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Privacy Policy

updated July 2018

As a Company that believes that data is the cornerstone of the future, we treat data privacy with the ultimate care and attentiveness. As such, we adhere to all legal requirements related to data privacy, including the Processing of Personal Data (Protection of Individuals) Law of 2001, and the implementation therein of Regulation (EU) 2016/679 in the matter of General Data Protection Regulation (GDPR). Our Company further takes reasonable efforts and measures to ensure compliance with data protection legislation in all countries where it offers its services. In addition, we have taken our data privacy policy to additional levels, not required by law. Our company has a zero tolerance policy relating to breach of data privacy and we expect a stringent level of protection from our Company, its employees and its agents. We appreciate the importance of protecting personal information and recognize the trust placed in us when supplied with personal information. We recognize the importance of data privacy and that every individual and entity has the right to control how his or her personal information is collected and used.

DATA COLLECTION AND USE.

When you view our Company's ad on a site or application, we may collect information about your device that you have viewed. This information enables our Company to improve services, including recognizing your device when you use other sites and applications that have partnered with us. Our Company collects data about your browser or device, and we do not intentionally collect information that reveals your real-world identity, such as your name, address or the name of your pets. The non-sensitive data information our Company collects includes common information found in every communication sent over the internet, from which we infer things: browser type; operating system; IP address etc. We may also receive additional data in order to calculate unique identifiers, such as location data. Any personal information is anonymized and you retain all rights to opt out of the collection of sensitive information. You may further ask us to access the personal information collected by us, to correct or update any inaccurate information we hold. If you choose to opt-out our Company will no longer use the information connected to you. Please note that you may still see the same amount of ads displayed, however these may be less of relevance due to the data opt-out. We partner with third-party website publishers and app developers to analyze and provide audience segmentation service. Based on our affiliation with marketing and advertising agencies you may then receive ads which are customized to user interests and geographic locations, which third-parties may derive or infer from information that we collect about how users interact with sites and apps. This enables our partnering publishers and developers to provide content-rich services that are more relevant to their users. We may also obtain your user data from our data partners, directly or through cross-data collection, for optimising digital advertising and/or analytical purposes. Please note that the collection, use or storage of such data is governed both by this privacy policy as well as that of such party that provides the data. In addition, we take steps designed to ensure that data segmentation is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners.

WE BELIEVE IN DATA PROTECTION, TRANSPARENCY, COMPLIANCE, SECURITY, SAFEGUARDS & TRUST.

Our Company, its employees and its agents shall comply fully with all applicable, laws, rules and regulations, including those of Cyprus and any and all other jurisdictions globally, which apply to the Company's business activity. The Company's employees and agents shall familiarize themselves with the Processing of Personal Data (Protection of Individuals) Law of 2001, the provisions of the GDPR, and this Company Policy, all as may be amended from time to time; shall comply with such Act, Regulation or Policy; and will take no action that will cause the Company to violate such Act, Regulation or Policy. Our employees are trained to manage data in such a way that complies with our Privacy Policy. Our Company shall provide its employees with ongoing training and updates regarding our Policy and relevant legislation. With your interest in mind, we ensure that privacy is integrated into the design and architecture of our systems and processes. We work only with sources that have opt-in/opt-out capabilities, ensuring customer consent to share personal data. We collect the following data: device type (e.g. smartphone, tablet, etc.),operating system (e.g. iOS, Android, Windows, Blackberry), network provider, mobile browser used (e.g. Safari, Internet Explorer etc.),platform, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for Advertising, iOS Identifier for Vendors, model, manufacture of device, OS version of device, session start/stop time, locale (specific location where a given language is spoken), time zone, network status such as WiFi, the geo-location of your device (using GPS or other geo-location data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID) etc. In some countries, we also collect information such as international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data, which may be considered to be personal information and in which case, we ensure compliance with applicable laws in our collection or use of the same, to the extent applicable in such jurisdictions. All the data we collect is kept anonymous at all times. All data is diligently stored in such a way that protects it from malicious attacks and unauthorized access, utilizing high-end security safeguards and encryption capabilities. We take all reasonable steps to securely store and protect data from interference, unauthorized use, disclosure, access, modification, loss or misuse. This include confidentiality requirements for employees and agents and having in place data storage security, policies, systems and site access restrictions. We monitor all database access to locate and prevent any unauthorized access and any breach of our security. We ensure the use of data only for specified purposes and will never store any data that is no longer required by our Company. The data collected by our Company is never shared with unauthorized third parties. Any transfer of data to third parties shall only be undertaken if such party is GDPR compliant and fully accepts the terms and conditions herein as well as the privacy level our Company adheres to. We will not sell, rent or trade or otherwise make your data available to unauthorized third parties. All data is analyzed by compliant agents or in-house and is never stored beyond the time needed to analyze such data. All segmentations, demographic compilations, audience identification, traffic analysis and other forms of optimization statistics shall be devoid of identifying information. Our Company and its employees and agents will not act or engage in a practice that contravenes a protective data security standard in respect of data collected, held, managed, used by us and in respect of data systems kept by us. Our Company further commits to undertake security risk profile assessment based upon our above commitments, and as necessary implement changes to our Privacy Policy and protective data security plan.

WE COMMIT TO PROTECT YOUR DATA AND RESPECT YOUR PRIVACY.

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