Privacy Policy

• Service Provision. To provide our Customers with the Services of our Sites, or for other customer service purposes.
• Client Communication. To reach and communicate with our Customers regarding Customers' accounts via e-mail or other means of communication, to answer general Customer queries, requests, or complaints, and, lastly, to provide Customers with news, pieces of advice, or other information that is useful or of interest based on their communications preferences. This type of communication may entail the use of cookies in our e-mails so that we can track when the e-mails are opened and also evaluate the performance of our campaigns. For additional information on our cookies, please visit our Cookie Policy.
• Marketing and Advertising Purposes. To offer newsletters, exclusive deals, and promotions to our Customers either via e-mail or other methods, and to contact them regarding products or services that we think are in accordance with their interests; for general updates regarding Sevio's activity and services; also, for other marketing and advertising purposes. All of the Information sent to us will comply with the communications preferences of our Customers.

• Sevio's Affiliates. Current or future affiliates of Sevio, as well as parent companies, or subsidiaries, may receive some of our Customers' Information for the purposes expressed in this Privacy Policy (affiliates are companies that manage, are managed by, or are under our common management, such as Sevio FZC, referred to herein as "Affiliates").
• Sevio's Service Providers. Customer Information may also be disclosed to our third-party vendors, service providers, agents, contractors, or other services that perform various tasks on our platform in our interest. Some of these tasks may include maintenance, data analysis, surveys, e-mail marketing, data hosting, fraud detection, and payment processing.
• Customers. Customer Information may be disclosed to other Customers if this is relevant for the Service we provide. For instance, our publishers may receive Information regarding possible advertisers on their network, or we may offer our advertisers Information about which publishers' sites their ads have appeared on.

• data regarding the device and operating system of the User;
• IP address;
• the web pages visited within our Customers' websites;
• the link that brought the User to a Customer's website;
• the accessing dates and times on a Customer's website;
• event information (e.g., system crashes);
• geographic location of User's internet service provider (i.e. country, city);
• other diagnostic data.

• Service Provision. For the purpose of providing our services to our Users and Customers.
• Content Customization. For the purpose of customizing and personalizing the content and information that we may deliver or feature to Users; retargeting content to Users via our Services; personalizing our Services' user experience. For additional information regarding the personalization of our content, please access the Interest-Based Advertising section of this Privacy Policy.
• Content Personalization for Multiple Devices. For the purpose of offering an improved user experience for an all-encompassing variety of browsers and devices (e.g., smartphones, tablets, PCs) with better-targeted ad campaigns. We aim to provide the same quality and user experience and personalized content whether you are using a web browser or a mobile app. To achieve this, we may sync cookies and identifiers with our service providers or Customers that already have this implementation, so that our Users can benefit from improved data and data segments, and gain insight of other customers from the market.
• Providing Data Segments for Targeting Content and Advertisements for Services of Possible Interest. We may provide our Customers with several data segments (groups of Users with common attributes) either from us or from our data partners (accredited or authorized institutions are able to request such documents) to help them gain exposure to Users that have a higher chance of showing interest in their content and ads. When forming segments, we do not base our creation process on sensitive information (e.g., race, ethnicity, religious affiliations, or health status, genetic or biometric data, sex life or sexual preferences). Our Customers may use, via our Services, several standard health-related segments which focus on non-sensitive issues that mostly concern general health and well-being or over the counter treatments. We may also provide standard finance-related segments that are about Users who have an interest in financial services.

• Sevio's Affiliates. Any of the existing or future Affiliates, parent companies, or subsidiaries of Sevio may receive User Information for data processing according to this Privacy Policy's designated purposes.
• Sevio's Service Providers. Our vendors, service providers, agents, contractors, or other parties that provide our platform with services (e.g., maintenance, data analysis, surveys, payment and credit card processing, data hosting, etc.) may receive User Information on our part.
• Third Parties with No Affiliation. User Information may be disclosed to other third parties that hold no affiliation with Sevio, such as (i) our data partners (accredited or authorized institutions are able to request such documents), so that we can enable our advertisers to offer targeted content to specific audience segments, and (ii) our programmatic demand and supply partners (accredited or authorized institutions are able to request such documents) so that we can offer personalized advertisements.
• Customers. User Information may be disclosed to the Customers that have a Service we think might benefit from such information. For instance, publishers may receive from us data regarding the viewing and click-through patterns of their content, and advertisers may receive conversion rates data that they can use for analytics.

• The display of interest-based ads from Sevio can be disabled by clicking on the opt-out button below. It should be noted that you will still be able to see Sevio's content recommendations even if the opt-out function is enabled. Opting out prevents Sevio from using your Information to generate recommendations based on your particular interests. The recommendations you will receive from now on will be based on the specific website you are visiting (i.e., contextually based ads).
You can opt-out using our form at Sevio opt-out page.
• Not Opted Out: You will receive personalized recommendations from Sevio based on your browsing history.
• Opted Out: Your activity will no longer be tracked by Sevio, and, therefore, you will not be receiving personalized content recommendations derived from your past online activities:
As we individually track device or browser operations, you will need to opt-out on each device and browser, individually, in order to completely opt out across multiple devices.
• Your opt-out may not come into effect if your browser is set to reject cookies, as we have already recognized your opt-out configuration based on an opt-out cookie that we've sent to you. For the opt-out to be effective in this scenario, you will be required to confirm that your browser has the proper configuration. Users that have a Safari browser on iOS11 or macOS High Sierra first have to change their Privacy and Security Settings in order to disable "Prevent Cross-Site Tracking" and "Block All Cookies", and then access, once again, this privacy policy or their opt-out platform of choice to reset the opt-out settings.
• Technologies that do not use cookies may be used by Sevio in very few specific situations. These technologies work in a similar manner to cookies, as they help us to create tailored ad recommendations based on your interests and keep track if the opt-out function was enabled. Please keep in mind that you may not be able to restrict the use of non-cookie technologies with certain web browsers, but you can go to the "User Choices" section on this page and click on the Opt-Out feature to have this function enabled.
• Users can also disable getting targeted ads from Sevio and other advertising companies.
• The NAI opt out tool stops Sevio and other NAI-approved member companies from sending you targeted ads. The NAI offers a guideline on how to opt out from mobile devices that run on Android, iOS, and Windows Phone operating systems.
• The Digital Advertising Alliance affiliate websites also feature more information regarding User Choices and how to disable targeted advertising for each of the member companies.
• The DAA consumer choice page is available to United States-based Users at www.aboutads.info/choices
• The DAAC consumer choice page is available to Canadian Users at www.youradchoices.ca/choices
• The EDAA consumer choice page is available to European Users at www.youronlinechoices.eu
• You will still be able to see the advertisements from the companies featured in the DAA, DAAC, or EDAA consumer choice pages, even if you have activated the opt-out function. Opting out prevents these companies from using your Information to create ad recommendations based on your particular interests. The recommendations you will receive from now on will be based on the specific website you are visiting (i.e., contextually based ads).
• Your opt-out may not be effective if your browser has been set to reject opt-out cookies when visiting DAA, DAAC or EDAA consumer choice pages (these cookies notice companies if your opt-out preference is enabled).

• Data Collected Directly from You. Site Visitor Information may be collected by Sevio directly from you, in cases such as when you send us an e-mail with an inquiry or a form on our Sites that confirms you want to receive marketing materials or e-mail newsletters. The data inputted into these fields before submitting the forms may be recorded by third-party analytics. Other visitor Information that you have sent to us may be collected, including the contents of a message sent via our Sites.
• Data Collection from Third Parties. Site Visitor Information may also be collected by Sevio through third parties that automatically do so, on our behalf, when you access our Site. The collected Information may be about your operating system, IP address, system configuration, device information, mobile data information, your visited web pages within our Sites, the link that redirected you to our Sites, what site you visited when you left our Sites, the accessing dates and times, event information (e.g., system crashes) and weblog data.

• Service Provision. For the purpose of providing the Services of our Sites, as well as for management motives.
• Content Personalization. For the purpose of offering personalized content and data to you when you visit our Sites, and to give you a tailored browsing experience.
• Communication Purposes. In order to communicate with you and to respond to your questions or complaints regarding our Services through e-mail; or to offer you news, pieces of advice or other updates we deem are of interest to you.
• Marketing and Advertising. To send and contact you about services and materials that we believe might be of interest to you, such as newsletters, exclusive offers, and promotional services, as well as for other purposes that involve marketing and advertising. All of the information we will send will be compliant with the communications preferences set by you.
• Analytical Purposes. To have an ampler insight on how our Sites are accessed and used, at an aggregated and individualized level; to offer our response to any demands and preferences; and to analyze and research how our site is used.

• Sevio's Affiliates. Any of the existing or future Affiliates, parent companies, or sub-branches of Sevio may receive Site Visitor Information for the processing purposes detailed in this Privacy Policy.
• Sevio's Service Providers. Third-party service providers, such as vendors, agents, contractors, or other entities that perform services for our platform (e.g., maintenance, data analysis, surveys, payment and credit card processing, data hosting, etc.) may receive Site Visitor Information from us.

• The DAA consumer choice page is available to United States-based Users at www.aboutads.info/choices.
• The DAAC consumer choice page is available to Canadian Users at www.youradchoices.ca/choices.
• The EDAA consumer choice page is available to European Users at www.youronlinechoices.eu.

1. How Your Information Is Used In addition to the purposes aforementioned in Sections 1-3, we may use data collected from Customers, Users, and Site Visitors for several other purposes: Service Analysis. To improve our comprehension on how our Sites and Services are accessed and used, at an aggregated and individualized level; to offer our response to Customers', Users', and Site Visitors' demands and preferences; and to perform other analysis and research involving our Sites usage. Legal Compliance. To achieve full compliance with the laws set forth by legal authorities or other governmental regulatory bodies. Protection of Rights and Interests. With the purpose of protecting our rights and interests, and, by extension, the rights and interests of our Customers, Users, Site Visitors, and the general public, in addition to the enforcement of our Privacy Policy and our Terms of Service. 2. Information Disclosure Third parties that receive Information collected from us as mentioned above are required to agree and comply with this Privacy Policy and our contractual specifications in order to use the Information provided by us, and are not allowed to use said information in other contexts or for other purposes than those underlined in this Privacy Policy. Additional Information disclosures may be made for the following purposes: Business Acquisitions or Transfers. In case of our company acquisition or merger by/with another company, or if our business unit or assets are sold or transferred to another company, in the context of bankruptcy events, or other business transmissions, we reserve the right to disclose and/or transfer Information to the company in question. Compliance with Legal Matters. Information may be disclosed if it is required by law via legal procedures, such as subpoenas, court orders, or other law, regulation, or judicial proceedings. Protection of Rights and Interests. If we believe that an investigation, prevention, or action against illegal activities is required, we may disclose Information in order to combat cases such as suspected fraud attempts, potential threats to personal safety, breaches of our Terms of Service or this Privacy Policy, or to provide them as evidence in court cases in which we are involved. De-identified and Aggregated Data. Our Customers and other third parties may receive aggregated or de-identified user Information to be processed for purposes such as marketing, advertising, or research. 3. Tracking Technologies: Cookies and Others Links to third-party websites may be embedded in our Sites and Services. The use and access of these websites are not under compliance with this Privacy Policy but with the privacy policies set forth by the third-party websites. We absolve ourselves from any responsibility regarding the information security and privacy practices employed by these third-party websites. Our Sites, for instance, incorporate features from third-party social networking platforms, such as the "Like" button from Facebook. When using such features, they may collect certain Information, including, but not limited to, the IP address or the pages visited within our Sites and may also deploy a cookie to enable the feature to have proper functionality. Features and widgets from social media networks either have third-party hosting or direct hosting on our Sites. The interaction with these features falls under the privacy policy of the providing company of said features. Links to Customers' websites are not governed by this Privacy Policy but by the Customers' privacy policy. 4. Security The Information collected through our Sites or Services is secured through the application of proper technical and organizational procedures in order to prevent the data from being lost, altered, misused, accessed or disclosed by unauthorized entities, destroyed, removed, or any other type of unofficial activities. Please keep in mind that no security implementations can provide complete security. 5. Notice to European Economic Area ("EEA") Residents 6. Data Controller The personal Information of EEA residents which has been provided, collected by or for, or processed by Sevio in relation with our Services, will be controlled by Sevio Solutions SRL. 7. Legal Basis for Data Collection and Processing The legal basis for collecting and using the personal Information of European Economic Area Customers, Site Visitors, or Users (denoted in this Section 4.6 as "EEA Data") will vary according to the type of personal Information collected and the specific circumstance in which the collection took place. We will only collect Information from you for the following purposes: (i) when we have your consent; (ii) to establish a contractual agreement with you; (iii) when processing is in our legitimate interest and this does not come into conflict with your data rights, interests, and liberties. We may be legally required to collect personal Information from you in certain cases or may need the personal data to ensure the protection of your own or another individual's personal interests. In case of a legal requirement or establishing a contract with you, we will clearly state, at the right time, when and if it is compulsory for you to provide us with your personal Information (you will also be informed of the possible consequences of refusing to supply the required personal Information). The same applies should we require to collect and use your personal Information for our own legitimate interests (or any of our third parties), as we will explain to you, in due time, what these specific interests are. Should you have additional questions or require further information regarding the legal basis on which your personal Information is processed and used, and to have a better understanding of how our legitimate data processing interest affects your data protection rights and freedoms, please reach out to us by filling our contact form. 8. Personal Rights on Information Your rights include requesting Sevio to (i) give you access to your personal Information that might be held by us, (ii) make corrections or modifications to your personal Information (if there are any), (iii) erase your personal Information (if there are any), and (iv) prohibit any type of processing of your personal Information (if there are any). Another right you have is to file a complaint to a data protection authority regarding our collection, use and processing of your personal data. If you are interested in finding out more, please communicate with your local data protection authority by contacting them through the methods described here. Should you have queries regarding our collection and use of your personal Information, please contact us first at [email protected]. Users that want to find out more about the personal Information and behavioral Information Sevio may hold about them, and the enforcement of their personal Information rights, can request such Information by sending us an e-mail at [email protected], so we may provide them with the answers they are seeking or direct this request to/cooperate with their employer, if needed. 9. EEA Data Transfers Sevio data transfers outside of the EEA region. Customer, User, and Visitor Information is currently stored in Sevio's data centers located in the United States, Germany, India, Singapore, Japan 10. Global Data Transfers Your Information may be transferred by Sevio outside the country where the collecting took place, including to a country that may have less personal Information protection than the country of your residence. In order to prevent such discrepancies from affecting your personal Information, Sevio has set up all contracts to maintain the adequate level of protection for your Information processing when it is shared between or among Sevio's Affiliates, parent companies, and/or subsidiaries.

Should you have inquiries regarding the privacy aspects of our Sites or Services, please feel free to reach us at the following addresses: Sevio Solutions SRL Business Address UAE, Business Center, Al Shmookh Building, UAQ Free Trade zone, Umm Al Quwain E-mail: [email protected] European Economic Area residents are able to take their inquiry or complaint to a higher level if they are not satisfied with the support team by contacting our Data Protection Officer at [email protected]

This Privacy Policy is updated starting with the Effective Date stipulated above. This Privacy Policy may be subjected to occasional updates or changes, so please read this policy periodically to keep abreast with the new modifications. Any changes related to this Privacy Policy on our Sites will be immediately published by us. If any revisions to our Privacy Policy have a significant impact on our practices concerning the Information we may have about you, we will try our best to alert you of such updates in advance by emphasizing the changes on our Sites. We will request your permission in advance for any material changes, should this be compulsory via applicable data protection laws. By continuing to use the Sites and our Services, you express your agreement regarding this Cookie Policy and any updates. If you have questions regarding this privacy policy, you can contact us at any time using the following contact form. Last modification made on 15th of October 2019 at 14:00 GMT