MAINSTREAM DATA PRIVACY POLICY

May 25, 2018

1. WHAT AND WHO THIS PRIVACY POLICY COVERS

Mainstream Data (“The Company”) is the data controller of personal data (e.g. information that identifies a specific person, such as full name or email address) we collect from and about you through the Company Services that are processed in compliance with the terms of this Privacy Policy.

This Privacy Policy applies to all users, including those who use the Company Services without being registered with or subscribing to a Company Service and those who have registered with or subscribed to a Company Service. The Company Services are for a general audience, are not targeted at children, and do not knowingly collect personal data from children under 16 years of age.

2. WHAT KIND OF PERSONAL DATA DO WE COLLECT?

The Company may collect (1) registration data when you sign up for a Company Service, (2) public data, and (3) activity data when you access and interact with a Company Service. The data the Company collects can include the following:

  1. Registration data. This is the information you submit to register for a Company Service, for example to create an account or receive a newsletter. This data may include, for example, name, surname, email address, gender, country, postcode, and birthday date.
  2. Public data. Public information is always public, which means it is available to everyone and may be displayed in search results on external search engines.
  3. Activity data. When you access and interact with the Company Services, we may collect certain information about those visits. For example, in order to permit your connection to the Company Services, our servers receive and record information about your computer, device and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information. Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology commonly called Flash cookies) may also be collected. These technologies may be used to collect and store information about your usage of the Company Services, such as pages you have visited, the video and other content you have viewed, search queries you have run and advertisements you have seen.
  4. Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information.

We do not collect:

  1. Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (Payment Service). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
  2. Sensitive Information: We ask that you do not send us, and you do not disclose, any sensitive personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Company Services or otherwise.

Finally, Company Services may also be linked to sites, including social media sites, operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or applications developed and maintained by unaffiliated companies. The Company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Company Services or click an advertisement you should review the applicable Privacy Policy of the other service.

3. HOW DO WE USE YOUR PERSONAL DATA?

We use the personal data we collect from and about you to:

  1. Provide the Company Services and features to you;
  2. Measure, analyze and improve those Company Services and features;
  3. Improve your experience with both online and off-line Company Services by delivering content you may find relevant and interesting;
  4. Provide you with customer support and to respond to inquiries;
  5. Protect the rights of the Company and others. For example, there may be instances when the Company may use your

personal data, including situations where the Company has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Company, our Company Affiliates or their employees, agents, contractors, licensors and suppliers (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Company Services or members of the public; (iii) protect the Company, as well as other third parties involved, such as Company suppliers, against fraud or for risk management purposes,

  1. Comply with applicable laws or legal process and/or respond to requests from public and government authorities;
  2. Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company business, assets or stock (including in connection with any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or a material part of its business, the Company may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction;
  3. With your prior consent, send (via email, SMS, telephone, chat and social media) to you offers, promotions and other

marketing communications regarding the Company Services and services/products of Company Affiliates, including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party or Company Affiliate that may be hosted on the Company Services or on the Company Affiliate or third party’s service;

  1. With your prior consent, send to you marketing communications customized to your interests and needs by means of the channels of communication set out under letter h) above.

We may use anonymized information or information that does no longer identify you personally, even indirectly (e.g. statistics) for any purpose or share it with third parties.

4. REVOKING YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA

You can revoke your consent to the processing of your personal data for the purposes of Paragraph 3, letters h) to i) at any time by sending a communication to the email address described in Paragraph 11 below.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data through both electronic and manual means, and it is protected through security measures, taking into account the state of the art, the costs of implementation and the nature, scope, context and purpose of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals. In particular, we use appropriate administrative, technical, personnel and physical measures to safeguard personal data in our possession against loss, theft and unauthorized use, disclosure or modification.

6. WHO CAN HAVE ACCESS TO YOUR PERSONAL DATA?

We may share your personal data for the purposes of Paragraph 3 to the following categories of recipients located within or without the European Union in compliance and within the limits of the provisions of Paragraph 7:

  1. Third parties service providers entrusted with processing activities and duly appointed as processors when required by applicable laws, e.g., cloud service providers, providers of services instrumental to or supporting the Company Service;
  2. Company Affiliates in their capacity of data controllers or data processors;
  3. Business partners after your prior consent; and
  4. Competent authorities in order to comply with applicable laws and regulations.

A complete list of the data processors may be requested from the Company at the address as per Paragraph 11 of this Privacy Policy.

7. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

Your personal data may be transferred to other countries (including countries other than where you are based that have a different data protection regime than the one existing in the country where you are based). If you are located in the European Economic Area (EEA), this may include countries outside of the EEA, including the United States of America. We have adopted appropriate safeguards to protect your personal data regardless of where it resides.

8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

You have the right to:

  1. Obtain confirmation as to whether or not your personal data exists on our systems and to be informed of its content and source, verify its accuracy and request its rectification, update or amendment;
  2. Request the deletion, anonymization or restriction of the processing of your personal data processed in breach of applicable law;
  3. Object to or request the limiting of the processing, in all cases, of your personal data for legitimate reasons;
  4. Receive an electronic copy of your personal data at a reasonable cost not to exceed the cost of gathering such data;
  5. You may send your request to the email address indicated under Paragraph 11. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, or delete.
  6. Remember that even after you cancel your account, or if you ask us to delete your personal data, copies of that information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services or, for example, when retention of such copies is necessary to comply with legal obligation or legal defense. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law.

9. RETENTION RIGHTS

We will retain your data only for the period necessary to fulfill the purposes for which the data was collected.

10.UPDATE TO THIS PRIVACY POLICY

The Company may modify or update this Privacy Policy for any reason. Please look at the Effective Date at the top of this Privacy Policy to see when it was last revised. If we make material changes to this Privacy Policy that change the nature of processing or expand our rights to use the personal data we have already collected from you, we will make such changes available on the Company Services and by email request directed to the email address listed in Paragraph 11 below.

11. CONTACT US

If you have questions about this Privacy Policy please contact us at the following email address privacy@mainstreamdata.com.