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:

§ WHAT INFORMATION WE COLLECT?

§ MINORS

§ HOW WE USE THE COLLECTED INFORMATION?

§ MARKETING

§ WITH WHOM WE SHARE INFORMATION?

§ INTERNATIONAL TRANSFER OF INFORMATION

§ THIRD PARTY TRACKING TECHNOLOGIES

§ THIRD PARTY SERVICES

§ RETENTION OF PERSONAL INFORMATION

§ YOUR RIGHTS

§ HOW WE KEEP YOUR INFORMATION SECURED

§ CHANGES TO THE PRIVACY POLICY

§ HOW TO CONTACT US

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:

§ Personal Information 

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:

§ Contact details: you may voluntarily provide us with certain contact details, such as your full name and email address.

§ Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.

§ Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.

§ Social networks: when you voluntarily decide to register through your social network account (such as your Facebook account), we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account.

§ In addition, when using the Services, you may be able via your social network to "Invite a Friend" to use the Services. Should the person accept your invitation, we may obtain Personal Information from him/her such as: name, email address, phone number and date of birth. We will use the Personal Information for the purposes set out herein and disclose such information only to third parties as detailed in this Privacy Policy.

§ Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

§ Non-Personal information

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:

§ Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.). This information also includes anonymous online identifiers, such as the Google Advertising ID and the IDFA.

§ Device and app information – this category includes your device's type and model, system language, the device's operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari), app history and usage information (such as information about running and installed apps on the device), information regarding downloads and installations of mobile applications and any information regarding in-app events (such as in-app purchases), and anonymous identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Google Advertising ID, or other types of device identifiers.

§ Location information – we collect information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.

§ Ad information – this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the advertiser’s website, downloaded an app or purchased the product or service advertised.

§ Log and analytics information: we collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. referral URL, pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.

§ Other anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

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:

§ To provide and operate the Services, such as to provide our clients with performance marketing, online user acquisition network, online promotions, and for the purposes of user attribution;

§ To communicate with you and to keep you informed of our latest updates to our Services and special offers;

§ To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;

§ To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);

§ To support and troubleshoot the Services and to respond to your queries;

§ To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;

§ To identify and authenticate your access to certain features of the Services;

§ To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;

§ To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;

§ To investigate and resolve disputes in connection with your use of the Services; and

§ As required by law or regulation, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.

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:

§ Our clients that deploy our Services on their online properties (such as websites and mobile apps); this includes our clients whose websites or apps you have visited, as well as an advertiser whose site or app you have visited – we share information about how you have interacted with such websites or apps.

§ Companies within the Company and other affiliated companies;

§ Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;

§ Auditors, contractors or advisers of any of the Company’s business processes;

§ To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);

§ Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and

§ Potential purchasers or investors in any of the companies within the Company, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Company (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:

· Storing such information on our behalf, for example by using cloud computing service providers;

· Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);

· Performing research, technical diagnostics or analytics (such as for geo-location);

· Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under "Marketing"); and

· Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our User Agreement and Privacy Policy), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

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:

· Secure network topology, which includes intrusion prevention and Firewall systems;

· Encrypted communication;

· Authentication and Access Control;

· External and Internal audit tests; etc.

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.