PRIVACY POLICY
Purpose
This policy provides an effective, responsible, and transparent framework to ensure
compliance with the requirements of the General Data Protection Regulation (GDPR).
This Privacy Policy helps all relevant parties understand our principles and conditions
for data processing. Your data is collected, stored, and used by MediaSales Ltd.
(hereinafter referred to as the “Company”), a company registered at Lion Office
Building, Angyalföldi út 5/B, 1134 Budapest, Hungary. Tax number: 13912963241.
This document outlines the types of data we may collect and process when you use
https://pomscloud.ie (the “Website” or “Webpage”), including any of its
subdomains and/or subpages. The data collected on these pages is processed in
accordance with the provisions of this Policy.
Important Information:
● This policy does not apply to third-party websites or applications that direct users
to our Website.
● Please read this policy carefully to understand our data processing practices.
● If you do not agree with this policy, please do not use our Website.
Policy Statement
We are committed to conducting our business in full compliance with all applicable data
protection laws and regulations, as well as upholding the highest ethical standards.
This policy defines the expected behaviour of our employees and third parties regarding
the collection, use, storage, transfer, disclosure, and disposal of personal data. Personal
data refers to any information (including opinions and intentions) related to an identified
or identifiable natural person. Such data is protected by various legal safeguards and
regulations that restrict how organisations may process it.
An organisation that processes personal data and determines how it is used is classified
as a Data Controller. As a Data Controller, we are responsible for ensuring compliance
with the data protection requirements set forth in this policy.
Failure to comply with this policy may result in complaints, regulatory actions, financial
penalties, and/or reputational damage to the Company.
Our management is fully committed to the continuous and effective implementation of
this policy and expects all employees and third parties to share this commitment.
Violations of this policy will be taken seriously and may result in disciplinary actions or
business sanctions.
- Data Controller
The data controller responsible for processing the data generated from the use of
https://pomscloud.ie, including any of its subdomains and/or subpages, is
MediaSales Ltd. (hereinafter referred to as the “Company”).
● Registered Address: Lion Office Building, Angyalföldi út 5/B, 1134 Budapest,
Hungary
● Tax Number: 13912963241 - Data Protection Officer (DPO)
To demonstrate our commitment to data protection and enhance the effectiveness of
our compliance efforts, we have appointed a Data Protection Officer (DPO).
The DPO operates independently and is supported by appropriately trained
professionals with all necessary authorisations.
● Data Protection Officer: Adrienn Beres
● Email: DPO@mediasales.hu - Collected Data
What Data Do We Collect?
The type of data we collect depends on the nature and purpose of your interaction with
the Website. - General data collected from all visitors:
○ Navigation-related data, including IP address, browser type, operating
system, language preferences, and visited pages. - Data collected from users of our services:
○ In addition to the above, we collect data uploaded by the user and
information related to the associated website.
○ We also track user activity on the Website. - Data collected from registered account users:
○ Personal identification data, such as:
■ Full name
■ Email address
■ Passwords
■ Phone number - Non-personal data collected:
○ Company name
○ Registered office address
○ Tax number
○ Billing address
○ Transaction dates and amounts
○ Corporate email addresses
○ Corporate phone numbers
○ Links pointing to the company’s website
○ Trademarks of company products
○ Product information
○ Uploaded data, including metadata
Voluntary or Mandatory Nature of Data Provision
Providing personal data is generally voluntary. However, certain personal data may be
required for us to perform our services or fulfill our contractual obligations (for example,
fulfilling an order or registering an account). If you choose not to provide the necessary
data, you may not be able to use certain features or complete certain transactions on
our Website.
How Do We Collect Your Data?
Most of the data we collect is provided directly by you. We collect and process data in
the following ways:
● When you register online or place an order for our products/services.
● When you voluntarily complete customer surveys or provide feedback via our
forums or email.
● When you browse and interact with our Website through cookies stored in your
browser.
● Through the website URL you provide.
● Through images, texts, or other content you upload.
● Through emails you send us or communications via phone.
We may also receive your data indirectly from the following sources:
● Representatives of advertising agencies, media agencies, or creative agencies
affiliated with you.
● Our Website also collects data indirectly through cookies and tracking
technologies. Please read our Cookie Policy to better understand these
technologies and how we use them on the Website and within our services. - Use of Data
How Will We Use Your Data?
The Company collects your data for the following purposes:
● To process your order and manage your account.
● To send you emails regarding the requested services.
● To contact you by phone regarding your requested services or subscription
information.
● To send you emails with special offers on other products and services that may
interest you.
● To ensure the proper functioning of the Website’s services.
● To provide you with personalised advertising offers as part of our marketing
campaigns.
Lawful Basis for Processing
Our lawful bases for processing personal data include:
Performance of a Contract: We process certain data to provide our services (e.g.,
registration, order fulfillment).
Legal Obligation: We may process data to comply with applicable legal requirements
(e.g., accounting or tax regulations).
Legitimate Interests: We rely on our legitimate interests to maintain and improve our
Website, ensure its security, and carry out certain marketing activities. However, where
required by law, we will ask for your consent for direct marketing activities.
Consent: In specific cases (e.g., sending newsletters or personalised offers via email if
you are not an existing customer), we process your data based on your explicit consent.
You can withdraw this consent at any time (see “Your Rights” section).
Who Processes Your Data, On What Legal Basis, and With Whom Do We Share It?
The primary processors of your data are the Company’s employees. When processing
an order, the Company redirects you to a banking platform where you can complete
your financial transaction. The Website does not store credit card information or any
other sensitive banking details. To ensure secure card payments, the Company
transmits your order and the necessary data only to internationally recognised and
registered banking service providers.
For customer support purposes, we may share your data with the Website’s technical
operator:
● POMS Cloud Ltd.
○ Address: 25 Hastings Green, Balbriggan, Co. Dublin, IRELAND
When using our services, we may share non-personal data you provide with AI service
providers:
● OpenAI OpCo, LLC OpenAI Ireland Ltd.
○ Address: 1st Floor, The Liffey Trust Centre, Dublin 1, D01 YC43,
IRELAND
● Anthropic Artificial Intelligence Company
○ Location: San Francisco, California, U.S.
● Google – Gemini
○ Address: Gordon House, Barrow Street, Dublin 4, Ireland
If you consent, our Company may share your data with partner companies so they can
offer you their products and services.
The legal basis for data processing is our legitimate interest in the administration and
operation of our services, as well as the marketing and promotion of the Website’s
services. - Data Transfers
Ownership Changes or Succession
If the Company is acquired by another entity, merges with another company, undergoes
reorganisation, ceases operations, or sells its assets (e.g., due to financial instability,
bankruptcy, or liquidation), your data may be transferred to the new owner. This
means that user data registered on the Company’s websites may become part of the
transferred assets.
Transfers Outside the European Union
The transfer of your data outside the European Union (as mentioned above) will only
occur after implementing appropriate safeguards and in compliance with the
European Commission’s Standard Contractual Clauses (SCCs). These clauses
ensure that the level of protection and security for personal data remains in accordance
with applicable legal regulations.
We also implement additional measures where required, such as encryption of
certain data prior to transfer or pseudonymisation of personal data, in order to
maintain a high level of protection.
By using the Website, you acknowledge and accept that your data may be transferred
to these servers. - Legal Disclosure
We may disclose your data in the following circumstances:
● Compliance with legal obligations, laws, and legal proceedings, including
requests from government authorities and regulatory bodies.
● To protect the rights, property, or safety of the Company, our customers, or
other stakeholders, when we deem disclosure necessary or appropriate. This
includes sharing information with other companies and organisations for fraud
prevention and anti-counterfeiting measures, particularly in relation to credit
card fraud and other financial fraud protection. - Data Storage
The Company stores your data only for as long as necessary to fulfil the purposes
mentioned above. All data is stored on European cloud-based systems.
● Cloud Service Provider: AWS (Amazon Web Services), Seattle, Washington,
United States
The storage period may vary depending on the type, purpose, and nature of the data. In
some cases, legal requirements may impose mandatory retention periods.
Specific data retention periods:
● If you contact us via form or phone, your data will be stored for 3 years from
the last exchange before being deleted.
● Recorded phone conversations are retained for 1 year from the recording
date.
● If you contact us as a partner agency or company, we store your data for the
duration of the contract and for an additional 5 years after contract
termination, unless you request otherwise.
● If you subscribe to our services as a user, we retain your data for 5 years
after contract termination before deletion.
● If you download generated content from the Website, your activity data
(including downloaded files) is stored for 5 years before deletion.
● If generated advertising materials are not downloaded by the user, the data
is stored for 90 days before automatic deletion.
● If you subscribe to newsletters, we retain your data until you unsubscribe. If
you do not consent to receiving newsletters, your data is stored for 6 years.
● If you report illegal content, your data is retained for the duration of the
investigation and as required by applicable regulations.
● If you request the deletion of your personal data, we retain your data for 5
years before permanent deletion.
● Data collected via cookies and tracking technologies is stored for the
duration specified in our Cookie Policy.
Data Deletion Requests
If you request the deletion of your personal data and there is no overriding legal basis
(e.g., statutory retention periods, ongoing contractual obligations, or legal claims) that
requires further storage, we will erase your data without undue delay. However, certain
categories of data (for example, invoice or financial transaction data) may need to be
retained for up to 5 years (or the legally mandated period) to comply with tax or legal
obligations or to defend against potential claims. Once these legal obligations or
potential claims expire, the data will be permanently deleted. - Your Rights
What Are Your Data Protection Rights?
The Company wants to ensure that you are fully aware of your data protection rights.
Every user is entitled to the following:
● Right to Access – You have the right to request copies of your personal data
stored by the Company. A small administrative fee may apply in certain cases.
● Right to Rectification – You have the right to request corrections to any
information you believe is inaccurate. You also have the right to request the
completion of any incomplete information.
● Right to Erasure (“Right to Be Forgotten”) – You have the right to request the
deletion of your personal data under certain conditions.
● Right to Restrict Processing – You have the right to request that the Company
restricts the processing of your personal data under certain conditions.
● Right to Object to Processing – You have the right to object to the Company’s
processing of your personal data under certain conditions.
● Right to Data Portability – You have the right to request that the Company
transfers the data it has collected to another organisation, or directly to you,
under certain conditions.
● Right to Withdraw Consent – If we process your data based on your consent,
you have the right to withdraw this consent at any time. The withdrawal of
consent does not affect the lawfulness of processing prior to such withdrawal.
If you submit a request regarding your rights, the Company will respond within one
month from the date of receipt. If the request is particularly complex or if a high volume
of similar requests is received simultaneously, this period may be extended by an
additional two months.
To exercise any of these rights, please contact us via email:
● Data Protection Officer: Adrienn Beres
● Email: DPO@mediasales.hu
In accordance with Article 12(6) of the GDPR, the Company reserves the right to
request identity verification before processing your request. Once the request has
been handled, the identity verification data will be deleted.
We may use certain website analytics and user activity data to create profiles of user
preferences, which helps us provide tailored advertising or offers. No automated
decisions are made that would produce legal or similarly significant effects for you
without human intervention. You have the right to object to such profiling at any time, or,
where relevant, withdraw your consent if the profiling is based on consent. - Security
Your data is stored on secure servers protected by firewalls and antivirus
software. We implement technical and organisational measures to protect your
data from loss, unauthorised access, modification, or disclosure.
However, due to the nature of the internet, we cannot guarantee the complete
security of data transmitted over the network. By using our Website, you
acknowledge that you are partially responsible for protecting your own data.
● We are not responsible for any issues arising from neglecting privacy
settings and security measures on the Website.
● You are responsible for keeping your account credentials secure (e.g.,
safeguarding your password).
● Do not share your login details with third parties.
● Be cautious when posting publicly visible content on the Website, as this
information may be accessible to others.
The Website may contain links to external social media platforms or third-party
sites that are not operated by the Company. Any data uploaded to these
third-party platforms is stored and processed on external servers beyond our
control.
As we do not manage these third-party sites, we assume no responsibility for
how they store or use your data. We strongly recommend reviewing the privacy
policies of any third-party websites you access through our platform. - Policy Review
Due to technological advancements and changes in data protection laws, we
may update this policy periodically.
● If you are affected by a significant modification, we will notify you via email.
● If any provision of this policy is deemed unlawful or invalid, it will only affect
that specific provision and will not affect the validity of the rest of the policy. - Cookie Policy
What Are Cookies?
Cookies are small text files placed on your computer to collect general internet
log information and visitor behaviour data. When you visit our Website, we may
automatically collect information about you via cookies or similar technologies.
Types of Cookies
● Session Cookies: Temporary cookies that remain active only while your
browser is open. They help link actions performed during a browsing
session.
● Persistent Cookies: Stored on your device for a longer period, allowing the
website to remember your preferences and settings.
● First-Party Cookies: Set directly by the website you are visiting.
● Third-Party Cookies: Set by external services (not the website you are
visiting).
For more information, visit allaboutcookies.org.
How Do We Use Cookies?
Our Company uses cookies to enhance your user experience in several ways,
including:
● Helping you stay logged in.
● Understanding how you interact with our Website.
● Linking ordered services to your account.
● Providing access to your generated and downloadable digital materials.
What Types of Cookies Do We Use?
Cookie Name Domain
Expiration
Time
Description
__Host-3PLSID accounts.google.com 1 years
Google authentication cookie used for login
persistence.
ACCOUNT_CHOOSER accounts.google.com 1 years Google cookie for account selection on login.
__Host-1PLSID accounts.google.com 1 years Google session security cookie.
LSID accounts.google.com 1 years Google authentication session cookie.
__Host-GAPS accounts.google.com 1 years Google authentication tracking cookie.
OTZ accounts.google.com 1 months Google analytics and advertisement tracking cookie.
XSRF-TOKEN pomscloud.ie 1 day
Security token used to prevent cross-site request
forgery (CSRF) attacks.
ecommercebanner_session pomscloud.ie 1 day
Session cookie that stores user preferences and
login status.
ecommercebanner_cookies pomscloud.ie 6 months E-commerce banner session and tracking cookie.
SIDCC google.com 1 years Google security cookie for session management.
__Secure-3PSIDTS google.com 1 years Google secure tracking session cookie.
NID google.com 1 years Google advertisement personalization cookie.
__Secure-3PAPISID google.com 1 years Google secure tracking and authentication cookie.
__Secure-1PAPISID google.com 1 years Google secure tracking and authentication cookie.
SAPISID google.com 1 years Google authentication cookie.
__Secure-3PSIDCC google.com 1 years Google security cookie for secure login sessions.
__Secure-1PSID google.com 1 years Google secure session tracking.
__Secure-3PSID google.com 1 years Google secure authentication cookie.
HSID google.com 1 years Google authentication and session security cookie.
AEC google.com 6 months
Google cookie ensuring requests within a browsing
session are made by the user.
SSID google.com 1 years Google authentication cookie.
APISID google.com 1 years
Google cookie used for user preferences and
security.
SOCS google.com 1 years Google tracking and security cookie.
__Secure-1PSIDTS google.com 1 years Google tracking and authentication security cookie.
SID google.com 1 years Google authentication and security cookie.
__Secure-1PSIDCC google.com 1 years No description available
UULE www.google.com 1 day
Google cookie that helps refine search results based
on location.
DV www.google.com 1 day Google analytics cookie used for ad personalization.
LOGIN_INFO www.youtube.com 1 day
YouTube cookie that stores login session
information.
LOGIN_INFO youtube.com 1 day
YouTube cookie that stores login session
information.
YSC youtube.com 1 day YouTube session tracking cookie.
SID youtube.com 1 day Google authentication and security cookie.
HSID youtube.com 1 day Google authentication and session security cookie.
SSID youtube.com 1 day Google authentication cookie.
APISID youtube.com 1 day
Google cookie used for user preferences and
security.
SAPISID youtube.com 1 day Google authentication cookie.
__Secure-1PSID youtube.com 1 day Google secure session tracking.
__Secure-1PAPISID youtube.com 1 day Google secure tracking and authentication cookie.
What Types of Cookies Do We Use?
Our Website uses various types of cookies, including:
● Functional Cookies – These cookies allow us to recognise you on our Website
and remember your previous preferences, such as your preferred language or
location settings. Our Website utilises both first-party and third-party cookies.
● Advertising Cookies – These cookies collect information about:
○ Your visits to our Website
○ The content you viewed
○ The links you clicked
○ Your browser type, device, and IP address
● We may share parts of this data with third parties for advertising purposes.
Additionally, we may share cookie-generated data with our advertising partners,
meaning that when you visit other websites, you may see advertisements tailored
to your interests.
● Performance-Enhancing Cookies – These cookies help us improve the overall
performance of our Website.
● Cookies That Enable Extra Features – These cookies support advanced
functionalities on the Website.
How Can You Manage Cookies?
You can set your browser to not accept cookies, and you can find instructions on how to
remove cookies from your browser at allaboutcookies.org.
However, please note that in some cases, certain Website features may not function
properly if cookies are disabled.
Consent for Non-Essential Cookies
Under the applicable ePrivacy rules, we will only set non-essential cookies (e.g.,
marketing or analytics cookies) on your device after you have provided your consent
through our cookie banner or settings panel. You can withdraw this consent at any time
by adjusting your preferences in the cookie settings on our Website. - Contact
How to Contact Us?
If you have any questions about our Privacy Policy, the data we hold about you, or if you
wish to exercise any of your data protection rights, please do not hesitate to contact us:
● By Email: DPO@mediasales.hu
● Via Our Website: https://pomscloud.ie/#contact
How to Contact the Relevant Authorities?
If you believe that your data protection rights have been violated, you have the right to
file a complaint with the Hungarian National Authority for Data Protection and Freedom
of Information (NAIH):
● Website: https://naih.hu
Date: 09 February 2025