Eureka Entertainment Inc.

Last Updated: June 9, 2023

This Privacy Policy was amended as of June 9, 2023 and is effective as of that date. The English language version of this privacy statement is the controlling version regardless of any translation.

Our full Privacy Policy, contained in the pages that follow, serves to give notice about the types of Personal Data we collect, how we use it, who we share it with and why, and what we do to try to protect it. We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. We encourage You to read our full statement carefully.

This Privacy Policy is an important document that explains how we address some of our legal obligations, and your related legal rights, involving Personal Data. Please review this Privacy Policy regularly to understand the scope of purposes and the sources from which we collect Your data.

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' Personal information and determines the purposes and means of the processing of Consumers' Personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' Personal information, that does business in the State of California.

CCPA and/or CPRA refers to California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Eureka Entertainment Inc. For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: UK

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

GDPR refers to EU General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to insert website.

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

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TYPES OF DATA COLLECTED

We have collected your consent (where required under applicable law) to use your data for marketing. Where we rely upon your consent, you have the right to withdraw this consent by contacting the Data Protection Officer on the contact details above.

If you do not wish us to use your Personal Data, please do not submit it. This means you should not participate in the applicable activities on or use the applicable features available from our online and mobile resources. Such participation and use are strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources.

PERSONAL DATA

While using Our Service, We may ask You to provide Us with certain Personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Date of birth
• Phone number
• Address, State, Province, Region, ZIP/Postal code, City, Country
• Job title
• Biometric data such as fingerprints or facial or retina scans

We collect Personal Data in three ways: (i) Personal Data you voluntarily provide to us; (ii) Personal Data we collect through automated/technical means; and (iii) Personal Data that you have previously made available publicly or to other sources. By using our online and mobile resources, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your data as described.

We use this data for certain activities, including:

• Sending you email including, but not limited to service announcements, account related messages, project related updates, subscribed newsletters;
• Sending marketing information and offers to business contacts regarding Eureka Entertainment Inc services;
• Inviting you to provide reviews about other products and services, and to consider other services provided by Eureka Entertainment Inc;
• Providing our services, managing our website, responding to your questions, investigating any complaints, and providing customer service;
• Customize your digital markets experience;
• Resolving disputes;
• For internal analytical and research purposes to help us to measure interest in and improve our services;
• Preventing prohibited or illegal activities;
• Enforcing our policies.
• Because it is necessary to comply with applicable laws or regulations;

USAGE DATA

When you visit our sites or use our online and mobile resources, basic data about your internet/electronic activity is automatically collected through your browser via tracking technologies, referred to as “cookies.” Cookies are small text files downloaded onto your computer or mobile device. Cookies allow us to collect your IP address and recognize your computer or mobile device and store some data about your preferences for using our online and mobile resources or past actions. Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, URL, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, referring site, timestamp, geolocation, other standard browser data and other diagnostic data.

Behavioural data (such as data on the behaviour or presumed interests of individuals which are linked to those individuals and may be used to create a user profile) pages viewed, images viewed, documents downloaded and links to other sites followed. Inferences drawn from the foregoing may be used to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological traits, predispositions, behaviour, attitudes, intelligence abilities and aptitudes.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

We use this data:

• To Personalize your experience on our website;
• Operating our website, developing, and improving our products and services;
• Analytical, statistical and trend analysis to improve the user experience and performance of our website;
• Facilitate your access to and use of our website;
• Resolving disputes and troubleshooting problems.
• Because it is necessary to comply with applicable laws or regulations;

We have a legitimate business interest to:

• Manage and promote our business and brand;
• Provide and improve our services;
• Operate our business;
• Obtain payment for our services;
• Improve the performance and user experience of our websites;
• Monitor, investigate and report any attempts to breach the security of our websites;
• Improve the performance and user experience of our websites;
• Develop our product and service offerings for service users.
• Resolve any concerns or disputes you may have.

Data provided by you directly that we collect when you:

• Create or claim free or paid content;
• Connect with Eureka Entertainment Inc sales representatives;
• Register for an account with us;
• Correspond with us (either by phone or email).

Categories of data we collect automatically about you include:

• Personal Data such as your full name and contact details such as the name of your company, the state/county in which you are based, business email address, your telephone number and job title;
• Your company website URL;
• Data about the software you use, e.g., the product name, type of software and product description;
• Data we require so we may invoice you, including your payment details and billing data; and Other data you provide when you communicate with us, including your full name, contact details and business email address, phone number and details of our communications.

We use this data for certain activities, including:

• Invoicing you appropriately;
• Managing your profile and access;
• Sending you service emails (e.g., service announcements and messages relating to your account);
• Providing consultation services;
• Notifying you about special offers available from us, our affiliates or partners, which may be of interest to you;
• Sending marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand;
• Administering our services and website, investigating any complaints and providing customer service;
• Responding to your questions and requests and otherwise customize your digital markets experience;
• Resolving disputes;
• For internal analysis and research to help us to measure interest in and improve our services;
• Preventing prohibited or illegal activities;
• Enforcing our policies.

We also use the automatically collected Personal Data described here to compile generic reports about popular pages/features of our online and mobile resources, and to see how users are accessing our online and mobile resources and, in some cases, (such as affinity actions) send materials to you. We also may use any such Personal Data you provide to customize our programs and newsletters to make them more relevant to you. We use the Personal Data that we collect from other sources to contact prospective customers and provide them with details regarding our services. In limited cases we do sell Personal Data which you voluntarily provide when using our online and mobile resources.

Mobile Phone Data & Geolocation

If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain data such as uniquely identifiable mobile device data. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification data. Some mobile phone service providers also operate systems that pinpoint the physical location of devices, and we may receive this geolocation data as well.

Data Collected from Other Sources

When you use our online and mobile resources, we may allow third party service providers to place their own cookies or similar technologies to engage in the same types of collection we describe above.

As part of our services, we will sometimes initially identify prospective customers via public websites or applications operated by third parties. The type of data we collect is the same as that described above, such as name, email address, mailing address and phone number, as well as potentially workplace and job title. We purchase data sets from third parties and use them to check the accuracy of the data we collected from such public sources. In some cases, we may use the data we purchased from a third party even if we did not previously collect it from a public source. We exercise reasonable care and due diligence in purchasing data from third parties and only do so when we are able to obtain assurances that they obtained Personal Data in a lawful manner.

If you use both our app and a third-party mail service (such as Google's Gmail, Yahoo! Mail and others) on your mobile device, you may have activated a setting that allows us to use certain technologies such as application programming interfaces, to automatically access (sometimes referred to as “parse”) your mail as it relates to your use of our app. If you did activate the setting allowing us to do so, our use of any data we receive from those technologies will adhere to the requirements of the publisher of the applicable technology. This includes, if we use Google APIs, adhering to the Google API Services User Data Policy and its Limited Use requirements.

User Beware: External Sites, Apps, Links and Social Media

We may maintain a presence on one or more external social media platforms such as Twitter, Facebook, Instagram, and LinkedIn. We may further allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties.

We are not responsible for the content on, or the privacy practices of, social media platforms, or any third-party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor the terms of use appearing on or in any of our online and mobile resources apply to our social media presence or any third-party sites or apps to which we may link. That means even if You take an affinity action on our specific social media profile, and identifiers about You are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility. If you have questions about how those apps, sites and platforms collect and use Personal Data, you should carefully read their privacy policies and contact them using the data they provide.

TRANSFER OF PERSONAL DATA

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other Personal information.

WHEN/WITH WHOM DO WE SHARE PERSONAL DATA?

We may share your Personal Data as described below. This sharing applies to the Personal Data of all four groups of data subjects.

Affiliates. We may share Personal Data with other corporate affiliates who will use such data in the same way as we can under this statement.

Legal Requirements. Under certain circumstances, we may disclose Personal Data to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including responding to court orders and subpoenas.

To Prevent Harm. We also may disclose such data when we have reason to believe that someone is causing injury to or interference with our rights or property or harming or potentially harming other persons or property.

Business Sale/Purchase. If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganisation, divestiture, consolidation, or liquidation, Personal Data may be one of the transferred assets.

Vendors and Business Partners. We also share Personal Data with those of our vendors and business partners who need it to perform under the contracts we have with them. As part of our Security Program, we have adopted standards for those vendors and business partners who receive Personal Data from us. We attempt to bind such vendors and business partners to those standards via written contracts. Such standards include expectations that when we share Personal Data with our vendors and business partners, they will comply with all applicable privacy and data security laws and regulations and our Security Program and will contractually require and cause their subcontractors and agents to do the same.

For any Personal Data our vendors and business partners process or store at their own locations, we further expect them to use technology infrastructure meeting, at least at the facilities level, minimum recognized standards for security controls. Such recognized standards include those published by the International Standards Organization, the National Institute of Standards and Technology or any reasonably equivalent standards.

Please note, however, that we cannot guarantee that all our vendors and business partners will agree to the above-described contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

DATA PROCESSING

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and Personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

Google AdSense & DoubleClick Cookie

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your Personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Behavioural Marketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites or apps
• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2

You may opt-out of all Personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

CHILDREN'S PRIVACY

US Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward and collect and use /data from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18. Moreover, we do not knowingly collect Personal Data from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted Personal Data to us via our online and mobile resources, we will delete that data and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing Personal Data over the Internet.

PERSONAL DATA RETENTION

We use and retain your Personal Data in accordance with applicable law and only as long as necessary to carry out the purposes described above in accordance with our internal data retention procedures described below:

We retain your Personal Data for a period of time consistent with the purpose of collection and processing, required to fulfill our legal obligations and for enforcing our agreements. The retention period for Personal Data is determined by us based on the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and any applicable legal requirements. For example, we will retain certain identifiers for as long as it is necessary to continue maintaining your account and providing you our products and services, to comply with our tax, accounting, and recordkeeping obligations, to administer certain warranties, and for research, development, and safety purposes, as well as an additional period as necessary to protect, defend, or establish our rights, defend against potential claims, and to comply with our legal obligations. Typically, after expiry of the applicable retention periods, your Personal Data will be deleted, unless such deletion is rendered impractical or unreasonably burdensome due technical or other reasons, including where it becomes technically impossible, data retained as part of automatic archiving and back-up procedures, In such cases where any information is retained, We will implement appropriate measures designed to prevent misuse of such data. In certain circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such data without further notice to you

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

DELETION OF YOUR PERSONAL DATA

You have given us your consent (where required under applicable law) to use Your data for marketing. Where we rely on your consent, you have the right to withdraw this consent. You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You by contacting us using the information above or unsubscribing via the opt-out functionality provided in our marketing communications to you.

Our Service may also give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your Personal information.

You may also exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

YOUR RIGHTS AND OUR OBLIGATIONS UNDER THE GDPR

When we collect Personal information from individuals located in the European Economic Area and the United Kingdom (the "GDPR Jurisdictions"), those individuals have rights under the GDPR. This section of our statement is used to fulfil our GDPR obligations and explain your GDPR rights. For purposes of this section, the words "you" and "your" mean only such individuals located in the GDPR Jurisdictions.

Our Collection, Use, and Sharing Practices

Please review this section to understand the scope of purposes and the sources from which we collect Personal Data. Similarly, you can find data about the categories of third parties with which we may share your Personal Data and why we share it in this section. We do not use your Personal Data for automated decision-making. We do, however, collect certain Personal Data for the purpose of selling it as described here. We also purchase certain Personal Data from third parties. If we are reasonably aware that such third parties have not provided you with appropriate notice of collection as required under GDPR Article 13, we will provide you the required alternate notice under Article 14 when we first contact you using such data. We typically provide that Article 14 notice in the body of the communication used to contact you.

Legal Basis for Processing Your Personal Data

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Our legal basis for collecting and using your Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, such as to contact you about products and services you may be interested in. In certain circumstances where our legal basis of processing is for performance of a contract with you, please be aware that, in those circumstances, where you do not provide Personal Data, which is required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. If we happen to obtain your consent to process your Personal Data, you may withdraw your consent at any time via any of the means listed here.

Exercising Your Rights

You may exercise the rights available to you under the GDPR, including the right to object to the processing of your Personal Data, as follows:

Request Access. the right to obtain a confirmation that your Personal Data is being processed, access to your Personal Data (if we are in fact processing it), other data about the processing of your Personal Data (most of which is set forth in this statement) and a copy of the Personal Data we are processing. This includes the right to access, update or delete the information We have on You.

Rectification. the right to have Your Personal Data corrected if it is inaccurate, and depending on the purposes of processing, You may also have incomplete Personal Data completed.

Erasure. also known as the "right to be forgotten", the right to request your Personal Data be deleted under certain circumstances such as if it is no longer needed for the original purpose it was collected for or if You withdrew your consent. The right of erasure does not apply under limited circumstances including if the processing is necessary for exercising the right of freedom of expression and data or our compliance with a legal obligation.

Restrict processing. the right to restrict processing of your Personal Data under certain circumstances such as if you contest the accuracy of the Personal Data (and only for so long as it takes to verify that accuracy), the processing is unlawful and you have requested restricting the processing rather than erasure, or if we no longer need the Personal Data but you need it to establish, exercise or defend a legal claim.

Portability. the right to receive the Personal Data you provided to us (and not any other data) under limited circumstances such as if the basis for processing the Personal Data was consent or necessary for the performance of a contract with you, or the processing is carried out by automated means.

Automated Processing. the right to not be subject to a decision based solely on automated processing, including profiling.

Object to processing. the right to object to the processing of your Personal Data under the following circumstances:

Legitimate Interests. if the basis for which the processing occurs is in our legitimate interests or in the performance of a task carried out in the public interest. If you object, we will stop processing your Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or we require the Personal Data to establish, exercise or defend a legal claim.

Direct Marketing. if the processing is for direct marketing purposes.

You can exercise these rights by contacting us using the contact data listed here, however, we may need to request additional data from you to verify your identity before granting your request. We will respond to all requests we receive from individuals wishing to exercise such rights in accordance with the GDPR. We have the ability to charge a reasonable fee for administrative costs of providing the Personal Data to you in situations where the request is unfounded or excessive (due to its repeated nature), or in the alternative, we may refuse to act on the request in those situations.

Withdraw Your consent

You have the right to withdraw Your consent on using your Personal Data. If

You withdraw Your consent, We may not be able to provide You with access to certain specific

functionalities of the Service.

Lodging a Complaint

You have the right to complain to your data protection authority about our collection and use of your Personal Data. Please contact your local data protection authority for more data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Retaining Your Personal Data

We will store and retain your Personal Data in accordance with applicable law and as long as necessary to carry out the purposes described in this Section in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:

how long the Personal Data is needed in connection with the applicable purposes for which we use it;

The type of Personal Data collected

whether we are subject to a legal, contractual, or similar obligation to retain the Personal Data (e.g., mandatory data retention laws, government orders to preserve Personal Data relevant to an investigation, or Personal Data that must be retained for the purposes of litigation or disputes).

Cross-Border Data Transfer

By submitting Personal Data to us, we will, receive it in the United States where our technical infrastructure resides. We undertake such collection solely for the purposes described previously in this statement but note that such direct collection does not constitute a “transfer” under the GDPR. In certain instances, we collect Personal Data from data subjects located within the GDPR Jurisdictions, and do then transfer it to the U.S., to international organizations, and/or to third countries for the same purposes discussed above. When doing so, may use the mechanisms prescribed for lawful transfers in GDPR Articles 44 through 49, including, where appropriate, then-current standard contractual clauses or similar mechanism appropriate to the particular GDPR Jurisdiction involved. you can request further details in relation to international transfers, including a copy of the standard contractual clauses, by contacting info@onlineactivation.com

NEVADA PRIVACY NOTICE

Your Rights and Our Obligations Under Nevada Privacy Law

This privacy notice section for Nevada residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of Nevada.

If you are Nevada resident, Nevada law (SB 220), entitles you to opt out of the sale of certain kinds of personal data. A sale under Nevada law is the transfer of this personal data to third parties for monetary consideration. If you are a Nevada resident and wish to opt-out, you may do so by contacting us at any of the 4 methods here or click on the Opt-Out link at the bottom of our site

CCPA/CPRA CALIFORNIA

Your Rights and Our Obligations Under California Privacy Law

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Data Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

• Category A: Identifiers.

  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.

  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  Collected: No.

• Category D: Commercial information.

  Examples: Records and history of products or services purchased or considered.

  Collected: Yes.

• Category E: Biometric information.

  Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

  Collected: No.

• Category F: Internet or other similar network activity.

  Examples: Interaction with our Service or advertisement.

  Collected: Yes.

• Category G: Geolocation data.

  Examples: Approximate physical location.

  Collected: No.

• Category H: Sensory data.

  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

  Collected: No.

• Category I: Professional or employment-related information.

  Examples: Current or past job history or performance evaluations.

  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

  Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  Collected: No.

• Category K: Inferences drawn from other personal information.

  Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

  Collected: No.

• Category L: Sensitive personal information.

  Examples: Account login and password information, geolocation data.

  Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to provide advertising on our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide You with Our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission. If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

• The categories of personal information We collected about You
• The categories of sources for the personal information We collected about You
• Our business or commercial purposes for collecting or selling that personal information
• The categories of third parties with whom We share that personal information
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  • The categories of personal information categories sold
  • The categories of personal information categories disclosed

The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.

The right to correct Personal Data. You have the right to correct or rectify any any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.

The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.

The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

By email: info@onlineactivation.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
• We cannot respond to Your request or provide You with the required information if We cannot:
• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform: http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

We use Personyze to gain insights into our users' preferences and enhance our services and customer interaction. Personyze is a technological tool that assists us in comprehending how our users interact with our website (such as the time spent on various pages, the links clicked, likes and dislikes, etc.). This understanding aids us in tailoring and sustaining our services based on user feedback. Personyze utilizes cookies and similar technologies to gather information on user behavior and devices, including anonymized IP addresses, screen size, specific device identifiers, browser details, geographic location (country level), and the language chosen to view our site. The data collected through cookies is exclusively used in relation to our services and is never disclosed to any third parties. To opt out of Personyze and erase your data, please use the toggle below. You can read more by clicking here.

Personalization status:

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light Law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

CHANGES TO THIS PRIVACY STATEMENT

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and our mobile resources periodically for such changes since all data collected is subject to the Policy in place at the time of collection.

HOW TO CONTACT US REGARDING PRIVACY

If you have any questions about our privacy and data security policies, procedures, and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office.

info@onlineactivation.com