PRIVACY POLICY

Effective as of August 3rd, 2019

1. GENERAL PROVISIONS

1.1 This document uses the same terminology and abbreviations as our End User License Agreement. This Privacy Policy governs the collection, use and storage of Information obtained from Users through the use of our Software and our website (collectively referred to as Platform).

1.2 The Information on Users is divided into personally identifiable and non-personally identifiable Information depending on whether Information can identify the User as a specific person. Information about legal persons does not fall within the scope of Information as defined in our Terms of Use and Privacy Policy documents.

2 CLICKS MEDIA, SPRINGATES BUILDING, LOWER GOVERNMENT ROAD, CHARLESTOWN, NEVIS, UNITED KINGDOM, has a position of a ‘Controller’ as defined in EU GDPR and we shall be responsible for, and be able to demonstrate compliance with, the principles relating to processing of personal data. We can be contacted by sending an e-mail to [email protected] or by telephone at: +35635505035.

2. COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION

2.1 We may obtain some of your personal Information in order to provide our Services. The Information we collect is necessary to provide our Services, and we shall not collect any Information which is not required by the nature of our Services. We may collect some of the following personal Information:

• IP address and server log files

• Information about the User’s device

• Other information which you choose to provide

(A) IP ADDRESS AND SERVER LOG FILES

2.2 e integrate security systems on our Platform to prevent malicious attempts and exploits of the Platform. We scan IP addresses and ban IP addresses that show malicious signs such as seeking exploits. We process this information in the interest of protecting the integrity of the Platform and of the databases connected with it. We collect your IP address on the basis of a legitimate interest to maintain the integrity and safety of our databases.

2.3 The Platform collects a series of general data and information when a person accesses the Platform. This general data and information are stored in the server log files. Information that is collected includes (1) the software and browser types and versions used, (2) the operating system used by the accessing system, (3) the date and time of access to the Services, (4) the Internet service provider of the accessing system, and (5) any other similar data and information that may be used in the event of attacks on our information technology systems.

2.4 We collect this information for breach investigation purposes. When using this information, we may connect specific log files with specific Users. This information is needed to (1) troubleshoot problems and correct system bugs, (2) deliver the content of our Platform correctly, (3) optimise the content of our Platform as well as its advertisement, (4) ensure the long-term viability of our information technology systems and website technology, and (5) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. We collect this information based on our legitimate interest and for compliance with legal obligations.

2.5 We may also distinguish identifiers from your IP address to narrow down the approximate location of the User down to the country level in order to provide the content that may be of relevance to the specific User. We process this information based on our legitimate interest and in some cases based on our contractual relationship with the User.

2.6 You may at some point choose to provide other information which is not required for the proper functioning of the Services, such as your name, address, details from your personal life, your personal stories and similar. In all such cases we will use this information only for the purpose for which you disclosed it, for example we may use your name to address you in communication, or we may use other details to display with the content you provided. If we are not sure as to why you are providing such Information we will contact you wherever possible. Otherwise we will delete such information.

2.7 Some Services will not be available to you if you do not provide the requested Information. We may keep records of any questions, complaints or compliments made by you and the response, if any. Whenever you contact us, we shall collect any information which you chose to provide. We shall store and use this information only for the purpose of responding to your enquiries. Information contained within the enquiry, free from any personally identifiable Information, will be stored on our servers for the purpose of improving our Services and providing the best customer support possible.

2.8 We do not sell or rent personal Information to any Third-Party. We use collected Information for our internal and marketing purposes, as necessary by the nature of the Services, and only in accordance with this Privacy Policy. In some instances, we are obliged to comply with court orders and government requests and provide Information or parts of it to authorised bodies.

2.9 We may disclose your personal information to our partners, agents and operators who we believe reasonably need to come into contact with that information under confidentiality or similar agreements, in order: (i) to provide Services per your request; (ii) to administer our business or the Site; (iii) to provide customer support; (iv) to update account information; (v) to forward updates, announcements, and newsletters; (vi) to respond to your communications, and communicate with you about the Site and other activities related to the Site; (vii) in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of the Site’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or (viii) as otherwise authorised by you.

2.10 We have implemented security procedures and measures in order to ensure appropriate protection of the Information we process, against any misuse, unauthorised access, disclosure or modification. We will remove any Information about you upon your request no later than thirty (30) days after the request has been made.

2.11 We acknowledge that the safety of your Information is one of the highest priorities and therefore only authorised processors have access to your information. Although we take all appropriate measures in respect to keeping your information secure, you understand that no data security measures in the world can offer 100% protection. If we ever find or suspect a personal data breach we will without delay, within seventy-two (72) hours after becoming aware of it, notify the appropriate supervisory authority about the breach and Users where necessary.

2.12 The processing of the information is being performed automatically, without human intervention. However, whenever you contact us through email, the Information within the email will be handled and processed by a real person in order to provide you with the answer to the email.

2.13 2.13 Users may request access to, modification and erasure of personal Information and exercise the right to object. Such requests should be submitted to [email protected]

3. STORAGE AND TRANSFER OF INFORMATION

3.1 Information will be stored on secure servers hosted by Amazon Web Services Inc., 1200 12th Avenue South, Suite 1200, Seattle, WA 98144, United States (AWS) and which are hosted globally. Hosted servers are controlled and maintained in accordance with sufficient privacy safeguards. AWS may store or transfer Information on data subjects located in the EU to servers located in countries deemed adequate by the European Commission, or in countries which the European Commission has not deemed inadequate, provided that such countries implement appropriate and suitable safeguards regarding the security of personal information.

3.2 Information is stored on the servers only for the duration necessary for providing the Services and maintaining the integrity of our databases. We will maintain records of processing activities for the purpose of demonstrating compliance with EU GDPR.

3.3 Some services require the use of third-party solutions. When you are redirected from our Site to the third-party website you are no longer interacting with our Site. Any information that you provide through third-party websites will be handled and processed in accordance with their Privacy Policies and other applicable terms.

4. THIRD PARTY WEBSITES, SERVICES, AND COOKIES

4.1 The Site or e-mails may contain links to other external websites that do not fall under our domain. We are not responsible for the privacy practices or the content of such external websites. If you choose to follow such links to external websites, you do so at your risk.

4.2 Cookies help us optimise and improve the user experience of the Site by helping us deliver crucial functionalities. The cookies we use may vary over time as we continuously update and improve our Site and Services. We may use third party services like Google Analytics and others. Cookies from such services are used to collect data for statistical reports.

4.3 You can manage your cookies preferences at any time. This is done in your browser or device settings. Depending on which browser and device you use you may be able to control which cookies you allow, which cookies you want to block in the future, and delete cookies. For more information about these settings visit your browser or device´s help page. Note that some of our Services might not work as intended if you choose to disable cookies.

4.4 Third-party vendors, including Google, use cookies to collect anonymous statistical data. Any data collected will be used in accordance with our Privacy Policy and Google’s privacy policy. Users may opt out of Google’s use of Google Analytics by visiting the Google Analytics Opt-out Page. Users may opt out of third-party vendor use of cookies by visiting the Network Advertising Initiative Opt-out Page. http://optout.networkadvertising.org/#/.

4.5 The Software may include Yahoo’s, Microsoft’s, or Google’s search feed. You can read their privacy policies here on the following links: for Yahoo: https://info.yahoo.com/privacy/us/yahoo/search/details.html, for Microsoft: http://go.Microsoft.com/fwlink/?LinkID=248686 and for Google: https://www.google.com/policies/privacy/.

5. LICENSE

5.1 Subject to your compliance with this Agreement, we grant you a limited, non-exclusive, non-transferable, non-sub licensable license to access and use the App. Except as expressly permitted in this Agreement, you may not:

• make any modification, adaptation, improvement, enhancement, translation, or derivative work from the App;

• distribute, transfer, sublicense, lease, lend or rent the App to any third party;

• decompile, reverse engineer, disassemble, attempt to derive the source code of, or decrypt the application;

• remove, alter, or obscure any proprietary notice (including any notice of copyright or trademark) posted by us or the licensors of the App; or

• make the functionality of the App available to multiple users through any means.

5.2 Nothing in this Agreement shall operate to assign or transfer any Intellectual Property Rights from us to the User, or from the User to us.

5.3 Nothing in this Agreement shall give to the User or any other person any right to access or use the source code or constitute any license of the source code.

5.4 We reserve the right to modify, suspend or discontinue, temporarily or permanently, the App or any service to which it connects, with or without notice and without liability to you.

5.5 Upon installing the Software may make changes to your browser such as adding an extension for the Software or changing the default search engine or default browser.

5.6 The Software may provide links leading to Third-Parties or be made available or accessed through Third-Party services and content (including advertising) that we do not control. Users acknowledge that different Terms of Service and privacy policies may apply to Users’ use of such Third-Party services and content. In no event will we be responsible or liable for any content or services of such Third-Party providers.

5.7 The Software may contain or be provided in connection with Third-Party open source software. Insofar where use of the Software involves use of open source software you understand and agree that your use of the Software is further regulated by the terms of the open source license. You may review the terms of the open source license on the following link:

6. INFORMATION RETENTION PERIOD

6.1 If you download and install our Software, we will store your Information for as long as the Software is installed on your device. As soon as you uninstall the software we will remove all personally identifiable Information we have collected about you unless we have appropriate legal grounds for continuing their processing.

7. USER’S RIGHTS

7.1 You may request to:

• Obtain confirmation if your Information is processed, access Information about you that we had stored as well as supplementary information.

• Receive a copy of Information on you that is held by us in a structured, commonly used and machine-readable format.

• Correct your Information.

• Have your Personal Information deleted.

• Object to the processing of Information by us.

• Restrict the processing of your Information by us.

• File a complaint with a supervisory authority.

7.2 These rights might be limited if they are subject to our own legitimate interests and regulatory requirements.

8. CHANGES TO THE PRIVACY POLICY

8.1 We reserve the right to change our Privacy Policy at any time. The current version of our Privacy Policy is available through the Site, indicating the effective date. You are encouraged to periodically check our Privacy Policy.

9. CONTACT INFORMATION

9.1 If you have any queries or concerns regarding our Privacy Policy and how the information is handled, or you wish to access, retrieve, amend, or update your Information feel free to contact us at [email protected]