Privacy Policy

Last updated: May 2026

1. Who We Are

This website, kirovads.com, is operated by KINTITY LTD, a private limited company incorporated in England and Wales, trading as KirovAds. KINTITY LTD is the data controller responsible for your personal data.

We are subject to the UK General Data Protection Regulation (UK GDPR) as implemented by the Data Protection Act 2018. Where we process personal data of individuals in the European Union, we also comply with the EU GDPR (Regulation (EU) 2016/679).

2. Data We Collect

We collect personal data in the following ways:

2.1 Audit Request Form

When you submit our free audit request form, we collect:

• Full name
• Email address
• Phone number (optional)
• Company name
• Industry / business type
• Approximate monthly advertising budget
• Advertising platforms currently used
• Description of your main marketing challenge
• How you heard about us
• Consent confirmation (GDPR checkbox)

2.2 Analytics & Usage Data

We automatically collect anonymised and aggregated data about how visitors use our website, including pages visited, time on page, referral source, device type, and approximate geographic location. This is collected via Google Analytics 4 (GA4) through Google Tag Manager.

2.3 Advertising & Conversion Data

If you have interacted with our advertising on Meta (Facebook/Instagram) or Google, we may receive anonymised conversion signals to measure advertising performance. This data is processed in accordance with Meta's and Google's data policies.

2.4 Cookies & Browser Data

We use cookies and similar technologies. See Section 5 for full details.

2.5 Language Preference

We store your language preference (English or Bulgarian) in your browser's local storage under the key kirovads_lang. This is not a cookie and does not transmit data to any server.

3. How We Use Your Data

Purpose	Data used	Legal basis
Respond to your audit request and provide consultancy services	Name, email, phone, company, audit details	Legitimate interests / pre-contractual steps
Follow up on your enquiry	Name, email, phone	Legitimate interests
Improve our website and services	Anonymised analytics data	Legitimate interests
Measure advertising campaign effectiveness	Conversion events (anonymised)	Legitimate interests / consent
Comply with legal obligations	As required by law	Legal obligation

We do not sell your personal data. We do not use your data for automated decision-making or profiling that produces legal or significant effects.

4. Legal Basis for Processing

We rely on the following lawful bases under UK GDPR / EU GDPR Article 6:

• Legitimate interests (Article 6(1)(f)): Responding to audit requests, following up on enquiries, website analytics, and measuring advertising performance. We have conducted a legitimate interests assessment and are satisfied that our interests are not overridden by your rights and freedoms.
• Pre-contractual steps (Article 6(1)(b)): Processing necessary to take steps prior to entering a service agreement.
• Consent (Article 6(1)(a)): Marketing cookies and advertising pixels, where we request your consent via our cookie banner.
• Legal obligation (Article 6(1)(c)): Where processing is required to comply with applicable law.

You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. To withdraw consent, contact us at geno@kirovads.com or clear your browser cookies and local storage.

5. Cookies & Tracking Technologies

We use the following categories of cookies and tracking technologies:

Category	Technology / Cookie	Purpose	Duration
Functional	Local storage: kirovads_lang	Remembers your language preference (EN/BG)	Until cleared
Analytics	Google Analytics 4 (_ga, _ga_*)	Website usage analytics — pages viewed, session duration, referral source	Up to 2 years
Marketing	Meta Pixel (_fbp, _fbc)	Measures Meta Ads conversion performance	90 days
Marketing	Google Ads (_gcl_au, FPLC)	Measures Google Ads conversion performance	90 days

All cookies except functional local storage are loaded via Google Tag Manager (GTM). Analytics and marketing cookies are only fired after consent is given (where applicable under applicable law).

You can manage or withdraw consent for non-essential cookies at any time by clearing your browser cookies or adjusting your browser settings. Note that disabling certain cookies may affect site functionality.

6. Third-Party Services & Data Processors

We engage the following third-party data processors who may process personal data on our behalf:

Service	Provider	Purpose	Privacy Policy
Google Tag Manager	Google LLC, USA	Tag management — loads analytics and advertising scripts	policies.google.com/privacy
Google Analytics 4	Google LLC, USA	Website analytics	policies.google.com/privacy
Meta Pixel & Conversions API	Meta Platforms, Inc., USA	Advertising conversion measurement	facebook.com/policy.php
Google Ads Conversion Tracking	Google LLC, USA	Advertising conversion measurement	policies.google.com/privacy
Formspree	Formspree, Inc., USA	Processes and transmits audit request form submissions	formspree.io/legal/privacy-policy
Google Fonts	Google LLC, USA	Loads the Inter typeface	policies.google.com/privacy

We have Data Processing Agreements in place with all processors where required. We do not authorise these processors to use your data for their own purposes beyond what is necessary to provide the service.

7. International Data Transfers

Several of our third-party processors (Google, Meta, Formspree) are based in the United States. These transfers are safeguarded by one or more of the following mechanisms:

• UK Adequacy Regulations — transfers approved by the UK Secretary of State
• Standard Contractual Clauses (SCCs) — as approved by the European Commission and adopted by the UK ICO
• EU–US Data Privacy Framework — where the recipient is certified

You may request a copy of the relevant transfer mechanism by contacting us at geno@kirovads.com.

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Audit request form data: Retained for up to 2 years from the date of submission, or longer if a service agreement is entered into (in which case, standard accounting and contractual retention periods apply — typically 7 years).
• Google Analytics data: 14 months (GA4 default retention setting).
• Advertising conversion data: As per Meta and Google retention policies (typically 90 days for click-through data).
• Email correspondence: Retained for the duration of the business relationship plus 2 years.

When data is no longer needed, it is securely deleted or anonymised.

9. Your Rights

Under UK GDPR and EU GDPR, you have the following rights regarding your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten") — request deletion of your data where there is no compelling reason to continue processing.
• Right to restrict processing — request that we limit the processing of your data in certain circumstances.
• Right to data portability — receive your data in a structured, machine-readable format and transmit it to another controller.
• Right to object — object to processing based on legitimate interests.
• Right to withdraw consent — where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at geno@kirovads.com. We will respond within 30 days. We may need to verify your identity before fulfilling a request.

Supervisory Authority Complaints

If you are based in the United Kingdom and believe we have not handled your data lawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Helpline: 0303 123 1113

If you are based in Bulgaria or another EU member state, you may also lodge a complaint with the relevant national data protection authority. In Bulgaria, this is the Commission for Personal Data Protection (КЗЛД / CPDP):

• Website: cpdp.bg
• Address: 2 Prof. Tsvetan Lazarov Blvd, Sofia 1592, Bulgaria

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The "Last updated" date at the top of this page will be revised accordingly. We encourage you to review this policy periodically.

For material changes that affect how we process your data, we will take reasonable steps to notify you (for example, by email if you have an ongoing relationship with us).

11. Contact Us

For any questions, requests or concerns about this Privacy Policy or our data practices, please contact:

We aim to respond to all requests within 30 days of receipt.