Privacy Policy

Civic Frame ('We', 'Us', 'Our') respects Your privacy and is committed to protecting the personal data of visitors to www.thecivicframe.com (the 'Website'), Our clients, advertisers, and end-users reached through Our advertising technology platform (the 'Platform'). This Privacy Policy explains what data We collect, why We collect it, how We use and share it, and the choices and rights available to You.

1. Who We Are

Civic Frame is a digital marketing, public relations, and advertising technology agency based at Shakhauyat Bila, 2nd Floor, Flat No- A, Kalabagan, Dhaka, Bangladesh. For the purposes of this Policy, Civic Frame acts as a data controller in respect of Our own clients and Website visitors, and as a data processor/service provider when handling audience or campaign data on behalf of advertiser clients through the Platform.

2. Information We Collect

a) Information You Provide Directly

• Name, company name, email address, phone number, and physical/business address (e.g., via contact or 'Book a Meeting' forms)
• Billing and payment-related information (see Our Payment Security Policy for card-data handling)
• Brand assets, campaign briefs, credentials, and other materials You share with Us to perform Services

b) Information Collected Automatically

• IP address, browser type, device type, operating system, and general location (city/country level)
• Pages visited, time spent, referring URLs, and click behaviour on Our Website, collected via cookies and analytics tools (see Our Cookies Policy)

c) Information Collected Through the AdTech Platform

• Device and advertising identifiers (e.g., mobile ad IDs, browser cookie IDs), approximate location, app/site context, and interaction data (impressions, clicks, conversions) relating to end-users exposed to campaigns run through the Platform
• Audience segment and targeting data provided by advertiser clients or sourced from third-party data partners, as permitted under applicable law and the relevant client agreement

d) Information From Third Parties

• Data from advertising networks, ad exchanges, social platforms (e.g., Meta, Google, TikTok), and analytics providers, to the extent needed to plan, deliver, and report on campaigns

3. How We Use Your Information

• To provide, manage, and improve Our Services, including PR, marketing, development, and AdTech campaign delivery
• To communicate with You regarding proposals, projects, invoices, and support requests
• To process payments and maintain financial records
• To plan, serve, measure, and optimise advertising campaigns on behalf of clients, including audience targeting, frequency capping, attribution, and fraud detection
• To send marketing and promotional communications about Our Services via email, SMS, phone, or WhatsApp, where You have not opted out
• To comply with legal, tax, and regulatory obligations, and to protect Our legal rights

4. Legal Basis for Processing

Where applicable law requires a legal basis for processing (such as regulations modelled on the GDPR, relevant to Our international clients and their audiences), We rely on: performance of a contract with You; Your consent (e.g., for marketing cookies or communications); Our legitimate interests in operating and improving Our business and Services; and compliance with legal obligations.

5. How We Share Your Information

We do not sell Your personal data. We may share information with:

• Third-party service providers who support Our operations (e.g., payment gateways, cloud hosting, analytics providers, email/SMS delivery services)
• Advertising networks, ad exchanges, and platforms (e.g., Meta, Google, TikTok) as necessary to deliver and measure campaigns on behalf of clients
• Professional advisors (accountants, lawyers) where necessary for Our business operations
• Government authorities, regulators, or law enforcement where required by applicable law or to protect Our legal rights
• A successor entity in the event of a merger, acquisition, or sale of business assets

6. International Data Transfers

As Civic Frame works with international clients, advertising networks, and cloud service providers, Your data may be transferred to and processed in countries outside Bangladesh. Where required, We seek to ensure that such transfers are subject to appropriate contractual or technical safeguards.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including satisfying any legal, accounting, or reporting obligations. Campaign and performance data processed through the Platform is generally retained for the duration of the campaign engagement plus a reasonable reporting/audit period, unless a shorter or longer period is required by the applicable client agreement or law.

8. Data Security

We implement reasonable technical and organisational measures — including access controls, encrypted transmission (SSL/TLS), and restricted internal access — to protect personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure, and We cannot guarantee absolute security.

9. Your Rights

Subject to applicable law, You may have the right to: access the personal data We hold about You; request correction of inaccurate data; request deletion of Your data; object to or restrict certain processing (including marketing communications); and request a copy of Your data in a portable format. To exercise any of these rights, please contact Us using the details in Section 13.

10. Marketing Communications

By providing Your contact details to Us, You consent to Civic Frame contacting You via email, SMS, phone call, or WhatsApp regarding Our Services and relevant offers. You may opt out of marketing communications at any time by using the 'unsubscribe' link in Our emails or by contacting Us directly; this will not affect service-related communications necessary for an active engagement.

11. Children's Privacy

Our Website, Services, and Platform are intended for use by businesses and individuals aged 18 and over. We do not knowingly collect personal data from children, and any such data discovered will be deleted promptly.

12. Cookies

Our use of cookies and similar tracking technologies on the Website and Platform is described in detail in Our separate Cookies Policy, which forms part of this Privacy Policy.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in Our practices, technologies, or legal requirements. The updated version will be posted on Our Website with a revised Effective Date.

14. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or Your personal data, please contact Us at:

• Email: civicframe01@gmail.com
• Phone / WhatsApp: +880 1857-702270
• Address: Shakhauyat Bila, 2nd Floor, Flat No- A, Kalabagan, Dhaka, Bangladesh