Privacy policy

1. Who we are

This website is published by Click Fire Media D.O.O, Crnogorskih serdara 5/6 F, Podgorica 81000, Montenegro ("we", "us", "the company"). The site it applies to is the one you are reading, and its address is in the company details at the end of this page.

We are the controller for the processing described here. The advertisers, networks and platforms named below are separate controllers for what they do with data themselves. Write to about data protection, or to about anything else.

2. What this policy covers

It covers this website only. There is no account, no registration and no form here, so nothing is asked of you: the data described below either arrives with the request itself or is created when you choose to follow one of the links to a provider.

It does not cover the websites you reach through our links. Those are run by other companies, under their own terms, and we neither control them nor are party to anything you agree with them.

3. Data we process

• Request data. The page requested, the time, the referring page, your browser's user agent and the IP address the request came from. Every web server receives this, and it is needed to serve the page and keep the service secure.
• Click data. When you follow one of our outbound links, our server creates a random identifier for that click and records the page it happened on, the destination, an approximate country and a coarse device type. Where you arrived from an advertisement we paid for, the platform's own click identifier (gclid or msclkid) is read from the address of the page you landed on and stored with it. Nothing is stored on your device for this.
• Measurement data, unless you switch analytics off. Pages read and offers shown, measured by Google Analytics and by our own statistics, consulted in totals rather than per visit.
• Your privacy choice. Whether you allowed or declined measurement, and when.
• Correspondence. Whatever you send us, if you write.

None of it is combined into a profile, and none of it identifies you by name.

4. Cookies and storage on your device

We and our partners use cookies and similar technologies on this website: to make it work, to understand how it is used, and to measure whether our advertising and links work. Our cookie policy describes them and your choices. You can change your choices at any time under "Cookie settings" in the footer of every page.

Advertising platforms you came from, and providers you visit through our links, set cookies on their own sites under their own terms.

5. Why we process it, and on what legal basis

• Serving and securing the site: legitimate interest, Article 6(1)(f). A page cannot be delivered without processing the request that asked for it.
• Attributing a click we are paid for: legitimate interest, Article 6(1)(f). Our interest is in being paid for readers we actually send; the data used is a click identifier, the page and a country, which is the least that can answer the question.
• Measurement and analytics: legitimate interest, Article 6(1)(f) GDPR, in knowing which pages and advertisements work, and your consent where the law requires it. You can object or change your choice at any time under "Cookie settings".
• Keeping your privacy choice: storing it on your device is strictly necessary to respect it (§ 25(2) no. 2 TDDDG); keeping a record of it serves our obligation to demonstrate consent, Article 6(1)(c) with Article 7(1).
• Correspondence and legal records: legitimate interest, Article 6(1)(f), and legal obligation, Article 6(1)(c).

We do not sell personal data, we do not share it for cross-context behavioural advertising, and we make no automated decision that has a legal or similarly significant effect on you.

6. Affiliate links and advertising we buy

This site is funded by affiliate commission: some of the providers listed pay us when a reader signs up or buys through a link here, and the link carries our click identifier so that the result can be matched to it. The advertiser receives that identifier and nothing else about you, and reports back its own identifier, a time and a value. We never receive your name, address, account or payment details, and we do not want them.

We also buy advertising on search engines. When a reader arrives from one of our advertisements and later completes a signup or a purchase at a provider, we report that conversion back to the platform against the platform's own identifier, so it can price the advertising. The same limit applies: an identifier, a time and a value, never a name, an email address, a phone number or a hashed form of any of them, and never a customer list. The platforms are named in the next four sections.

7. Google Ads

Operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. A click on one of our advertisements adds a gclid parameter to the address you land on, Google may set its own conversion cookie, and completed signups are reported back against that identifier. Google is a controller for its own purposes here, including running and improving its advertising systems; see Google's privacy policy. Personalisation can be limited in your own Google account settings.

8. Microsoft Advertising

Operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, United States. A click adds an msclkid parameter, Microsoft's tag may set its own cookie, and completed signups are reported back against that identifier. Microsoft is a controller for its own purposes here; see Microsoft's privacy statement, which also carries its own advertising controls.

9. Google Analytics

Google Analytics 4, operated by Google Ireland Limited and Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States) as our processor under Google's data processing terms. It runs unless you switch analytics off under "Cookie settings"; once you do, no Google script runs on this site and nothing is sent to Google for analytics. While on, it gives your browser a random identifier, records the pages you read and an approximate location derived from your IP address, and does not store the IP address itself. Data may be transferred to the United States; Google LLC is certified under the EU-US Data Privacy Framework. It is held for up to 14 months and never used to identify a reader.

10. Cloudflare

Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, United States, delivers this website, terminates the encrypted connection and filters abusive traffic, processing the request data above as our processor under a data processing agreement; see Cloudflare's privacy policy. Cloudflare's own web analytics is not used on this site.

11. Other recipients and transfers abroad

Beyond the services named above, data goes only to professional advisers, auditors and authorities, and only where the law requires it or a claim makes it necessary. It is not sold, rented or traded.

Some of these providers are in the United States. Those transfers rest on the EU-US Data Privacy Framework where the recipient participates in it, and otherwise on the European Commission's Standard Contractual Clauses, with the data involved limited to the technical and pseudonymous categories described above. A copy of the safeguards can be requested.

12. How long we keep it

• Request data: up to 12 months.
• Click data, including any platform identifier: up to 24 months, the window in which an advertiser may still report a result against it, then aggregate only.
• Measurement data: up to 14 months in Google Analytics.
• Your privacy choice: six months on your device; our record of it for as long as we must be able to demonstrate it.
• Correspondence: up to 24 months after the matter closes.
• Accounting records: as tax and accounting law requires.

13. Your rights

Where the GDPR or a comparable law applies, you may ask for access, correction, erasure, restriction or portability, object to processing based on legitimate interest, and withdraw consent at any time without affecting what was lawful before. Requests go to and are answered within 30 days, at no charge unless a request is manifestly unfounded or excessive.

Because we hold nothing that identifies you, we usually cannot connect a request to a record without help: tell us the approximate date and time, and the identifier from the link if you have it. Where we cannot identify you in our data, we will say so rather than ask for more identifying information than we already hold.

You may also complain to a supervisory authority: in Montenegro, the Agency for Personal Data Protection and Free Access to Information; in the European Economic Area, the authority where you live or work.

14. Children, security and unsolicited mail

This site is not directed at children under 13 and we do not knowingly process a child's data. If you believe we hold any, write to and it will be deleted.

The site is served over an encrypted connection, access to the systems holding click and request data is restricted and protected by multi-factor authentication, and the data itself is limited by design to what is listed above.

Our contact addresses are published so that readers and partners can reach us. We object to their use for unsolicited advertising and reserve the right to act against it.

15. Changes and contact

The version on this page is always the current one, and the date below is when it last changed. A change that materially affects how your data is processed will appear here before it takes effect. Data protection: . Everything else: .

Company details

Click Fire Media D.O.O, Crnogorskih serdara 5/6 F, Podgorica 81000, Montenegro.

Company details