PRIVACY POLICY

Last Updated: March 2019

PLEASE READ THIS PRIVACY POLICY (THIS “PRIVACY POLICY”) CAREFULLY AND IN ITS ENTIRETY BEFORE USING OUR SERVICES.

This Privacy Policy has been established by Global Content Ltd (the “Company” “we” or “us”), to explain how we may collect, retain, process, share and transfer information collected from you when you use our Services, and to allow you to make an informed decision about how you will use our Services. Capitalized terms not defined herein have the meanings ascribed to them in our Terms of Services.

By accessing our Services, you are agreeing to this Privacy Policy. We encourage you to periodically review this Privacy Policy for updates and to ensure that you are familiar with its terms. If you do not agree to this Privacy Policy, please discontinue accessing or using the Services. This Privacy Policy is not applicable to third-party Content, properties, or websites, applications and services that contain other privacy policies.

Section 1. Summary Information

This Privacy Policy explains and describes how we collect, retain, process, share and transfer information collected from you when you use our Services. We recommend you review the entirety of our Privacy Policy to get a complete understanding, but the core features of our privacy practices are as follows:

Section 2. What Information Do We Collect?

We may collect information from you in two ways: information we gather from your use of our Service and information you give to us, as further outlined below. This information may include “Personal Information” and “Non-Personal Information.” For purposes of this Privacy Policy, “Personal Information” means information that you provide to us that personally identifies you, such as your first and last name, email address, physical address, telephone number and billing information. For purposes of this Privacy Policy, “Non-Personal Information” means information that does not specifically identify you.

The information we collection about you may include the following:

Section 3. How Do We Use This Information?

We are able to deliver, personalize, and improve our Services by combining and using the information that we have about you to understand how you use and interact with our Services. We also may use the information that we have about you for the following purposes:

In connection with the foregoing, we may combine your Personal Information that we have with other information that we obtain from service providers or other companies. We may also combine your Personal Information with Non-Personal Information. When Personal Information and Non-Personal Information is combined, it will be treated as Personal Information for the duration of such combination.

Section 4. How Do We Share This Information?

We will not share the Personal Information we collect about you with any third party for their own marketing purposes without your consent. Except as set forth below, we do not sell, license or share information that individually identifies our users with companies, organizations or individuals outside of the Company and its affiliated entities. We will share your information in the following ways:

Any transfer of your information will comply with applicable law in all cases. We disclaim and shall have no liability or obligation in connection with any third party actions or omissions concerning your information, even if those acts or omissions are a result of our sharing and disclosure your information, as allowed pursuant to this Privacy Policy. If you have any issues concerning a third party’s use of your information, please contact such third party. For more information on third-party use of your information, please see Third-Party Practices herein. Any Non-Personal Information we collect may be shared by us publicly and with others.

Section 5. How Do We Use Cookies and Tracking Technology?

A “cookie” is a small file containing your preferences that is sent to your browser and sent back by your browser each time your browser accesses our servers. When you visit our Services, we may send your computer or mobile device a cookie that uniquely identifies your browser. Cookies that we may use may only be read by the server that placed them there. Our use of cookies is primarily focused on improving the quality of our Services and your use of those Services. By way of example, we use cookies to deliver our Services in your language of choice, to filter results and fulfill other preferences you may have, and to analyze how our users, including you, interact with our Services, such as by tracking user trends and patterns of how people search. Many browsers are set up to accept cookies unless the user changes the settings for cookies. You have control over this and can set your preferences to indicate when a cookie is being sent or to refuse altogether. While you maintain control over your cookie setting, some portions of our Services may not function correctly without cookies. You can review more information about cookies and how to control and delete cookies in various browsers, such as Internet Explorer, Firefox, Safari, Opera and Chrome.

We may currently or in the future use web analytics companies to assist us in measuring the effectiveness of our Services. This requires that we allow such web analytics companies to include their own Web beacons and cookies on the Services. These web analytics companies collect information from Web beacons and cookies such as click-throughs by users and other similar information. We use this information to help us learn things like overall user preferences, click-through rates, means to improve our Services, and what the types of offers that are of most interest to our users. We control how that data may be used, notwithstanding its collection by third party web analytics companies.

To "opt-out" of receiving cookies from certain of our ad serving partners. We use the term "cookies" in this Privacy Policy to refer to cookies and all such similar technologies that collect information automatically when you are using our Services.

Section 6. How Long Do We Keep the Information?

We retain the information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

Section 7. How Do We Protect Your Personal data?

We take the protection of your Personal Information very seriously. Only our employees, contractors, affiliates, service providers, and agents will have access to your Personal Information, except as otherwise provided for in this Privacy Policy. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password, if any, used in connection with your use of our Services. While we take precautions against possible breaches in our Services and databases, we cannot guarantee that it is completely secure. We are not able to assure you that unauthorized hacking, access, data loss, or other breaches will never occur. As such, your use of our Services is at your own risk. You are encouraged to protect your Personal Information when you are on the Internet, including making sure you use a secure Internet browser.

Section 8. Third-Party Practices

Applicable law obligates our service providers to protect the privacy of certain types of data. We are not responsible for their actions or omissions in any way, including with respect to any information they receive directly or indirectly from us. If you believe that any party who claims association with us, including our service providers, is improperly collecting or using information about you, you should contact them directly. though we maintain no responsibility to reply to such correspondence or to take any action in connection with such correspondence.

In order to provide or enable certain portions of our Services, our service providers may request or require you to provide information, including Personal Information, to them or to download certain software. We have no responsibility for the privacy practices of our service providers or the contents of any software downloaded from them. Our Services may also link to third party websites and offerings over which we exercise no control. Under no circumstances shall we be responsible for the privacy practices or the content of such third-party websites and offering, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.

Section 9. Age Limitations.

Our Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Information, from children or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

COPPA

We comply with the Children's Online Privacy Protection Act (COPPA).

Section 10. Jurisdiction and International Data Transfers

We do not represent or warrant that our Services are appropriate or available for use in any particular jurisdiction. Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit access to our Services, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

The Company may transfer your Personal Information to countries other than the one in which you live. In particular, your Personal Information will be transferred to and processed in the United States where many of our central databases operate. By using our Services, you are consenting to such cross-border data transfers of your Personal Data, as set forth in this Privacy Policy. By using the Services, you acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your Personal Information being collected, processed and transferred as set forth in this Privacy Policy and US law. The Company has entered into European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our users that operate in the European Union.

Section 11. Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their Personal Information. Subject to any exemptions provided by law, you may have the right to request access to your Personal Information that we retain, as well as to seek to update, delete or correct this Personal Information. If you wish to exercise any of these rights, please contact gdprcontact@polarity.com.cy. While we may be able to provide you access to your Personal Information in some cases, there is no guarantee we will be able to provide access in all circumstances. In circumstances where we are unable to verify your identity or are required to retain such information in accordance with applicable laws, we may not be able to modify or remove your Personal Information. We will remove your Personal Information in accordance with applicable law.

To the extent that our processing of your Personal Information is subject to the General Data Protection Regulation, the Company relies on your consent. If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time by contacting us at gdprcontact@polarity.com.cy.

Section 12. Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict the Company’s use of your Personal Information and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Information within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to us at gdprcontact@polarity.com.cy.

Section 13. California Privacy Rights Under California Civil Code Section 1798.83

California Civil Code Section 1798.83, known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. For all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.

Section 14. More Information.

For more information about protecting your privacy. In addition, the Federal Trade Commission Consumer Response Center offers a helpline at 1-877-FTC-HELP (1-877-382-4357) to allow consumers to make comments or inquiries regarding companies and business practices. If you have questions about this Privacy Policy, or if you would like access to Personal Information we may have about you in our files, to correct, update or to have us delete it.

Section 15. Changes to this Privacy Policy

We reserve the right to revise, from time to time, this Privacy Policy. Any changes to this Privacy Policy will be posted on our Services and, to the extent the changes are significant. Your continued use of our Services after such change has been made will signify your acceptance of such change.