Last revised: May 25, 2018 INTRODUCTION International Internet Development Limited (the "Company"), offers a global network of content-rich web, mobile and social sites, including user acquisition and media buying (including paid search, display, mobile and social advertising), content optimization (including key word search, off-page and on-page optimization), and affiliate program, both in the web and mobile ecosystem (including through websites or mobile apps operated by Company; collectively, the “Services”). The Company is deeply committed to safeguard the privacy expectations of its end users (“User(s)”, “you” or “your”). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.   In this Privacy Policy, you can learn about:   We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By visiting or interacting with the Company’s websites, mobile apps or other online properties, or by visiting or interacting with third party websites, mobile apps or other online properties that deploy our Service, you hereby agree to the Privacy Policy.   If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send our Data Protection Officer at dpo@internationalinternetdevelopment.info . WHAT INFORMATION WE COLLECT? We collect two types of information from our Users: The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:   The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”). Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. Types of Non-Personal Information we collect from or about you:     MINORS The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at dpo@internationalinternetdevelopment.info.   HOW WE USE THE COLLECTED INFORMATION? We use your Personal Information for the purposes listed below:   MARKETING The Company will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Company; or (ii) the Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you. We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes. You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to dpo@internationalinternetdevelopment.info . Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.   WITH WHOM WE SHARE INFORMATION? We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy. We share Personal Information with any of the following recipients: In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:   TRANSFER OF INFORMATION Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union. We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).   THIRD PARTY TRACKING TECHNOLOGIES When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies"). The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners. We also allow third parties to collect information about you through Tracking Technologies. To learn more please visit our Cookie Policy.   THIRD PARTY SERVICES While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services. Please be advised that such third party websites, services or applications are independent from the Company. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties. You should always review their privacy practices carefully before providing Personal Information to such third parties. You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.   RETENTION OF PERSONAL INFORMATION If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations. In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.   YOUR RIGHTS If you reside in the EU or in other jurisdictions that afford you with the below rights, you may contact us at any time by email (at: dpo@internationalinternetdevelopment.info ), and request:
  1. To access or delete any Personal Information relating to you
  2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
  3. That we will restrict or cease any further use of your Personal Information;
  4. That we will provide the Personal Information you volunteered to us in a machine-readable format.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.   HOW WE KEEP YOUR INFORMATION SECURED We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store. We employ industry standard procedures and controls to ensure the safety of our users’ information, such as: Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.   CHANGES TO THE PRIVACY POLICY We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.   HOW TO CONTACT US If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at dpo@internationalinternetdevelopment.info    or by sending a letter to our EU representative: International Internet Development Limited Attn: Data Protection Officer 108 Premier Building, Seychelles We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.