PRIVACY POLICY

ALZ Software Limited ("we" or "us") are committed to protecting and respecting your privacy. This privacy policy should be read in conjunction with the General Business Terms and Conditions for Business, the applicable Service Order Form, Schedules and specific terms agreed through the Clickio Platform (the "Terms").

Capitalized terms used in this privacy policy (the "Policy ") shall have the same meaning as in the Terms except to the extent expressly stated in this Policy. For convenience the Capitalized Terms have been reproduced at the end of this Policy in the Glossary section.

This Policy applies to all Personal Data that we collect from you in relation to your account registration, set up and operation of your Personal Account but excluding Publisher Personal Data (" Publisher Account Data").

In the event of any conflict between the Terms and this Policy, the terms of this Policy take precedence in relation to the Publisher Account Data. Terms relating to the processing of your Publisher Personal Data are set out in clause 8 of the Terms.

1. WHO WE ARE

The data controller responsible for the Publisher Account Data is ALZ Software Limited. In this Privacy Policy references to ALZ Group means us, our subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (as subsidiary and holding company are defined in s1159 Companies Act 2006) ("ALZ Group").

If you have any questions or concerns relating to your Publisher Account Data or this Policy, please contact us using the following contact details:

Alexander Azarov

support@clickio.com

ALZ Software Limited, Unit 2.05, 12-18 Hoxton Street, London, UK, N1 6NG

Whilst you have the right to make a complaint at any time to the Informational Commissioner's Office (www.ico.org.uk), we would like to have a chance to deal with any concerns before you approach the ICO.

2. YOUR DUTY TO LET US KNOW OF CHANGES

This Policy was last updated on 24th May 2018. We may need to make updates or changes to this Policy from time to time. We will inform you of any such changes.

Accurate data is key to our ability to deliver services. You must inform us without delay in writing or by email at support@clickio.com in the event of any changes or inaccuracies in the Publisher Account Data.

3. PUBLISHER ACCOUNT DATA WE MAY COLLECT FROM YOU

We may collect, use, store and process the following types of Publisher Account Data:

Contact Data includes your company name, username (or similar identifier), password, billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Profile Data includes your interests, preferences, feedback.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Clickio Platform, Code and Network.

Usage Data includes information about how you use the Clickio Platform, Code and Network.

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your Publisher Account Data but is not considered Personal Data as it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with Publisher Account Data so that it can directly or indirectly identify personal data, we treat the combined data as Personal Data which will be used in accordance with this Policy.

4. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect Publisher Account Data, including through:

Direct interactions . You provide us with Contact and Financial Data by registering on the Clickio Platform, creating a Personal Account and using the Network.

Automated technologies or interactions. As you interact with our website, the Network and the Clickio Platform, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below for further details.

Third parties. We may receive Personal Data about you from various third parties where you have expressly consented to do so.

5. USES MADE OF YOUR PUBLISHER ACCOUNT DATA

We will only use the Publisher Account Data when the law allows us to. In particular,

• Where we need to perform the contract for services we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

We have set out below a description of all the ways we may use the Publisher Account Data and the legal bases we rely on to do so. Note that we may process the Publisher Account Data for more than one lawful ground. Please contact us if you need details about the specific legal ground we are relying on to process your Publisher Account Data where more than one ground has been set out in the table below.

Function

Type of data

Lawful basis for processing including basis of legitimate interest

To create a Personal Account and register to use the Clickio Platform, Code and Network.

(a) Contact

Performance of the services under the Terms

To process and deliver the services requested in the Service Order Form

(a) Manage payment of Commission and or any other charges

(a) Contact

(b) Financial

(c) Transaction

Performance of the services under the Terms

To manage our relationship with you which will include notifying you about changes to our Terms or this Policy and communicate technical changes to the Clickio Platform, Code and Network

(a) Contact

(b) Transaction

(a) Performance of the services under the Terms

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how Publishers use the Network)

To administer and protect the Clickio Platform, Code and Network (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Contact

(b) Technical

(a) Necessary for our legitimate interests (for running of the Clickio Platform, Code and Network, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve you

(a) Contact

(b) Preference

(c) Usage

(d) Technical

(a) Necessary for our legitimate interests (to grow our business and to inform our marketing strategy

To use data analytics to improve the operation and performance of the Clickio Platform, Code and Network

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

6. DISCLOSURE OF INFORMATION

We may have to share your Publisher Account Data with Third Parties or otherwise within the ALZ Group for the purposes set out in the table in above.

We require all Third Parties to respect the security of the Publisher Account Data and to treat it in accordance with the law.

We may disclose information if legally required to do so, if requested to do so by a governmental entity or regulatory authority, or if we believe in good faith that such action is necessary to comply with legal requirements or process, prevent a crime or protect national security.

If you engage, or we reasonably suspect that you are engaging, in any illegal activity, we may disclose your Publisher Account Data, to the extent we determine in our sole discretion is necessary to cooperate with appropriate authorities.

7. SECURITY

Although the transmission of data over the internet may be subject to intrusion, we protect your Publisher Account Data by ensuring we have implemented appropriate physical, electronic and procedural safeguards to avoid unauthorised access or disclosure, accidental loss, use, alteration or destruction of such Information.

Where we engage third-party contractors, as far as is necessary, we may share information in order for such parties to perform services on our behalf and in accordance with enforceable confidentiality obligations.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. MAINTENANCE AND RETENTION OF PUBLISHER ACCOUNT DATA

You have certain rights in relation to your Publisher Account Data. Please contact us by email, should you wish to:

• Request access to your Publisher Account Data - enables you to receive a copy of the Publisher Account Data we hold about you and check that we are lawfully processing it.

• Request correction of your Publisher Account Data - you may correct any inaccuracies or incomplete data although we may need to verify the accuracy of the new data you provide.

• Request erasure of your Publisher Account Data - where there's no good reason for us to continue to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your Publisher Account Data to comply with local law.

• Object to processing of your Publisher Account Data - where we are relying on a legitimate interest and you object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

• Request restriction of processing your Publisher Account Data - This enables you to ask us to suspend the processing of your Publisher Account Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your Publisher Account Data - you may request that we transfer data to you or a third party. This only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent to our use of your Publisher Account Data - where we are relying on consent. This will not affect the lawfulness of processing that we carried out before you withdraw consent. If you withdraw consent, we may not be able to provide products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of these rights. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex in which case we will let you know and keep you updated.

We will only retain your Publisher Account Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Publisher Account Data, we consider the amount, nature, and sensitivity of the Publisher Account Data the potential risk of harm from unauthorised use or disclosure of the Publisher Account Data, the purposes for which we process your Publisher Account Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our Publishers (including Contact, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your Publisher Account Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. COOKIES

Cookies are small amounts of information which we may store on your computer. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalise the content of the Personal Account and the Network for you. You may set up your computer to reject all or some cookies although, in that case, you may not be able to use certain features of the Network or the Publisher Account If you do not wish to receive cookies in the future, please let us know.

11. DEFINITIONS

"Advertisement" means the advert placed in the Advertising Space by the Publisher.

"Advertisers" means clients of ALZ who provide the Publishers with Advertising Material to be incorporated or embedded in the Publishers Advertising Space.

"Advertising Materials" means, without limitation, textual information, graphical information and text-and-graphic blocks, as well as any other interactive materials, relating to goods or services of the Advertiser and/or the Advertiser's clients, that contain hypertext links to web pages or websites containing information on or offering for sale the relevant goods or services of the Advertiser and/or the Advertiser's client each as designated by the Advertiser.

"Clickio Platform" means the proprietary software and technology platform licensed to ALZ and available to be accessed and used by the Publisher on the terms of the Agreement via the URL address http://clickio.com. ALZ act as an authorised licensee and operator of the Clickio Platform. All interactions between the Parties are carried out exclusively via the Clickio Platform.

"Commission" means the income generated by the Publisher in allowing Advertisers to use the Publisher's Advertising Space. Commission is determined by the Tariff selected by the Advertiser and the number of Events that occur. Commission is payable to the Publisher by ALZ.

"Customer Specific Terms" means the specific terms (if any) that the Publisher and ALZ agree through the Publisher's Personal Account within the Clickio Platform.

"Code" means ALZ's proprietary software code designed for placement on a Publisher's website for the purposes of advertising the Advertising Material in the Advertising Space.

"Data Protection Legislation" means all applicable laws and regulations relating to processing of personal data and privacy, including without limitation the Data Protection Act 1998 and GDPR (as applicable) and including where applicable the guidance and codes of practice issued by the Information Commissioner or any other relevant Regulator;

"Data Subject" has the same meaning set out in the GDPR;

"Demand Sources" means third party buyer global demand side clients of ALZ including but not limited to ad exchanges such as Google Ad Exchange, OpenX and Citreo;

"Event" means affirmative action of an internet user relating to a specific Advertisement placed on the Publisher's website which leads to the Publisher generating an income pursuant to section 6 below. The nature of the Event will depend on the applicable Tariff;

"GDPR" means the General Data Protection Regulation as may be amended from time to time or replaced as a result of the UK ceasing to be a member state of the European Union;

"Personal Account" means the Publisher's own individual account that is created on the Clickio Platform website ( http://clickio.com);

"Personal Data" shall have the same meaning as set out in the GDPR;

"Processing" has the same meaning set out in the GDPR and the terms 'Process', 'Processed' and 'Processes' will be interpreted accordingly;

"Processor" has the same meaning set out in the GDPR;

"Publisher Personal Data " means all Personal Data that is used or generated in the operation of this Agreement that belongs to the Publisher or of which the Publisher is the Controller in respect of including but not limited to Publisher User Data;

"Publisher User Data" means Personal Data in relation to users and or clients of Publisher;

"Purposes" means the purposes of registration, participation, use of the Network (including the Clickio Platform), payment of Commission and otherwise in order to perform the services under this Agreement in accordance with this Agreement;

"Regulator" means any supervisory authority for the purposes of Data Protection Laws (including, but not limited to the ICO) to which ALZ or Publisher is subject from time to time or whose consent, approval or authority is required so that ALZ or Publisher can lawfully Process Personal Data;

"Service Order Form" means the Service Order Form attached to this Agreement and the schedules incorporated within it together with any subsequent Service Order Form(s) and attached schedules that the Parties may agree from time to time to annex to this Agreement

"Tariff" means the different methods available to the Advertisers in allowing their Advertising Material to be Advertised by a Publisher. The Tariff determines the way in which the Publisher can generate an income from the Advertisement. The Publisher does not select the Tariff that applies to the Advertisement. The different Tariffs are identified at section 6 below.

"Third Parties" means third party service providers appointed by ALZ to provide the services under this Agreement to Publisher including, Google (G Suite), Intercom, Leaseweb (Netherlands), Hetzner (Germany), Luxup, Payonner, Paymaster 24 Prosperworks,Targetprocess, Tipalti, Xero.

We reserve the right to modify this Policy from time to time.

Dated 24 May 2018