Privacy Policy
Introduction
Pay2Win Agency ("Company," "we," "us," "our," or "Service Provider") is committed to protecting your privacy and ensuring you have a positive experience on our website and when using our services. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal information in connection with our marketing and recruitment services.
This Privacy Policy applies to information we collect through:
• Our website (https://pay2win.agency/)
• Our marketing services and lead generation platforms
• Our recruitment and talent sourcing services
• Our email communications
• Third-party advertising and marketing channels
Please read this Privacy Policy carefully. If you do not agree with our privacy practices, please do not use our services. By accessing our website or using our services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy.
1. Information We Collect
1.1 Information You Provide Directly
Contact Information: When you fill out our inquiry form or contact us, we collect information such as:
• Full name
• Email address
• Phone number
• Company name and website
• Job title and position
• Business description and industry
• Service preferences (marketing, recruiting, or both)
• Budget and timeline information
• Any messages or communications you send us
Payment and Transaction Information: If you engage our paid services, we collect:
• Invoice and billing details
• Payment method information (processed securely through third-party payment processors)
• Transaction history and receipts
• Service agreement details
Recruitment Data: If you register as a job candidate or apply for positions, we collect:
• Resume/CV
• Work experience and education history
• Professional certifications and qualifications
• LinkedIn profile or other professional social media links
• Video interview recordings and transcriptions
• Interview notes and assessments
• Background check information (only with consent)
1.2 Information Collected Automatically
Website Usage Information:
• IP address and device identifiers
• Browser type and operating system
• Pages visited and time spent on each page
• Referral sources and click patterns
• Search queries and interaction data
• Device information (hardware model, mobile network information)
Cookies and Tracking Technologies: We use cookies, pixels, and similar technologies to collect data about your browsing behavior. See Section 8 for more details.
1.3 Information from Third Parties
We may receive information about you from:
• Lead generation platforms (Google Ads, Meta Ads, TikTok Ads, Taboola, etc.)
• Job boards and recruitment platforms (LinkedIn, Djini, Indeed, Fiverr, Upwork)
• Publicly available sources and business databases
• Business partners and referral partners
• Social media platforms
• Data enrichment services
1.4 Special Categories of Data
We do not intentionally collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification, or health data) except where:
• Necessary for recruitment purposes (with explicit consent)
• Required by law
• You explicitly provide such information
2. How We Use Your Information
2.1 Marketing and Lead Generation Services
We use information to:
• Generate and deliver qualified leads to your business
• Create and manage targeted advertising campaigns
• Personalize marketing messages and content
• Test and optimize campaign performance
• Report on campaign metrics and ROI
• Conduct market research and analysis
• Identify patterns and trends in customer behavior
• Improve our service offerings
2.2 Recruitment and Talent Services
We use information to:
• Source and identify qualified candidates
• Conduct preliminary screening and assessments
• Schedule and conduct interviews
• Evaluate candidate qualifications and fit
• Facilitate communication between candidates and employers
• Perform background checks (with explicit consent)
• Maintain candidate databases for future opportunities
• Provide recruitment analytics and reporting
2.3 General Business Operations
We use information to:
• Provide and improve our services
• Respond to your inquiries and customer support requests
• Send service-related announcements and updates
• Process invoices and manage billing
• Maintain accurate records and fulfill our contractual obligations
• Prevent fraud and ensure security
• Comply with legal obligations
• Establish and defend legal claims
2.4 Marketing Communications
With your consent, we may use your email address and phone number to send you:
• Promotional offers and special deals
• Case studies and success stories
• Industry news and insights
• Service updates and new features
• Webinars and educational content
You can opt-out of marketing communications at any time by clicking the "unsubscribe" link in our emails or contacting us directly.
2.5 Analytics and Improvement
We analyze how our website and services are used to:
• Understand user preferences and behavior
• Improve user experience and interface design
• Troubleshoot technical issues
• Develop new features and services
• Monitor service performance and reliability
3. Legal Basis for Processing
We process your personal information based on the following legal grounds:
• Contract: Processing necessary to perform our services agreement with you (e.g., lead generation, recruitment services)
• Consent: Processing with your explicit consent (e.g., marketing emails, interview recordings, background checks)
• Legitimate Interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, service improvement, analytics)
• Legal Obligation: Processing required by law or regulation (e.g., tax reporting, compliance with government requests)
• Vital Interests: Processing necessary to protect vital interests of individuals or public
4. How We Share Your Information
4.1 With Our Clients
For our marketing services, we share lead information with the client businesses who have engaged our services. We maintain strict contractual obligations regarding data use.
4.2 With Recruiting Clients
For recruitment services, we share candidate information (resume, interview notes, assessments) with the hiring companies. Candidates are informed when their information will be shared.
4.3 With Service Providers
We may share information with third-party service providers who assist us with:
• Advertising platforms (Google Ads, Meta, TikTok, Bing, Taboola, Apple Search)
• Email marketing and communication services
• Payment processing and billing
• Data analytics and reporting tools (Google Analytics, Mixpanel, Tableau)
• Customer relationship management (CRM) systems
• Cloud hosting and storage providers
• Video conferencing and recording services
• Background check and verification services
We ensure these service providers have contractual obligations to protect your data and use it only for specified purposes.
4.4 Business Partners
We may share information with:
• Affiliate networks and referral partners
• Co-marketing partners
• Strategic business partners
4.5 Legal Compliance and Safety
We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to:
• Comply with legal obligations, court orders, or governmental requests
• Enforce our Terms of Service and other agreements
• Protect against fraud, security threats, or illegal activities
• Protect the rights, property, and safety of Pay2Win Agency, our users, and the public
4.6 Business Transfers
If Pay2Win Agency is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.
4.7 Aggregated and De-identified Information
We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for marketing, analytics, research, and other purposes without restriction.
5. Data Retention
5.1 Retention Periods
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law. Specific retention periods include:
• Client contact and project information: Duration of contract + 3 years (for accounting and tax purposes)
• Lead information: As agreed with client, typically 1-2 years
• Candidate information: Duration of recruitment process + 1 year (for future opportunities with consent)
• Website cookies and analytics: Up to 2 years
• Email communications: Duration of business relationship + 3 years
• Payment and billing records: Duration of contract + 7 years (legal requirement)
5.2 Deletion of Information
When information is no longer needed, we securely delete or anonymize it. You may request deletion of your information at any time, subject to legal retention obligations.
6. Your Privacy Rights
6.1 Right to Access
You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used, machine-readable format within 30 days of your request.
6.2 Right to Correction
You have the right to request that we correct inaccurate, incomplete, or outdated personal information. We will make corrections within 30 days of verification.
6.3 Right to Deletion (Right to Be Forgotten)
You have the right to request deletion of your personal information, except where:
• We are required to retain data by law
• The data is necessary to complete your service request or contract
• We have a legitimate business interest in retaining the data
• The data is needed for legal or dispute resolution purposes
6.4 Right to Restrict Processing
You have the right to request that we restrict how we process your information while we verify its accuracy or assess our legitimate interests.
6.5 Right to Data Portability
You have the right to request that we provide your personal information in a portable format so you can transfer it to another service provider.
6.6 Right to Object
You have the right to object to:
• Marketing communications (you can opt-out at any time)
• Processing based on legitimate interests
• Automated decision-making and profiling
6.7 Right to Withdraw Consent
Where we process your information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing before the withdrawal.
6.8 Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection authority in your jurisdiction if you believe we have violated your privacy rights.
6.9 How to Exercise Your Rights
To exercise any of these rights, please contact us using the information in Section 12. We will respond to your request within 30 days. You may be asked to verify your identity before we process your request.
7. Data Security
7.1 Security Measures
We implement comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction, including:
• SSL/TLS encryption for data in transit
• Encryption of sensitive data at rest
• Secure password policies and multi-factor authentication
• Regular security audits and penetration testing
• Access controls and role-based permissions
• Firewalls and intrusion detection systems
• Secure data centers and backup procedures
• Employee training on data security and privacy
7.2 Data Breach Notification
In the event of a data breach that compromises your personal information, we will:
• Notify affected individuals within 72 hours (as required by law)
• Provide information about the nature of the breach
• Describe measures we are taking to address the breach
• Provide contact information for questions and support
7.3 Limitations
While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of any passwords or authentication credentials you use.
8. Cookies and Tracking Technologies
8.1 What Are Cookies?
Cookies are small text files stored on your device that help us remember your preferences and understand how you use our website.
8.2 Types of Cookies We Use
Essential Cookies (necessary for basic website functionality):
• Session management and user authentication
• Security and fraud prevention
• Load balancing and performance
Analytics Cookies (help us understand how visitors use our website):
• Google Analytics (GA4)
• Mixpanel
• Custom analytics tracking
Marketing Cookies (used for targeted advertising and remarketing):
• Facebook/Meta pixel
• Google Ads conversion tracking
• TikTok pixel
• LinkedIn Insight Tag
• Other retargeting pixels
Preference Cookies (remember your choices and settings):
• Language preferences
• Theme preferences (light/dark mode)
• Accessibility settings
8.3 Managing Cookies
You can control cookies through your browser settings:
• Accept or reject cookies
• Delete cookies from your device
• Set preferences for specific types of cookies
Note that disabling cookies may limit your ability to use certain features of our website.
8.4 Pixel Tags and Web Beacons
We may use pixel tags and web beacons (small, invisible images) to:
• Track email open rates
• Measure advertising effectiveness
• Conduct analytics and audience analysis
9. Third-Party Links and Services
9.1 External Links
Our website may contain links to third-party websites, including social media platforms, job boards, and advertising networks. We are not responsible for the privacy practices of these external websites. Please review their privacy policies before providing any information.
9.2 Third-Party Services We Use
Our website and services integrate with third-party platforms:
• Squarespace: Website hosting and content management
• Google Services: Analytics, Ads, Search Console
• Meta/Facebook: Advertising and pixel tracking
• LinkedIn: Recruitment and marketing
• Stripe/PayPal: Payment processing
• Email service providers: Mailchimp, SendGrid, or similar
9.3 Advertising Partners
When we display ads or use advertising services, partners may collect information about your browsing behavior. You can opt-out of personalized advertising through:
• Google Ads Settings
• Facebook Ad Preferences
• Your browser's privacy settings
• Industry opt-out mechanisms (Digital Advertising Alliance, Network Advertising Initiative)
10. International Data Transfers
10.1 Global Operations
Pay2Win Agency operates globally, and your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have different data protection laws than your home country.
10.2 Data Transfer Mechanisms
When transferring data internationally, we use appropriate safeguards:
• Standard contractual clauses (SCCs) approved by relevant authorities
• Binding corporate rules
• Your explicit consent
• Other mechanisms permitted by applicable data protection laws
10.3 Ukraine and European Operations
As a company based in Ukraine, we comply with applicable Ukrainian data protection laws and GDPR requirements for processing data of EU residents.
11. Children's Privacy
Our services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected information from a child under 16, we will promptly delete such information and take steps to prevent further collection.
If you believe we have collected information from a child under 16, please contact us immediately using the information in Section 12.
12. Contact Us
Data Protection and Privacy Inquiries
Email: info@pay2win.agency
Website: https://pay2win.agency/
Company Name: Pay2Win Agency
Jurisdiction: Ukraine
How to submit a request:
• Send an email with your request and relevant details
• Include "Privacy Request" in the subject line
• Provide proof of identity (for data subject requests)
• We will respond within 30 days
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
• Posting the updated Privacy Policy on our website
• Updating the "Last Updated" date at the top of this policy
• Sending you an email notification (for significant changes)
Your continued use of our website or services after changes become effective constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.
Your Acknowledgment
By using our website and services, you acknowledge that:
• You have read and understood this Privacy Policy
• You agree to our collection, use, and disclosure of your information as described
• You have the authority to provide any information you share with us
• You understand the risks of transmitting information over the internet
• You will notify us of any changes to your information
Important: This Privacy Policy is subject to our Terms of Service. In case of conflict between this Privacy Policy and the Terms of Service, the more protective provision will apply.
Pay2Win Agency - Privacy Policy
Version 1.0 | Effective Date: May 27, 2026
© 2026 Pay2Win Agency. All rights reserved.