objects to the processing; etc.

Note, that we can retain your personal data as necessary to comply with our legal obligations or resolve disputes.
Upon receiving your request for erasure, we will assess whether the conditions for erasure are met and, if so, without undue delay delete or anonymize your personal data from our systems and notify any third parties to whom the data have been disclosed.
d. Right to rectification
You have the right to request info@compassads.online to correct your personal data if they are incomplete or inaccurate.
Upon receiving your request for rectification, we will review the accuracy and completeness of your personal data and make any necessary corrections or updates.
e. Right to data portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and, if technically feasible, transmit it to another data controller.
Note that this right applies when we process your personal data with your consent or based on a contract.
Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.
f. Right to object to the processing of your personal data
Where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to the processing on this ground.
Upon receiving your objection to processing, we will not process your personal data unless we can demonstrate that there are compelling legitimate reasons that override your interests, rights, and freedoms, or if it is necessary for legal claims and legal actions.
g. Right to withdraw consent
If personal data processing is based on your explicit consent, you have the right to withdraw your consent at any time.
If we do not have any other legal basis for processing your personal data, we will stop processing it once we receive your request to withdraw consent.
h. Right to lodge a complaint
If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.
Since we are registered under the law of the Republic of Malta, the personal data authority overseeing us regarding the personal data processing is Office of the Information and Data Protection Commissioner (IDPC).
Office of the Information and Data Protection Commissioner (IDPC)
Airways House, Second Floor
High Street, Sliema SLM 1549, Malta
Telephone: +356 2328 7100
Email: idpc.info@idpc.org.mt
You always have the right to make a data protection related complaint at any time to a supervisory authority. You may also contact your local data protection authority. A list of local data protection authorities is available here.
Be aware that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us using the provided contact information:
- via e-mail address: info@compassads.online; or
- atour legal address: 64, 'Excalibur', B.Bontadini Street, Birkirkara BKR 1737, Malta.
Please note we may deny a request under certain circumstances, in particular if we are unable to verify your identity or locate your information on our systems. If we are unable to fulfill all or part of your request, we will explain our reasons for denying the request.
We will review your request as soon as possible, but not more than within one (1) month. Please keep in mind that this period may be extended for an additional two (2) months, if necessary, based on the complexity and number of your requests. In that case, we will tell you about the extension within one (1) month of receipt of your request and explain the reasons for the delay.

9. Security measures
We implement reasonable and appropriate technical and organizational measures to protect the security of your personal data against accidental or unlawful destruction, loss, change or damage. The following measures are implemented:

• Measures of pseudonymisation and encryption of personal data;
• Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
• Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing;
• Measures for the protection of data during transmission;
• Measures for the protection of data during storage;
• Measures for internal IT and IT security governance and management;
• Measures for ensuring data minimisation;
• Measures for ensuring data quality;
• Measures for ensuring limited data retention;
• Measures for ensuring accountability;
• Measures for allowing data portability and ensuring erasure.

10. Are our services designed for children?
Our Services are not intended for children. We do not knowingly collect or request personal data from individuals under the age of 16, and we do not allow such individuals to use our Website. If you are under the age of 16, please refrain from providing us with any personal data. If we become aware that we have inadvertently collected personal data from a person under the age of 16, we will promptly delete it. If you believe that we may have personal data about or from someone under the age of 16, please contact us using the provided contact information.

11.Changes to the Privacy Policy
This Privacy Policy may be changed from time to time due to the implementation of new technologies, laws’ requirements or for other purposes. Your continued use of the Website after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously).

12. Links to other websites
The Website may, from time to time, contain links to external websites or online resources that are operated by third parties and are not under our control.
If you follow a link to a third-party website, please note that such website is governed by its own privacy policy and terms of use. We do not control, and are not responsible for, the content, privacy practices, or data processing activities of any third-party websites or services.
This Privacy Policy applies only to personal data collected through the Website and in connection with our services. It does not apply to information collected by third parties, whether online or offline, even if accessed via links on the Website. We encourage you to review the privacy policies of any third-party websites you visit.