Privacy Policy

This Privacy Policy explains which personal data we process when you visit IQ Thinking at iqthinking.site and when you use the phone service. It is based on the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the EU General Data Protection Regulation (GDPR).

1. Data controller

UGC Masters Ltd
Registered office: ul. "Tsar Asen Parvi" №15, Belogradchik, Bulgaria
UIC / Company No: 204836938
VAT: BG 201088845
Email: hello@ugcmasters.com
Website: ugcmasters.com

2. Data we process

Technical access data: IP address, date and time, pages visited, referring page, browser type, operating system, device type, language setting and approximate country-level location.
Visit, click and campaign data: information about which advert or campaign brought you to us, which buttons you clicked and which pages of the service you passed through.
Click identifiers: randomly generated identifiers such as the click-ID, used to link a visit to an advert.
Puzzle data: the answers you choose and the score calculated from them. We do not ask for your name or email address for this.
Service and transaction data: the number shown, the time, length and cost of a call, the calling phone number and the recording of the service provided.
Information you choose to give us, for example in an email to our support team.

3. Why we process your data

to provide the website, the puzzles and the phone service;
to measure advertising and attribute conversions to campaigns;
to produce campaign and service statistics and analyse traffic;
to detect and prevent fraud, abuse and invalid clicks;
for technical troubleshooting and system security;
to answer your enquiries and meet our legal obligations.

4. Legal bases

We process personal data to perform a contract with you or take steps before entering into one (Article 6(1)(b)), for our legitimate interests in running a secure and efficient service and measuring our advertising (Article 6(1)(f)), to comply with legal obligations (Article 6(1)(c)) and, where required, on the basis of your consent (Article 6(1)(a)).

5. Cookies and similar technologies

We use cookies, local storage and similar technologies. Essential cookies keep the website working and store your consent choice. Other technologies are used for advertising measurement and fraud prevention, in particular:

rtkclickid-store: stores the click-ID of your visit so that a click can be linked to the correct campaign;
_fbp: an identifier used to measure advertising campaigns where an advertising pixel is used;
consent cookies set by our consent tool to remember your choice.

On your first visit you can choose which non-essential technologies you allow using the consent banner. You can also delete or block cookies at any time in your browser settings.

6. Tracking with RedTrack

We use the tracking service RedTrack to measure our advertising campaigns. When you open our landing page, a script is loaded that creates a click-ID, stores it in rtkclickid-store and passes it on to the following pages. This involves processing your IP address, browser and device data, time, campaign parameters and clicks. It allows us to see which advert led to a visit or use of the service and to detect invalid clicks.

7. Technical event processing

On the puzzle pages, technical events such as opening the page, displaying the phone number and clicking the call button are sent together with the click-ID to a technical service provider. The provider supplies the phone number, links events to campaigns, produces statistics and helps detect misuse. Your calculated score and the number shown are also processed for this purpose.

8. Recipients and international transfers

We share personal data with carefully selected service providers, for example for hosting, tracking, consent management, telephony and billing, and with authorities where we are legally required to do so. Some recipients are located in the European Union, the United Kingdom or other countries. Where a country does not offer an adequate level of data protection, we rely on appropriate safeguards such as standard contractual clauses or the UK International Data Transfer Addendum.

9. How long we keep data

We keep personal data only for as long as necessary for the purposes described above or as required by law. After that, data is deleted or anonymised.

10. Security

We use appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access, such as encrypted transmission and restricted access rights.

11. Your rights

Under applicable law you have the right of access, rectification, erasure, restriction of processing, objection and data portability, and the right to withdraw consent at any time with effect for the future. To exercise these rights, email hello@ugcmasters.com. You also have the right to complain to the Information Commissioner's Office (ICO) in the United Kingdom or to another competent supervisory authority.

12. Children

Our Services are not intended for people under 18. We do not knowingly process data about children.

13. Changes to this policy

We may update this Privacy Policy when our Services or the law change. The version published on this page applies.