PRIVACY POLICY

GENERAL

This Privacy Policy governs collection, processing, storing and use of your personally identifiable information and other personal data required for using and/or related to your use of the Clickio software and technological platform available via the domain and website http://clickio.com (the "Clickio Platform"), which is provided and operated by ALZ Software Limited, a company registered and operated under the laws of England, with its address at: Hamilton House, Mabledon Place, London, UK, WC1H 9BB and/or its subsidiaries or affiliates (collectively, the "Operator"). This Privacy Policy constitutes an integral part of the Advertising Services Offer Agreement governing your relationship with the Operator (the "Offer Agreement") and is a legally binding agreement between the Internet user accepting the terms of the Offer Agreement and this Privacy Policy ("You") and the Operator governing collection, processing, storing and use of your personally identifiable information and other personal data required for you using and/or related to your use of the Clickio Platform, and its provisions may be enforced against you under applicable law. Please read and review this Privacy Policy before submitting any personal data to or with help of the Clickio Platform. By submitting any personal data to or with help of the Clickio Platform, or otherwise accessing or using the Clickio Platform, you acknowledge that you have read, understand and agree to be legally bound by this Privacy Policy without limitation. This Privacy Policy is subject to change; please review the Privacy Policy each time you access and/or use the Clickio Platform. By submitting any personal data to or with help of the Clickio Platform, or otherwise accessing or using the Clickio Platform, you shall be deemed as having accepted the most recent version of this Privacy Policy. If you do not agree to the terms of collection, processing, storing and use of your personally identifiable information and other personal data set forth in this Privacy Policy, you may not submit any personal data to or with help of the Clickio Platform, or otherwise access or use this Clickio Platform in any way.

COLLECTED INFORMATION

In certain instances of using the Clickio Platform discussed below, you may be prompted by the Clickio Platform to provide information about you that may identify you (your "Personal Data"). Personal Data submitted by you through and with help of the Clickio Platform and collected from you via the Clickio Platform may include the following information:

You agree that the Operator may collect your Personal Data in certain instances, such as, but not limited to:

You agree that all Personal Data you provide via the Clickio Platform must and will be correct, truthful, current, and complete. Providing false information about your identity is forbidden. If the Operator believes that the Personal Data you provide is not correct, current, or complete, or is false or misleading, the Operator has the right to refuse, suspend or terminate your access to the Clickio Platform or any of its resources and to suspend or terminate your personal profile at any time.

You hereby agree that if you do not want the Operator and/or its designated Personal Data processing contractor to collect, process, store and/or use any of your Personal Data, you may not or will not be able to use certain functionality of the Clickio Platform, order Services via the Clickio Platform, or use those sections or modules of the Clickio Platform that require or may require your Personal Data in accordance with their designated purpose.

PERSONAL DATA OF CHILDREN AND TEENS

The Clickio Platform is intended for use by adults only. The Operator and its designated Personal Data processing contractor (if applicable) do not knowingly collect, process, store, use or disclose Personal Data of children younger than 13 years of age and teens aged between 13 and 18 years of age.

To use the Clickio Platform and submit your Personal Data, you must be both (1) at least 18 (eighteen) years of age, and (2) of legal age in the jurisdiction from which you access and use the Clickio Platform. Any use by you of the Clickio Platform shall be deemed to constitute your conformance with this requirement.

The Operator reserves the right to report attempts of use of the Clickio Platform by the minors to the appropriate authorities.

If the Operator has learned or has sufficient grounds to believe that Personal Data is submitted by a child or a teen instead of an adult, the Operator reserves the right to suspend the personal profile through which the Personal Data was submitted and request provision of an e-mail address of the parent or legal guardian of the submitting person so that the Operator can notify the parent or legal guardian that their child or teen has provided Personal Data through the Clickio Platform and provide an opportunity for the parent or legal guardian to request the deletion of that Personal Data from the relevant records. The Operator will contact the parent or legal guardian at the e-mail address provided and the parent or legal guardian will have 48 hours from delivery of the e-mail to advise who exactly submitted the Personal Data. If the parent or legal guardian fails to reply to the query sent to the provided e-mail address, the Operator will assume that the parent or legal guardian has not consented to collection and processing of their child’s or teen’s Personal Data, after which the related personal profile will be immediately terminated and the Personal Data in question will be purged from Operator’s and/or its designated Personal Data processing contractor’s records.

PRINCIPLES OF PROCESSING

The Operator and/or its designated Personal Data processing contractor (if and where applicable) collect, process, store and use your Personal Data in accordance with the following general principles:

PURPOSES OF PROCESSING

The Operator and/or its designated Personal Data processing contractor (if and where applicable) collect, process, store and use your Personal Data solely for the following purposes:

YOUR CONSENTS TO PROCESSING AND DISCLOSURE

You hereby expressly acknowledge and agree that you grant the Operator, its affiliates, subsidiaries, controlling and controlled companies and designees, as well as its designated personal data processing contractor(s) (if and where applicable) your consents granted under this Privacy Policy with respect to collection, processing, storing and use of your Personal Data by yourself, voluntarily and by your free will, in your own interests and consciously.

You hereby expressly consent to the collection, processing, storing and use of your Personal Data by the Operator by all means and for all purposes outlined in this Privacy Policy and under applicable law, including, but not limited to, this Section of the Privacy Policy, and disclosure of your Personal Data in accordance with this Privacy Policy.

The Operator may from time to time engage third parties to perform functions on behalf of the Operator, such as hosting or operating the Clickio Platform, receiving and processing payments made by you via the Clickio Platform, sending e-mail communications, carrying out user behavior analysis and performing other functions. You hereby grant your express consent to the Operator to share your Personal Data with such third parties in order for them to perform such functions and to disclose your Personal Data to such parties where and when required.

The Operator may from time to time require sharing your Personal Data with other entities affiliated with the Operator, such as (but not limited to) Operator’s subsidiaries and controlling or controlled entities for internal business and operational purposes. You hereby grant your express consent to the Operator to share your Personal Data with such entities affiliated with the Operator and to disclose your Personal Data to such entities where and when required.

The Operator, where and when applicable or desirable, may engage third parties, such as the Operator’s designated Personal Data processing contractor, to process your Personal Data on Operator’s behalf. You hereby grant the Operator your express consent to share your Personal Data with such designated Personal Data processing contractor and to disclose your Personal Data to such contractor where and when required or desirable.

In certain instances, your Personal Data may be processed by Operator’s designated Personal Data processing contractor located in a certain jurisdiction outside of your jurisdiction of domicile in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. You hereby grant your express consent to cross-border transfer of your Personal Data to such third parties located in jurisdictions outside of your jurisdiction of domicile and to processing of your Personal Data by same.

In certain instances, your Personal Data may be processed by Operator to fulfill your payments made via the Clickio Platform, including but not limited to payments for ordered Services. You hereby grant your express consent to the Operator to process any Personal Data that may be received from you during such transactions, and share your Personal Data with third parties such as payment services providers and banks in order for them to be able to fulfill your payment requests.

ADVERTISING AND SURVEYS

The Operator or third party advertisers may use your e-mail address for sending you notifications and other informational and promotional materials about the new functionality and services available on the Clickio Platform or other services and products, and the Clickio Platform may display online advertisements. You hereby grant your express consent to receive such informational and advertising materials. Your e-mail address will not be used for sending you unsolicited advertising messages ("spam").

The Operator may, from time to time, conduct Clickio Platform surveys with voluntary participation required to improve and enhance your user experience with the Clickio Platform. You hereby grant your express consent to receive offers of participating in such surveys. If and to the extent you participate in such surveys, you hereby grant the Operator your express consent to processing of your Personal Data that you may be required to submit when completing such surveys.

ANONYMOUS DATA

In addition to your Personal Data, whenever you access or use the Clickio Platform the Operator and/or its designated third parties may automatically or passively collect certain information relating to your Internet and Clickio Platform use, such as information about your Internet service provider, your device’s operating system and device from which you access and use the Clickio Platform, browser type and build, type and serial number of your mobile device (where applicable), Internet protocol address, mobile network and country codes, time zone, domain name and/or URL address from which you access the Clickio Platform, the pages and areas of the Clickio Platform that you visited, Clickio Platform functionality you used, the date and time you accessed the Clickio Platform, and other information about your web surfing preferences and interests that is not personally identifiable. You hereby expressly agree that collection of such anonymous information does not constitute collection, use or other processing of your Personal Data. Notwithstanding this, you hereby grant the Operator, all of its affiliates, subsidiaries and designees, including but not limited to the Operator’s designated Personal Data processing contractor your express consent for collection, use and other processing of all anonymous information described above.

Any and all anonymous information collected and processed by the Operator and/or its designated third parties is used strictly for the purposes of improving the Clickio Platform, as well as for marketing purposes. You hereby agree that the Operator and/or its designated third parties are free to disclose any and all such anonymous information to third parties of their choice, including but not limited to third party advertisers and other parties.

ACTION REQUIRED BY LAW AND OTHER SPECIAL CIRCUMSTANCES

Notwithstanding that the Operator, its affiliates, subsidiaries and designees, as well as its designated Personal Data processing contractor treat your Personal Data in a strictly confidential manner and do not and will not disclose it to third parties without your prior written consent or not in accordance with your consents granted herein, the Operator and mentioned parties reserve the right to disclose your Personal Data to third parties at their sole discretion and without obtaining your prior consent and without notification to you in the following special circumstances:

DATA SECURITY

The Operator uses commercially reasonable technical, organizational and administrative measures to ensure protection and security of your Personal Data. The Clickio Platform and the servers hosting the Clickio Platform utilize certain electronic security measures designed to protect against the loss, misuse, and alteration of the information under Operator’s control, including Personal Data, which measures fully correspond to requirements set forth under applicable law. However, you acknowledge and agree that no electronic data transmission or storage of information can be guaranteed to be fully secure, and while the Operator makes and will continue to make the discussed measures to ensure protection and security of Clickio Platform-related network and systems and safety of your Personal Data, the Operator cannot and does not guarantee that security measures implemented on the Clickio Platform will prevent third-party hackers or other malefactors from illegally obtaining information about you, including your Personal Data.

Please note that the Operator cannot ensure or warrant the security of any information you transmit via the Clickio Platform, including your financial transaction information. You hereby expressly acknowledge and agree that you use the Clickio Platform at your own risk.

COOKIE POLICY

The technologies used in relation to the Clickio Platform may include cookie files. A "cookie" is a small data file that can be sent to and placed on your computer’s hard drive or mobile device, whichever is applicable, when you access and use the Clickio Platform. The Operator may deploy cookie files to collect, store, and sometimes track information for statistical purposes to improve the Clickio Platform and the functionality and services it offers, as well as to store user preferences, to record session information, to record user-specific information on what pages you access or visit, to record past activity on the Clickio Platform to provide better service when you return to the Clickio Platform, to ensure that you are not repeatedly sent the same advertising or notifications, and to collect other information that you send or that may be required for maintenance, improvement and enhancement of the Clickio Platform. The Operator may also deploy "web beacons" and similar technology to assist with delivery of the cookie to your computer or mobile device. Note that blocking or rejecting cookies on your computer or other device may prohibit you from accessing and/or using certain functionality or services available on the Clickio Platform. You hereby expressly consent to the Operator placing the cookies on your computer’s or other computing or mobile device’s hard drive for the purposes set forth in this Section, including but not limited to Clickio Platform maintenance and improvement, and accessing and using certain functionality and services of the Clickio Platform.

THIRD-PARTY WEBSITES AND COOKIES

The Clickio Platform may contain hyperlinks to other websites that are not maintained by, or related to, the Operator or its affiliates. It is your responsibility to review the privacy policies of those websites. This Privacy Policy applies only to this Clickio Platform.

Advertisers and other third parties may also use their own cookies. The Operator does not control the use of such third party cookies and expressly disclaims any and all responsibility for any information collected by third parties through use of such third party cookies.

TERM OF PROCESSING, UPDATING AND DELETING PERSONAL DATA

Your Personal Data is processed and stored by the Operator and/or its designated Personal Data processing contractor for the total period required for providing you access to the Clickio Platform and the ability to use the Clickio Platform, providing you with notifications and sending you promotional materials, and using your Personal Data for other purposes set forth in this Privacy Policy but for no longer than 3 (Three) years, if you do not request the Personal Data to be deleted earlier in accordance with this Section.

If you decide to terminate your personal profile within the Clickio Platform, the above 3-year term will apply to storage of your Personal Data and your Personal Data will remain in Operator’s archives for that period.

You have the right to request the Operator to update or delete your Personal Data by sending an e-mail to the following address: support@clickio.com. Your Personal Data will be updated or deleted, depending on your request, in 10 (Ten) business days as of receipt of your request. You may also send a request to fully delete your Personal Data in writing to the following address:

ALZ Software Limited

Hamilton House, Mabledon Place,

London, UK, WC1H 9BB

You have the right to opt out at any moment from collection of your Personal Data by turning off the ability to place cookie files on your computer by means of settings of your Internet browser. Please note that if you turn off the ability to place cookie files on your computer you may be able to access only limited functionality of the Clickio Platform. Turning on the ability to place cookie files on your computer shall constitute your consent to collection of your personal data under this Privacy Policy by Clickio Platform.

The Operator is under no obligation to store your Personal Data indefinitely and hereby disclaims any liability arising out of, or related to, destruction of such Personal Data.

GOVERNING LAW

Except where prohibited by applicable law or provided otherwise herein, this Privacy Policy shall be governed by the laws of England.

CHANGE OF OWNERSHIP

You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the Clickio Platform, of any information about you, including your Personal Data provided to the Operator in accordance with the Offer Agreement and this Privacy Policy, in case the Operator assigns its rights and obligations regarding such information in connection with a merger, acquisition, or sale of all or some of the Operator's assets, or in connection with a merger, acquisition or sale of all or some assets related to the Clickio Platform, to a subsequent owner or operator. In the event of such a merger, acquisition, or sale, your continued use of the Clickio Platform signifies your agreement to be legally bound by the privacy policy of the Clickio Platform's subsequent owner or operator. This provision shall remain in full force and effect notwithstanding any termination of your use of the Clickio Platform.

CHANGES TO PRIVACY POLICY

To the fullest extent permitted under applicable law, the Operator reserves the right to modify, update, supplement, revise or otherwise change this Privacy Policy in order to comply with applicable new legislation and/or regulations and/or to improve the Clickio Platform, and to impose new or additional rules, policies, terms or conditions in relation to the Clickio Platform, from time to time with or without notice to you. In addition, there may appear from time to time new, unanticipated uses of information collected through the Clickio Platform that were not previously governed by this Privacy Policy. The Operator may notify you of the amendments to this Privacy Policy by sending an email message to the email address listed in your personal profile and/or by posting the notice on the Clickio Platform. All amendments to this Privacy Policy will be effective immediately and incorporated into the Privacy Policy upon sending and/or posting of such notice. You are responsible for regularly reviewing this Privacy Policy. Your use of the Clickio Platform or any part thereof after any changes to this Privacy Policy are posted on the Clickio Platform or otherwise made available for review will be considered your acceptance of those changes and will constitute your agreement to be legally bound thereby. If you object to any such changes, your sole recourse will be to terminate your personal profile, request deletion of your Personal Data from our servers and stop using the Clickio Platform.

CONTACTS

If you have any comments or questions concerning this Privacy Policy, processing and use of your Personal Data, or if you would like the Operator to update or delete your Personal Data, please contact the Operator using the following contact details:

Operator address: ALZ Software Ltd., Hamilton House, Mabledon Place, London, UK WC1H 9BB

For questions regarding the Privacy Policy, data processing: support@clickio.com

To request update or deletion of your Personal Data: support@clickio.com