Your Privacy Rights
Last Updated: 11th June 2026
Fivecell Research Group Limited ("Fivecell," "we," "our," or "us") does not process personal information relating to residents of the United States, and US privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), do not apply to our processing activities. This page addresses your rights under the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the IAB Europe Transparency & Consent Framework ("TCF").
This page forms part of our privacy policy framework and should be read alongside our Privacy Policy, Advertising Policy, Our Legitimate Interests, and Internet Advertising Transparency & Data Processing Disclosure pages.
A Note on How Your Data May Reach Fivecell
If you are reading this page because you are a visitor to the Fivecell Research Group website, please note that Fivecell does not collect advertising data through this website. Our website uses only cookies that are strictly necessary for it to function, and we do not place advertising or tracking cookies.
The information below relates to how individuals can manage their privacy choices regarding data Fivecell receives through the digital advertising supply chain, typically as a result of using apps or browsing websites that work with our data vendors.
Your Rights
Under the GDPR and UK GDPR, you have the right to:
Request access to the personal data we hold about you
Request correction of inaccurate personal data
Request erasure of your personal data
Restrict certain types of processing
Object to processing based on Legitimate Interests
Withdraw consent at any time where processing is based on consent
Receive your data in a portable format, where applicable
Lodge a complaint with a supervisory authority
Managing Your Preferences Under the IAB Europe Transparency & Consent Framework
Fivecell Research Group Limited is in the process of registering as a vendor on the IAB Europe Global Vendor List ("GVL"), which forms part of the TCF. Upon successful registration, we will be assigned a GVL Vendor ID and this section will be updated accordingly.
As Fivecell does not yet hold a Vendor ID, our current receipt of data rests on the disclosed-purpose consent obtained by our data vendors, each of whom is an IAB-registered vendor whose consent disclosures cover the provision of data to third parties, including Fivecell, for analytics purposes. Once our GVL registration is complete, our systems will additionally check incoming Transparency & Consent Strings ("TC Strings") for signals specific to our Vendor ID, once our data vendors update their Consent Management Platform ("CMP") configurations accordingly.
As described in our Advertising Policy, Fivecell does not place its own cookies or device identifiers. We receive identifiers already placed by other parties, along with consent established by those parties for the provision of data to recipients like us. As a result, the controls described below are primarily exercised through the CMP of the app or website where the identifier was originally placed, not through Fivecell directly, though you may also contact us directly using the details below.
Withdrawing Consent (TCF Purposes 3 and 4, and Special Feature 1)
If you previously consented to the use of your data for personalised advertising, or to the provision of your precise location data, through a CMP, you can withdraw that consent at any time by:
Revisiting the privacy or consent settings on the app or website where you originally gave consent. Where that CMP is TCF-compliant, withdrawing consent will generate an updated TC String that communicates your new preferences to vendors in that CMP's vendor list, including Fivecell once our Vendor ID is propagated.
Contacting us directly at legal@fivecellgroup.com with sufficient detail to identify the processing you wish to stop. We will action your request within 30 days and update our suppression records accordingly.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Special Feature 1 (Precise Geolocation Data):
Where data we receive includes precise location data (latitude/longitude), this is classified under the TCF as Special Feature 1, which requires your explicit consent and cannot be based on Legitimate Interests. This consent is obtained by our data vendors at the point of collection. You can manage this consent through the CMP of the app or website where it was originally given, or by contacting us directly as described above.
Objecting to Legitimate Interests Processing (TCF Purposes 7, 9, and 10, and Special Purposes 1 and 3)
Where we rely on Legitimate Interests as our legal basis, as described in detail on our Our Legitimate Interests page, you have the right to object under Article 21 of the GDPR. You can exercise this right by:
Using the "Object" controls in the detailed preferences panel of any TCF-compliant CMP, where available. Your objection will be recorded in the TC String and communicated to us automatically once our Vendor ID is propagated.
Contacting us directly at legal@fivecellgroup.com. Where you object to processing based on Legitimate Interests, we will cease that processing in respect of your data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless processing is necessary for the establishment, exercise, or defence of legal claims.
Global Privacy Control (GPC)
We recognise and honour the Global Privacy Control ("GPC") browser signal as a valid objection to non-essential processing under the GDPR. Where we detect a GPC signal, we treat it as an objection to processing based on Legitimate Interests and, where applicable, as a withdrawal of consent. GPC signals are processed automatically by our systems and do not require you to submit a separate request.
For further information about the TCF, visit https://iabeurope.eu/transparency-consent-framework/.
Data Licensing to Clients (Activity B) and Your Rights
As described in our Internet Advertising Transparency & Data Processing Disclosure, in addition to producing generalised audience and spatial insights through our SaaS platform ("Activity A"), we separately license underlying data, which may include data in the form we received it, including precise location data, to our enterprise clients under data licence agreements ("Activity B"). For Activity B, Fivecell acts as a controller, determining which clients receive data and under what terms; the clients receiving this data are themselves independent controllers for their own subsequent use of it.
If you exercise an erasure or objection right with us, and your data has previously been licensed to a client under Activity B:
In accordance with Article 19 GDPR, we maintain records of which data has been licensed to which clients, allowing us to identify any client whose licensed dataset could plausibly contain your data.
Where a client has an active data licence agreement that could contain your data, we will forward your erasure or objection request to that client. Our data licence agreements require the client to act on such requests and to provide us with signed confirmation that the relevant data has been deleted or that processing has ceased. We track these confirmations and the timeframe within which they are provided.
Where a client's data licence agreement has already ended, our data licence agreements require all licensed data to be deleted on termination, so no further action is generally required in respect of that client.
We are not able to guarantee the actions taken by an independent controller, but we have processes in place to request and track confirmation of deletion as described above. If you wish to exercise rights directly against a specific Activity B client, and you are able to identify that client, you may also need to contact them directly. We can assist with this where possible.
How to Submit a Request
To exercise any of the rights described above, please contact us at:
Fivecell Research Group Limited
Dimostheni Severi 12, Office 601, 1080 Nicosia, Cyprus
Email: legal@fivecellgroup.com
We will respond to your request within 30 days, or within 45 days where the request is complex. We may need to verify your identity before processing your request. We will not discriminate against you for exercising any of these rights.
Representatives: If you are located in the EU or UK, a representative may act on your behalf under a power of attorney or equivalent arrangement, subject to our ability to verify the representative's authority to act on your behalf.
Supervisory Authority Complaints
If you believe that we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with a data protection supervisory authority. Our lead supervisory authority, given our establishment in the Republic of Cyprus, is:
Office of the Commissioner for Personal Data Protection (Cyprus) Website: www.dataprotection.gov.cy Email: commissioner@dataprotection.gov.cy
If your complaint relates specifically to the IAB Europe Transparency & Consent Framework, you may also contact the Belgian Data Protection Authority, which has supervisory responsibility over IAB Europe as the managing organisation of the TCF:
Belgian Data Protection Authority (Autorité de protection des données) Website: https://www.dataprotectionauthority.be/citizen
Data Minimisation and Retention
Where data is no longer required for the purposes described in this page and our other policies, it is removed from our active processing pipelines in accordance with the retention schedule set out in our Privacy Policy, Advertising Policy and Internet Advertising Transparency & Data Processing Disclosure. Aggregated or generalised data may be retained for longer periods in accordance with the schedules described in those policies.