Holywell S.A., a company operating under the brands “AWG” and “AWG Media” (“AWG”, “we”, “us” or “our”), operates websites, mobile applications, OTT applications and Connected TV (CTV) applications (collectively, the “Services”). This Privacy Policy explains how we collect, use, disclose and safeguard personal data when you use the Services, and the choices available to you. By using the Services, you agree to the practices described in this Privacy Policy. Terms not defined here have the meaning given in our Terms and Conditions.

Our business. AWG is a digital media, advertising-monetization and content-commercialization company. We (i) operate and monetize digital content and advertising inventory across web, mobile and CTV environments, and (ii) sell access to digital content directly to end users as the merchant of record, using a range of payment and access methods. This Privacy Policy covers both activities.

1. Definitions

Personal Data — data about an identified or identifiable natural person.

Usage Data — data collected automatically through the use of the Services or generated by the Services infrastructure (e.g., session duration).

Cookies and Similar Technologies — small data files and identifiers (cookies, SDKs, pixels, beacons, device and advertising identifiers) stored on or read from your device.

Data Controller — the entity that determines the purposes and means of processing. For most processing under this Policy, AWG acts as Controller.

Data Processor / Service Provider — a party that processes Personal Data on behalf of the Controller.

2. Information We Collect

Information you provide to us.

•Account and registration data, such as email address, name and account credentials.

•Purchase and billing data when you buy content or subscriptions, including the products purchased, transaction amount and history. Card and bank credentials are entered into and processed by our third-party payment processors; we generally do not store full card numbers.

•Communications and support requests you send to us, and your marketing preferences.

Information collected automatically.

•Usage Data and device information, including IP address, device type and unique device identifiers, mobile carrier, operating system, browser type and version, pages or screens viewed, and dates and times of access.

•Advertising identifiers such as mobile advertising IDs (e.g., IDFA / Google Advertising ID) and CTV device identifiers.

•Approximate location derived from IP address or device settings. We do not collect precise (GPS-level) location without your consent.

Information from third parties.

•Payment processors and, for carrier-billing transactions, mobile network operators and aggregators (e.g., confirmation that a charge succeeded).

•Advertising, measurement and analytics partners, and other companies within our group, consistent with their terms and applicable law.

3. How We Use Personal Data

•To provide, operate, maintain and improve the Services and the content offered through them.

•To process purchases, subscriptions and payments, deliver content, and provide receipts and customer support, in our capacity as merchant of record.

•To serve, deliver, personalize and measure advertising, including interest-based advertising, and to monetize content and inventory.

•To analyze usage, conduct research, and develop new features and products.

•To detect, prevent and address fraud, abuse, security incidents and technical issues.

•To communicate with you, including service messages and, where permitted, marketing communications you may opt out of.

•To comply with legal obligations and enforce our terms and policies.

4. Advertising, Analytics and Your Choices

We and third-party advertising partners (including advertising networks, supply- and demand-side platforms, and ad servers such as Google Ad Manager) use cookies, SDKs and device/advertising identifiers to deliver and measure advertising across web, mobile and CTV, including interest-based advertising. Measurement partners help us and advertisers understand who saw an ad and how audiences responded, using aggregated and de-identified information where possible.

You can manage advertising choices through industry tools and device settings, including: NAI opt-out; DAA opt-out; Google Ads settings; the Google Analytics opt-out add-on; your mobile device’s “limit ad tracking” / reset advertising identifier controls; and your CTV device’s advertising settings. Opt-out choices are generally browser- and device-specific.

5. Payments, Subscriptions and Carrier Billing

When you purchase content or a subscription, you contract with and pay AWG as the merchant of record. Payments are processed on our behalf by third-party payment processors and may use methods such as credit and debit cards, digital wallets, bank transfers, QR-based payments, and direct carrier billing. For carrier-billing transactions, charges may appear on your mobile bill or be deducted from prepaid balances, and your mobile network operator and aggregators process data necessary to complete the charge. We receive transaction confirmation and related billing data to fulfil your purchase, provide support, manage refunds and chargebacks, and prevent fraud.

6. Cookies and Similar Technologies

We use session, preference, security, analytics and advertising cookies and similar technologies. You can control cookies through your browser and device settings; some app-specific identifiers must be managed through your device’s app settings. If you reject certain technologies, some features of the Services may not function properly. Where required by law, we request consent before placing non-essential cookies.

7. How We Share Personal Data

•Service providers and processors that perform services on our behalf (e.g., hosting, analytics, customer support, payment processing).

•Advertising and measurement partners, as described in Section 4.

•Payment processors, mobile network operators and aggregators, as needed to process transactions (Section 5).

•Companies within our corporate group.

•Authorities and third parties where necessary to comply with law, respond to lawful requests, enforce our terms, or protect rights, property or safety.

•Acquirers or successors in connection with a merger, acquisition, financing or sale of assets; we will provide notice where required.

8. Legal Bases for Processing (EEA/UK)

Where the GDPR or UK GDPR applies, we process Personal Data on one or more of the following legal bases: performance of a contract with you; your consent (which you may withdraw at any time); our legitimate interests (balanced against your rights); and compliance with legal obligations.

9. International Data Transfers

We operate internationally, and your Personal Data may be transferred to and processed in countries other than your own, including jurisdictions whose data-protection laws may differ from those in your location. Where required, we implement appropriate safeguards (such as standard contractual clauses) for such transfers.

10. Data Retention

We retain Personal Data only for as long as necessary for the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes and enforce our agreements. Usage Data is generally retained for shorter periods, except where needed for security, functionality or legal compliance.

11. Your Rights

Depending on your location, you may have rights to access, correct, update, delete, restrict or object to the processing of your Personal Data, to data portability, and to withdraw consent. Where the GDPR/UK GDPR applies, you may also lodge a complaint with your local supervisory authority.

California residents (CCPA/CPRA). You may have the right to know, access, correct and delete personal information, and to opt out of the “sale” or “sharing” of personal information and of certain targeted-advertising activities. We do not sell personal information of consumers we know to be under 16 without authorization. To exercise these rights, including the right to opt out, contact us at privacyawgmedia@awg.la. We will not discriminate against you for exercising your rights.

To exercise any right, contact us at privacyawgmedia@awg.la. We may need to verify your identity before responding.

12. Children’s Privacy

Protecting children’s privacy is important to us. We do not knowingly collect Personal Data from children below the age set by applicable law (under 13 under the U.S. Children’s Online Privacy Protection Act (“COPPA”), and under 16 in certain jurisdictions) without verifiable parental consent. On Services or sections directed to children, we collect only the information necessary, take steps to prevent children from publicly posting contact information, and do not permit interest-based advertising. If you believe a child has provided us with Personal Data without parental consent, contact us and we will take steps to delete it. Parents and guardians may request access to, or deletion of, their child’s information.

13. Do Not Track and Global Privacy Control

Some browsers offer “Do Not Track” (DNT) signals and Global Privacy Control (GPC). Where required by applicable law, we honor recognized opt-out preference signals such as GPC. Industry standards for DNT remain inconsistent, and we describe the controls we offer in Section 4.

14. Third-Party Links and Services

The Services may link to or integrate third-party sites, content and services that we do not control. Their privacy practices are governed by their own policies, and we are not responsible for them. We encourage you to review the privacy policies of any third party you interact with.

15. Security

We use commercially reasonable technical and organizational measures to protect Personal Data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version with a revised effective date and, where appropriate, provide additional notice. Your continued use of the Services after changes become effective constitutes acceptance of the updated Policy.

17. Contact Us

Questions about this Privacy Policy may be sent to privacyawgmedia@awg.la.