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REMIXD MEDIA, INC.

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Privacy Policy

Last Updated: October 1, 2020

The Remixd platform (“Platform“) is a property of Remixd Media, Inc. (“Company,” “we,” “our” or “us“), a U.S. corporation located at 1629 K St NW, Suite 300 Washington, DC 20006. This Privacy Policy (“Privacy Policy“) governs our treatment of personal information and other information that we collect when an end-user (“User”) accesses any of the text and/or other information made available by a publisher or advertiser on or through the Platform (the “Content“).

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by calling us at: 202-508-1493; emailing us at: support@remixd.com or sending us mail to: 1629 K St NW, Suite 300 Washington, DC 20006

IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT BE ELIGIBLE TO ACCESS OR OTHERWISE USE THE PLATFORM OFFERINGS.

Personal Information Collected

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual, whether alone or in combination with other, non-individually identifiable information. Except as set forth in this Privacy Policy, Company does not collect personal information.

Company automatically collects the following information about your interactions with the Platform (collectively, “User Data”):

  • Your Internet Protocol address
  • The type of device you use to access the Platform
  • The number of advertising impressions during your interaction with the Platform
  • Your engagement with the Content and advertising during your interaction with the Platform, including
    • Content Plays
    • Content Pauses
    • Content Completions
    • Ad Plays
    • Ad Completions
  • To validate whether advertising has been delivered during your interaction with the Platform, we also collect the following information about such advertising
    • Remote Internet Protocol address
    • Request URL
    • Page URL
    • Domain
    • User Agent
    • Timestamp
    • Session ID
    • Publisher ID
    • Volume
    • Speed
    • Ad duration

Use and Sharing of Personal Information

By accessing the Content though the Platform, you agree that we may share or otherwise provide the User Data to any third-party for any purpose permitted by law.

Without limiting the above, you agree that Company may share aggregate or group data about Users of the Platform with third parties, including advertisers and their agents, for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Platform Users as a group, without disclosing personally identifiable information.

We may provide the User Data to third-party companies and individuals to perform certain functions on our behalf (“Third-Party Service Providers”). Examples include data storage and processing, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to User Data as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.

We will also use your personal information with your permission, for customer service, to customize your experience with the Platform and/or to contact you when necessary in connection with your use of the Platform. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Platform. We may also combine the information we have gathered about you with information from other sources.

We reserve the right to release current or past personal information: (A) in the event that we believe that the Platform is being or has been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Platform of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.

Cookies

When a User accesses the Platform, we may send one (1) or more cookies and/or gif files (collectively, “Cookies“) to assign an anonymous, unique identifier to the applicable User’s computer or other device. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information. Cookies have many benefits to enhance your experience at the Platform. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Platform, including for storing User preferences and tracking Platform-User trends (such as pages opened and length of stay at the Platform).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Platform; provided, however, that certain functions of the Platform may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking/Advertising

Company may use Cookies, pixels, beacons, and other tracking technology (collectively, “Tracking Technology”) in connection with the Platform for purposes of tracking Users’ activities (such as advertisements selected and pages viewed) after they leave the Platform. Company, and its third-party partners, may use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users. In addition, Company may use one or more Third-Party Service Providers in order to better understand Users’ needs and to optimize the Company’s offerings. Each such Third-Party Service Provider is a technology service that helps us better understand our Users’ Platform-related experience (e.g. how much time they spend on which Content) and this enables us to build and maintain our Platform offerings with User feedback. Each such Third-Party Service Provider may use cookies and other technology to collect data on our Users’ behavior and their devices (in particular, the various devices’ IP addresses (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only) and preferred language used to display our Platform). Neither the Third-Party Service Provider nor Company will ever use this information to identify individual Users or to match this information with additional data on an individual User.

In general, Users may be able to disable some, or all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking by utilizing the options made available by:

Further, Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http ://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties, including Google®, in connection with the Platform.

Data Security

We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. Access to all of our Users’ personal information is restricted on our premises, as well as the premises of our Third-Party Service Providers, such as our data hosting services. Only employees or third-party agents who need User personal information to perform a specific job are granted access to any User personal information. Our employees are subject to policies designed to ensure the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; note, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data to or through the Platform, is done at your own risk.

In compliance with applicable laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach of our premises or Platform servers with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. For personal data stored by our Third-Party Service Providers, such Third-Party Service Providers shall be responsible for notifying you of any information security breach of their premises or servers, in accordance with applicable law.

Minors

Company does not knowingly solicit or collect information from Users under eighteen (18) years of age.

Opt-Out/Unsubscribe

To opt-out of receiving e-mail and other forms of communications from us, you can:
  • Follow the instructions included in the applicable e-mail message or other communication you received from us
  • E-mail us at: privacy@remixd.com

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: privacy@remixd.com. Before processing such requests, and, to the extent permitted by applicable law, we will require individual Users to identify themselves and the information requested to be accessed, corrected or removed we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing only on backup storage media).

Please be advised that deleting your personal information may terminate your access to certain functionality of the Platform.

Please be further advised that, after you delete your personal information, residual copies may remain in our backup systems and it may take a period of time before they are deleted from our active servers.

Transfer of Personal Information Internationally

If you are accessing the Platform from a country other than the country in which our Platform servers are located, your use of the Platform may result in the transfer of information across international borders. By accessing the Platform and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our Platform servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Platform that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, you may:

  • email us as at: privacy@remixd.com
  • call us at: 202-508-1493
  • send us mail to:
    1629 K St NW,
    Suite 300 Washington,
    DC 20006


Additional Provisions for California Residents

These Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California (“CA Users”), and are intended to ensure that any personal information we collect is protected in accordance with the California Consumer Privacy Act (“CCPA”).

Categories of Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category

 

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

NO

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a User’s interaction with a website, application or advertisement.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated User information.
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We may obtain such personal information from one or more of the following categories of sources (with the specific categories of personal information indicated in parenthesis):

  • Directly from our CA Users. For example, from any communication you have with us related to the products and/or services that we offer by and through the Platform. (Category A, B, C and I)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, F and I)
  • Directly and indirectly from activity on the Platform. This may include, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Platform usage details and analytics as such are collected automatically by us and our third-party partners as described in this Privacy Policy. (Category F)
  • From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, Third-Party Service Providers that assist us in analyzing data and providing marketing analysis. (Category A, B, C and I)
  • From third-party data brokers or aggregators. (Category A, B, C and I)
  • From publicly available sources, such as Internet search engines. (Category A, B, C and I)

Use of Personal Information

We may use or disclose the personal information that we collect to fulfill or meet the reason for which the information is provided, such as:

  • To provide you with information, products or services that you request from us. (Category A, B, C, F and I)
  • To deliver advertising and other relevant Platform Content to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, F and I)
  • To provide you with email, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, F and I)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (Category A, B, C, F and I)
  • To improve the Platform and better present its contents to you. (Category A, B, C, F and I)
  • For customer service purposes and to respond to inquiries from you. (Category A, B, C and I)
  • For testing, research, analysis and product development. (Category A, B, C, F and I)
  • As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, F and I)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, F and I)
  • As described to you when collecting your personal information or as otherwise set forth under applicable law. (Category A, B, C, F and I)
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Category A, B, C, F and I)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing, we may share your personal information with/to third parties for marketing purposes, as well as other business purposes. When we disclose personal information to a third party, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Users that we actually know are less than eighteen (18) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

No information disclosed in the preceding 12 months

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:

No information has been sold in the preceding 12 months

We may disclose your personal information for a business purpose to the following categories of third parties (Category A, B, C, F and I)

  • Service providers. (Category A, B, C, F and I)
  • Third parties who purchase and/or license your personal information for purposes relating to advertising. (Category A, B, C, F and I)
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Category A, B, C, F and I)

In the preceding twelve (12) months, we have not: (a) sold personal information (including (i) e-mail address; (ii) full name; or (iii) telephone number; to the third parties who purchase and/or license your personal information for marketing purposes; or (b) shared your personal information for the business purposes set forth above.

In the preceding twelve (12) months, we have:

  • Received 0 requests for access to specific information and to exercise data portability rights. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0;
  • Received 0 requests to delete personal information. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0; and
  • Received 0 requests to opt-out from the sale of personal information. We have complied with 0 of those requests (in whole or in part) and denied 0 requests. The median number of days within which we substantively responded to such requests was 0.

Your Rights and Choices

The CCPA provides CA Users with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

  • Calling us at: 202-508-1493
  • Emailing us at: privacy@remixd.com
  • Sending us mail to: 1629 K St NW, Suite 300 Washington, DC 20006

Where you make a request to opt-out of the sale of your personal information through an Authorized Agent, we will require that you or the Authorized Agent provide us with a valid written authorization executed by you and that Authorized Agent, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by:

  • Emailing us at: privacy@remixd.com
  • Sending us mail to: 1629 K St NW, Suite 300 Washington, DC 20006

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we have shared that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased; and
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise their free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

  • Calling us at: 202-508-1493
  • Emailing us at: privacy@remixd.com
  • Sending us mail to: 11629 K St NW, Suite 300 Washington, DC 20006

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. Where you make a data deletion request, data portability request and/or information access request through an authorized agent, we will require that you or the authorized agent provide us with a valid written authorization executed by both parties, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by:

  • Emailing us at: privacy@remixd.com
  • Sending us mail to: 1629 K St NW, Suite 300 Washington, DC 20006

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to these Provisions

We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Platform.

Contact Information

If you have any questions or comments about these Provisions, the Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

  • Calling us at: 202-508-1493
  • Emailing us at: privacy@remixd.com
  • Sending us mail to: 1629 K St NW, Suite 300 Washington, DC 20006

Additional Provisions for European Residents

These Additional Provisions for European Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the European Union or the European Economic Area (“EU Users”).

Company is considered the “data controller” for its Platform as defined within Regulation (EU) 2016/679 (General Data Protection Regulation)(“GDPR”). You, the User, are the “data subject.” The following agreement applies solely to personal data held by Company within the Platform, or in Company’s internal records relating to the Platform.

1. Lawful Basis for Processing

Your data can only be processed if there is at least one lawful basis to do so. The lawful bases for processing data are:

  • The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

2. Consent

We obtain the following personal information with your consent on our Platform:

  • Users consent to the collection, storage and use of their information as set forth in our Privacy Policy.
  • Users entering information into any customer communication form, such as a helpdesk or customer support service, consent to have their name, email address, country and other voluntarily-provided data stored by Company for a period of up to two years unless consent is withdrawn. This is for the purpose of providing useful information in response to their enquiry
  • Users accessing products or services from Company consent to have their IP address stored by Company for the purposes of providing their product or service.

3. Responsibility and accountability

It is the responsibility and liability of Company, as the data controller, to implement effective measures and to comply with applicable law in its data processing activities, and Company hereby acknowledges such responsibility.

4. Right of access

As described above, depending on how you interact with our Platform, and what consent you have given, we may have some or all of the following personal data stored about you:

  • IP Address
  • First, Last Name, Middle Initial
  • Email Address
  • Country
  • Mailing Address
  • Phone Number
  • Any other information identified in our Privacy Policy

Upon a reasonable advance written request to us, and upon verification of the request being genuine, you have the right to access and correct such personal information in our possession.

5. Right to erasure

If you as a User of our Platform request in writing that we delete your personal data, upon verification of the request being genuine, we shall delete or render illegible all your requested personal data within a reasonable time (not to exceed five (5) business days). Should this request result in the inability for us to provide a service or functionality to you, we will inform you of the potential impact prior to performing the erasure.

In addition, visitors to the Platform who are not contracted customers will have their personal data erased automatically after two (2) years if they do not continue to interact with the Platform or with emails sent by us.

6. Data portability

If you as a User of Our Platform request in writing that we provide you a copy of your personal data, upon verification of the request being genuine, we will provide your personal information in an industry standard format that will allow you to use it somewhere else.

7. Data protection

We have implemented appropriate security measures to prevent, address and rectify unauthorized access to personal information. These measures include, without limitation, hardware and software firewalls; the physical security of our server locations; encryption of all personal data transmitted into and out of our servers; and policies and training of all personnel having access to personal information.

8. Records of processing activities

Company maintains records of its data processing, which include the purposes of the processing, the categories of data involved and the duration of the data retention period. These records are available to the applicable supervisory authority on written request to ss.

9. Data breaches

We will report to the relevant supervisory authority within 72 hours, as well as to affected Users, if we determine that there has been a data breach of our Platform servers.

10. Data Protection Officer

We do not, as our core activity, handle the data processing of operations that require regular and systematic monitoring of data subjects, therefore we do not have a formal Data Protection Officer for our Platform.

11. GDPR Representative

Because Company is not established in the EU, it designates the individual below as its representative in the EU with regard to its obligations under the GDPR. Supervisory authorities and data subjects should direct all communications regarding Company’s GDPR compliance to the following:

Gordan Topalovic
929-228-5334
gordan@remixd.com