I. GENERAL INFORMATION

I.1. As a platform for user acquisition solutions and traffic monetization, including through self-serve platforms (“Services”), СlickkyGroup Limited (“Clickky”, “we”, “us”) respects personal data privacy of the publishers, advertisers, and other users of the Clickky’s website at clickky.biz and our self-serving platforms (“Users”, “you” and “Website” respectively).

I.2. Clickky is committed to complying with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Directive 95/46/EC, and General Data Protection Regulation. For those reasons, Сlickky provides this Privacy Policy Statement (“Policy”), which explains how, when, and for what purposes Clickky collects and uses the information about the Users that Specifically identifies them and the information about their activities during the Services provision, when directly linked to personally identifiable information (“Personal Data”).

I.3. This Policy does not cover the collection and use of your Personal Data by our business partners(counterparties), and does not cover any information that may relate to Clickky outside of the Website and self-serving platforms.

I.4. This Policy shall be considered an integral part of the terms and conditions (agreement) between you and Clickky, together with the terms and conditions for the Self-serve platform for Advertisers and Self-Serve platform for Publishers

I.5. By using our Services, you consent to this Policy. We also inform the Users about the terms of the collection of the Personal Data on or before such collection. For the purposes of Personal Data(Privacy) Ordinance and the guidelines issued by the Office of the Privacy Commissioner for Personal Data (Hong-Kong), this Policy contains all the provisions required for the Personal Information Collection Statement (“PICS”). As well, for the purposes of General Data Protection Regulation, this Policy contains required provisions for collecting, storing, transferring, processing, etc. of Personal Data. Thus, the Users shall provide their active consent on the collection of the Personal Data on or before such collection under the terms hereof.

I.6. Clickky reserves the right to amend this Policy at any time and indicate the date of the last amendments on the top in the “Last amended” field. The User’s continued use of the Serviceы after any such amendments and notification thereof (which may be sent via e-mail to the address provided in the course of the User’s creating the account) shall constitute the User’s consent to and acceptance of such amendments.

I.7. Please pay attention that this Policy does not protect the information you post to any online profile, bulletin board, electronic communication, chat room, or any other publicly accessible forum independent of Clickky.

I.8. When access our site and/or using Services, you become subject to this Privacy Policy and voluntarily give us your consent for as well as grand us all rights for processing, collecting, transmitting (to the extent necessary for performing obligations and in accordance with data protection laws) and storing of your Personal Data for the purposes pointed herein as well as providing it to governmental and non-governmental authorities whenever they have the right to demand disclosure of such information (including Personal Data – if this is permitted and to the extent permitted by applicable data protection laws). You agree to all the conditions pointed herein and give us your free unambiguous consent to act with your Personal Data as pointed in this Privacy Policy.

I.9. Whenever we combine non-personally identifiable information with Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.

I.10. We can delete Personal Data as well as non-personally identifiable information any time we consider it appropriate, necessary for our business or protection of data privacy, stopping any data breach or any other reason which is reasonably deemed by us necessary, in compliance with the data protection laws and the purposes we collected it for. Sometimes we are obliged to keep some data as it is required by the data protection laws.

I.11. In cases, if we receive your Personal Data from the third party (controller of such data) in fulfillment of contractual obligations, we act as a processor. In order to secure such received Personal Data, we treat it with the same level of security as we treat Personal Data collected by us as pointed in this Privacy Policy (if applicable or if we are not obliged by the relevant contract to provide additional security measures). Notwithstanding anything to the contrary, you should acknowledge that we do not store such Personal Data for the period longer than it is necessary to for fulfillment of the relevant contract with the third party who provided us with your Personal Data.

II. COLLECTION OF THE PERSONAL DATA

II.1. We collect the Personal Data that you input into our Services and the data Automatically generated by your use of our Services.

II.2. You may input the Personal Data to make use of certain features of our Services. For example, when you create your account, you may be required to enter the Personal Data about yourself such as name, e-mail, Skype, telephone (identifying information). You may also be required to provide corporate information (company’s name, company’s email, website) and financial information (billing information, credit card number, expiration dates, address and security codes, which are transferred to a third-party provider of payment services and is not retained By Clickky). Here, you represent and warrant that you are of legal age, all the information provided by you is true, correct, up-to-date, you have necessary rights and/or is duly authorized to provide such information.

II.3. We also collect certain basic information to provide better services to the Users based on the inventory we have an access to, including:

II.3.1. Through our basic trafficking tracking system, which gathers IP addresses, UserAgent and whether or not the user has our domain cookies (https://www.cpactions.com);

II.3.2. Via our publishers which may provide us with user device information (hardware model, unique device identifier, OS version, device language) and device permissions. In such cases, Clickky does not collect information associated with the publishers’ user’s personal information, such as name, phone number, address, or any kind of the information that can identify such user as a person.

II.4. As to the cookies, the User shall understand the following:

II.4.1. Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization. It can include pieces of data embedded in an image on a website or email that allow for tracking of your activity on a website or your actions with regard to an e-mail, such as whether you opened the e-mail or accessed a link within the e-mail, etc.

II.4.2. The categories of cookies we use are: – Strictly necessary cookies – enable you to move around the Services; for example, help to remember you are logged into your account; – Performance cookies – collect anonymous information about how you use the Services to enable us to improve how they operate; – Functionality cookies – allow us to remember your username, language, and the region you are located or other information to provide you with an experience more appropriate with your selections;

II.4.3. You shall specifically agree to our use of cookies when you use our Website by clicking the respective button in the notification.

II.4.4. Generally, internet browsers contain controls for managing cookies. Those controls may enable you to delete cookies or to accept or reject certain categories of cookies. If you reject or delete cookies, the performance of the related features and functions of our Website or Services may be impaired to you.

III. PURPOSES OF THE COLLECTION

III.1. Clickky collects and uses your Personal Data for the following purposes: – proper provision of the Services to the Users; – creation and maintenance of your account; – processing of your inquiries and operations at the Services; – analyzing and understanding our audience for the purposes of improving our service; improving of delivery optimization, content selection, and other parts of the Services; direct marketing; – communicating with you concerning our Services; – assist third parties acting on our behalf; – ensure a smooth transition of the Services in the event of a merger, acquisition, reorganization,sale of all or substantially all of its assets, or sale of one of our User’s website; – investigate and/or enforce violations of our terms and conditions and/or this Policy, or to protect our interests in our operation and our legal rights and protections; – other purposes as may be required by applicable data protection law or Regulation.

III.2. We may directly communicate with the Users through e-mail, instant messages, and/or telephone provided to Clickky to ensure the proper Services provision and to promote our Services. Notices by Clickky may be given either by electronic messages to your registered e-mail address or by a general posting to your homepage.

III.3. We use the information indicated in paragraphs 2.3 and 2.4 hereof for certain purposes, including managing our business and improving our Services and ensuring the proper work of our Services. For instance, as to the platform for publishers, since our aim is to find relevant users for the products and services we promote and to improve the user experience of the advertising inventory for which we are distributing, we are trying not to disturb the user flow or user experience with the ad the user sees if said user has no desire to be engaged with the service That was offered. We use the user IP-range to define their location and country in order to distribute relative ads. We may also target users based on other criteria such as aforementioned criteria: user device, OS, language, UDID, and hardware model.

IV. TRANSFER AND DISCLOSURE OF THE PERSONAL DA

IV.1. We do not sell, share, or allow access to any of your Personal Data to the third parties, except as provided herein

IV.2. We may need to send the information to third parties (our employees or third Party companies), who work on our behalf, to provide a product or service to you within the Services provided under our terms and conditions. In cases where we need to disclose or share your Personal Data with such third parties, any such use of your Personal Data will be limited to the information required in that individual Case.

IV.3. We may hire other companies to perform certain business-related functions such as processing payments on our behalf. Our payment processing partner may request that you provide certain personal data (e.g., a valid government-issued ID, your legal name, address, and date of birth) for the purpose of making payment through its financial institutions and complying with any federal and state laws and regulations. They may also communicate directly with you regarding any issues with a payment. Any information provided to our third party will be confidential and only be used for intended purposes.

IV.4. Clickky (including our affiliates, advertisers, and content providers) Independently reserves the right to fully cooperate with requests from any recognized law enforcement or governmental authority, and to court orders, requesting or directing Clickky (including our affiliates, advertisers, and content providers) or from any third party entities investigating complaints related to bulk electronic communication complaints (SPAM, SPIM) requesting Clickky (including our affiliates, advertisers, and content providers) to disclose the identity or other information regarding any person who is or was using our Services. By accepting our Terms and Conditions and this Policy, you waive and hold Clickky (including our affiliates, advertisers, and content providers) harmless from any and all claims resulting from any and all actions taken by any of the foregoing during or as a result of any law enforcement or governmental authority investigations or inquiries.

IV.5. Before transferring any Personal Data to the third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make a reasonable check of such third party (including regarding its compliance with the data protection laws).

IV.6. We may disclose Personal Data if required to do so by data protection laws or to comply with a legal obligation, or if we believe in good faith that such action is necessary to: (i) protect our rights or property and our customers or (ii) protect the property or safety of users of our site or Services or any third party. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.

IV.7. We reserve the right to sell, assign or transfer our business or assets. In any such event or similar event, including but not limiting to a corporate sale, merger, reorganization, dissolution, etc., Personal Data may be part of the transferred assets. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Data as set forth in this Privacy Policy.

V. ACCESS TO THE PERSONAL DATA

V.1. You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address provided in this Privacy Policy: see what Personal Data we have about you, if any; change/correct any Personal Data we have about you; have us delete (right to be forgotten) or transfer (export) Personal Data we have about you; to know where your Personal Data is stored and processed (if processed by third party/parties – right to know name and location of the processor/processors); express any concern you have about our use of your Personal Data (including objecting against the processor); withdraw your consent for our collection, processing and use of your Personal Data; other rights granted to you by relevant data protection laws.

V.2. In order to exercise your rights, you should send a relevant request via email pointed in this Privacy Policy. We will respond (fulfill your request, explain why we can’t do it or other response if applicable) without undue delay, but in any case within 60 days from the day of receipt of your request. We will solely choose how to provide you information: written, or by providing access on our server (other types of storage), or sending it to you by email or on CD/DVD/ other devices, or in another applicable way, etc. Your request should not cause any additional unreasonable efforts for us in order to fulfill it. We may decline your request or ask you to pay relevant fees for its fulfillment if your actions have signs of abuse of rights. We will reply without undue delay, but in any case within 60 days from the day of receipt of your request.

V.3. The Users may modify or remove any of their Personal Data associated with their account at any time by logging into their accounts and accessing the respective Personal Data features, or by contacting a representative of Clickky, as set out in Section VII hereof, to keep the respective Personal Data accurate and up- to- date.

V.4. Clickky will maintain User’s records (identifiable information and any transactional or payment information) in accordance with applicable laws and regulations. We store your Personal Data for 3 months and make a revision of it after that period. During such revision, we may either delete all of your Personal Data or keep it collected for the next 3 months if: we are providing you Services; we are in the middle of dispute or you are our debtor; such information is still necessary for the purposes we collected it. We can delete your Personal Data any time and not wait for 3 months period to end if purpose we collected it for no longer apply. We make no warranties your Personal Data will be available for any specific period of time (3 months, or less or more etc.). Please consider, that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.

V.5. In cases, if you found out that someone illegally provided us with your Personal Data, let us immediately know about this via our contact email pointed in this Privacy Policy. Upon your request, we will delete your Personal Data without undue delay, but in any case within 60 days from the day of receipt of your request. We will only retain such copies of the information as are necessary for us to comply with data protection laws for such cases.

VI. SECURITY

VI.1. We believe we use reasonable administrative, logical, physical, and managerial measures to safeguard your Personal Data against loss, theft, and unauthorized access, use, and modification. Some data protection laws require providing anonymization (or pseudonymization, or encryption) of the Personal Data. We will make all commercially reasonable efforts to comply with such requirements.

VI.2. Your accounts are secured by your personal username and password. We use reasonable measures to protect information that is stored within our database, and we restrict access to such information to those employees who need access to perform their job functions (i.e., account representatives, financial services staff, and senior management). Our employees sign relevant NDA, which will stay in force for the period of time after termination of relations between us and them. As well our security measures are designed to ensure the possibility of identification of all the employees who had access / accessed Personal Data of our users.

VI.3. However, we cannot assure you that Personal Data will never be used or disclosed in a manner that is inconsistent with this Policy. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such Personal Data at any time. You should understand that no feasible system of data security is invulnerable. Accordingly, we cannot guarantee the 100% security of your information.

VI.4. Your obligations regarding the security of your data are the following: not to disclose your password and log in as well as other information which enables unauthorized access to the site of Services on your behalf; provide reasonable care regarding your actions on Internet and your use of site and Services.

VI.5. In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in any of the following ways: via your contact email, by phone, in your personal account, on our site or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if you are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.

VII. GEOGRAPHY

VII.1. We store your Personal Data in the European Union (“EU“). Any Personal Data gathered by Clickky in connection with our Services may be transferred to, processed, and stored in countries where data protection laws may be less protective than the legislation where you live. This may happen when facilities belonging to Clickky are located in a country outside of the European Economic Area or in a country which is not the party to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981).

VII.2. Supplying Clickky with the Personal Data, you permit its transfer outside the Country within the bounds of such use. When a transfer to non-European countries happens, we ensure that it takes place in accordance with this Policy and applicable laws. Herein you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, the center of vital interests, economic region, etc.).

VIII. ChildrenVIII.1. We understand the importance of taking extra precautions to protect the privacy and safety of children accessing Site and/or Services. Children under the age of 18, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the site and/or Services unless their parent provided verifiable consent or as part of the child account creation process (if this type of account is applicable). If we learn that we have collected the Personal Data of a child under 18, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with the data protection laws. If at any time a parent needs to access, correct, or delete such Personal Data he may contact us through email pointed in this Privacy Policy.

IX. Other Provisions as Required by Law

IX.1. Do Not Track Signals We do not track you by ourselves over time and across third-party websites to provide targeted advertising and therefore respond to Do Not Track (DNT) signals in a way that we use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords. As well, be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

X. INQUIRIES

X.1. Any enquiries regarding the Personal Data provided, including the requests for access to,correction, or removal of your Personal Data as well as executing any other rights provided by this Policy or applicable data protection laws, to express complaints about our Policy or any other matter regarding your Personal Data, or regarding person responsible for compliance with data protection laws, should be addressed to e-mail at privacy@clickky.me.

To learn more on how Clickky collects and processes their data, please read our Privacy Policy Addendum.