PRIVACY POLICY

Effective: November 1, 2020

PRIVACY POLICY
1. PURPOSE OF POLICY.

PM App, Inc., and its affiliated entities ("us," "we," or "Company"), is committed to respecting your privacy rights. We have created this Privacy Policy (this "Privacy Policy") to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is applicable to the data we collect when you engage with us including via mobile or desktop software, applications, websites, messages, plug-ins, platforms, social media, databases, and/or any other services and products that you may request or that we may provide you (collectively, our "Services").

We ask that you read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

2. NOTICE CONCERNING CHILDREN AND MINORS.

We do not direct any of our content specifically at children under the age of 13 years, nor do we collect any personal information from anyone who we know to be under the age of 13 years. If we learn or have reason to suspect that a particular user is under the age of 13 years, we will use our best efforts to prevent access to the Services of such user and to delete any personal information in such user's account(s) involving our Services.

California Civil Code Section 22581 permits minors under the age of 18 years, or their parents or guardians, to request and obtain removal of their information. To request removal of your personal information please contact us using the methods described in this Policy. Note that removal under the law does not ensure complete or comprehensive removal of your information.

3. INFORMATION WE COLLECT AND USE.

In offering our Services, we may collect or obtain certain information such as your name, mailing address(es), e-mail address(es), phone number(s), gender, age, date of birth, social security number, occupation, education level, income, race, religion, political party affiliation, and other bibliographic information, payment and applicable financial account information, and information pertaining to your creditworthiness, assets, income, or liabilities, information about your use of our Services which you have purchased, obtained, or have researched or to which, by use of our Services, have otherwise indicated interest, your IP address, geolocation data, domain servers, types of computers accessing our Services, types of browsers, and other data of a technical nature which relates to your use and access of our Services (collectively referred to as "Information").

As used in this Policy, and any of its supplemental policies, "Personal Information" is any Information that identifies (or can be used to identify) you or which permits the physical or online contacting of you, such as your name, address, email address, and phone number. "Anonymous Information" is any information that does not identify, and cannot reasonably be used to identify, you. "Pseudonymous Information" is any information that cannot be attributed to you without the use of additional information. "Aggregate Information" is any information about groups of visitors to our Services that does not identify, and cannot reasonably be used to identify, you.

3.1 HOW WE COLLECT INFORMATION.

Information you Provide Us: We may include registration, surveys, questionnaires, and other forms that ask you to provide information, including Personal Information. Some of the information that we collect is required from you to enable us to provide you with Services. For example, you may request that we add you to our newsletter, may request that we contact you, or you may order product or services from us, and as part of that request we may require you to provide your name, address, or email address. We will inform you at the point of collecting information from you whether you are required to provide information to us. If you choose not to provide us with the required information, you may be unable to utilize our Services or aspects thereof.

Server Information: Our servers may automatically collect Information of a technical nature, such as your IP address and your browser type, which relates to your use and access of our Services. This data does not in and of itself personally identify you but is helpful for improving user experience. In the event that you provide Personal Information while visiting our Services, this data may be correlated to you and thus your Personal Information.

Beacons: We may also use web beacon or other technologies to better tailor the our Services to provide better customer service. If these technologies are in use, a non-identifiable notice of that visit is generated which may be processed by us or by suppliers or affiliates, or other entities.

Online Tracking: Many browsers provide the ability for a user to send a "Do Not Track" signal which indicates that a user does not wish to have activity tracked. We may collect Personal Information across third-party websites or online services and may permit third parties from tracking consumers while they use our Services. For a list of the trackers and our purpose for using them, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy. Currently there is no industry standard on how to respond to "Do Not Track" signals; however, if you send a "Do Not Track" signal while using our Services, we will take every effort to respect your wishes that are possible. In any event, we will adhere to the standards set forth in this Policy.

Third Party Sources: We may also obtain information from additional sources of data, not directly collected from you, to tailor our Services to provide better customer service. For example, you may engage with us through social media services or third-party platforms, plug-ins, or applications, through which you may allow us to have access to certain information in your profile or account, such as your name, email address, photographs, network connections, and activities. Please refer to the respective policies on those third-party services, platforms, plug-ins, and applications to review your privacy rights and settings. Information may include public or private data from various sources and held at varied secured data storage facilities, inside and/or outside of the United States or the European Economic Area. For an entire list of specific data collected from third-parties, how the data is stored, and our purpose for using the data, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy. We will hold such data for the period of time as set forth, and at least for any period of time required by law.

Advertising Choices We may provide third-party advertising on our Services in an attempt to provide additional content that may be relevant to you. We do not control the use of any information about you that the third-party advertiser may obtain or use, and recommend you review their data collection and use policies. There are a variety of tools which are available to you to "opt-out" of interest-based advertising including by utilizing the tools available from Network Advertising Initiative and Digital Advertising Alliance. There are also a variety of browser tools and plug-ins which you can use in an attempt to block advertising and advertisements as you use the internet. For an entire list of specific data collected by these third-parties, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy.

Your Medical Information: You may desire to receive more information about our Services in relation to your specific medical condition. For us to better answer your inquiries, we may ask you for information about your medical condition such as the level of care requested, any diagnosis requested or received, or any previous medical history. We may receive or provide information to your medical provider when you use our Services. In cases of emergencies, we may also provide this information to emergency care responders or other medical providers.

3.2. HOW WE USE INFORMATION.

We use the Information, including Personal Information and all other information, to provide you access to our Services, to personalize the content and experiences provided by our Services, to communicate with you about our Services, to offer you any additional products or services that we think you may have an interest in receiving, to analyze communication traffic, to help diagnose problems with our server, to administer our Services, to determine how users interact with our Services, and for other similar reasons. We may also use the Information to send you offers for products and/or services from third-parties, and to provide you with targeted advertising based on your activity involving our Services and any third-party websites, platforms, plug-ins, and applications.

We may also use Anonymous Information, Pseudonymous Information, or Aggregate Information (or other information other than Personal Information) in any other manner that we deem appropriate or necessary, including to operate, understand, and improve our Services, including by using research and analytics tools. Such use may include sharing this type of information with business partners and advertisers.

Dependent on the jurisdiction in which you access our Services, you may be required to expressly consent to the sale, sharing, or rent of your Personal Information to third-parties, as well as those not affiliated with us. Please review the applicable section of this Privacy Policy to you for a greater discussion relating to those rights. If those rights are not applicable to you, we may sell, share, or rent Personal Information to third-parties, and we may otherwise disclose Personal information to third-parties not affiliated with us. Notwithstanding, we may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us or our any one of our related companies, subsidiaries or affiliates, (2) protect and defend our rights or property or those of our users, or (3) act under exigent circumstances to protect the safety of the public or customers or visitors.

We may employ or engage companies and individuals to perform business functions on its behalf. These persons may be engaged in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing payments, and providing customer service. Unless you exercise a statutory right, such as a right to opt out, these persons may be provided with Personal Information or other information required to perform their functions as our agent.

To accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected by our Services. If our company or substantially all of our assets are acquired, your Personal Information and/or other Information may be one of the assets transferred to the acquirer. You may be given the opportunity to opt out of any such transfer if, in our opinion, the new entity plans to handle your information in a way that is different in an important way from this Policy.

For a list of how we use your Personal Information, how we provide such information to the third party, the information provided, and the purpose in providing the data, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy.

3.3. OUR USE OF THIRD-PARTY VENDORS.

We may use third party vendors, services, plugins, software, applications, platforms, and other service or technology partners (the "Third Party Vendors") to provide a more robust experience. The Third-Party Vendors may collect, receive, or generate information from or about you to provide valuable features and services and to otherwise make our Services available to you. You acknowledge that no method of transmission or electronic storage is completely secure, and we cannot control how your information is collected, stored, disclosed, or used on or by the Third-Party Vendors.

By using our Services, you acknowledge that you may be transferring and storing your information using the Third-Party Vendors at your own risk. Your data will be subject to the policies and practices set out in each Third-Party Vendor's respective privacy and data use policies. Use of our Services constitutes your acceptance of each Third-Party Vendor's privacy policy and data practices. For a list of specific data collected by third-party providers, our purpose for using the third-party provider, and a link to the Third-Party Vendor's privacy policy, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy. We will hold such data for the period of time as set forth, and at least for any period of time required by law.

4. THIRD-PARTY WEBSITES.

Our Services may include or provide links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

5. CONTACT INFORMATION AND REQUESTS.

If you have any questions about this Privacy Policy or our Services, or if you would like to request that we disclose or delete your Personal Information stored in our database, or you wish to exercise any rights granted to you by statute (such as those granted to you by the CCPA, GDPR, ePrivacy Directive, or other applicable statute), please feel free to contact us at:

PM APP, Inc.
ATTN: Legal Compliance / Data Protection Officer
480 W. Alluvial Ave.
Fresno, CA 93650
support@portalme.com
+1-844-443-4100
www.portalme.com

6. SECURITY.

The safe keeping of your Personal Information is extremely important to us. We have measures in place by which we intend to prevent the loss, misuse, and alteration of the information that we obtain from you, including implementing various technical, administrative, electronic, and physical security measures designed to prevent Personal Information from accidentally being used or accessed in an unauthorized way. Unfortunately, despite our efforts, there are no methods that can fully prevent a breach, we cannot be liable for unauthorized disclosure of Personal Information due to no fault of our own, including but not limited to, errors in transmission and unauthorized acts of our staff and third parties. In the event of a suspected data security breach, we will notify you and any applicable regulator where we are legally required to do so.

7. GOVERNING LAW.

Our Services are published in the United States intended for users from the United States. To the extent permitted, this Privacy Policy shall be governed by and construed and enforced in accordance with the laws of the State of California, without giving effect to any choice of law rule that would cause the application of the laws of any jurisdiction other than the laws of the State of California to the rights and duties of the parties. U.S. law shall govern in any and all disputes.

We hope that this Privacy Policy provides you with full and fair notice of your privacy rights and our Information collection and use practices. We also hope that any concerns you might have can be resolved quickly and amicably by you contacting us under the methods provided in the "Contact Information and Requests" section of this Policy. However, in the unfortunate event that such dispute cannot be resolved, by your use of our Services, you expressly agree that any actions between us, including pertaining to this Policy, our Services, or our use and collection of the Information, shall be held in Fresno, California. You hereby irrevocably consent to the exclusive jurisdiction of the state or federal courts in Fresno County, California in all disputes arising out of or related to this Policy, or the use of our Services.

To the fullest extent not otherwise prohibited or required by law to be resolved in a different manner, by using our Services, you agree that any controversy between you and us involving the construction or application of any of the terms, covenants, or conditions of this Privacy Policy shall be submitted to binding arbitration. The arbitration shall be conducted in Fresno, California, and be in accordance with the rules established by the American Arbitration Association and include limited discovery to be in accordance with and governed by the provisions of the California Arbitration Act, Sections 1280 through 1294.2 of the California Code of Civil Procedure. The prevailing party shall be entitled to recover its reasonable costs and expenses of arbitration, including reasonable attorneys' fees. Nothing in this section or agreement shall limit or impair us from seeking and obtaining temporary and permanent injunctive relief to enforce the terms of this agreement.

8. UPDATES TO THE POLICY.

This Privacy Policy was published on November 1, 2019 and last updated on November 1, 2020. It constitutes our entire agreement with you concerning our collection and use of Information as you use our Services. Notwithstanding, you may also be subject to additional terms and conditions, policies, guidelines, or rules that may apply when you use or interact with our Services.

We may, in our sole discretion and without prior notice, revise this Privacy Policy at any time. We shall post any revision to this Privacy Policy to our Services, and the revision shall be effective immediately on such posting, unless stated otherwise. You agree to review this Privacy Policy and other online policies we post or provide to you periodically to be aware of any revisions. You agree that, by continuing to use or access our Services, you agree to any such revision.

9. EUROPEAN RESIDENTS: YOUR PRIVACY RIGHTS.

Residents of the European Economic Area ("EEA") or European Union ("EU") and the United Kingdom ("UK") are afforded additional rights with respect to their Personal Information under the General Data Protection Regulation ("GDPR"). To learn more about your rights under these laws, please visit our "GDPR Privacy Policy" at www.portalme.com/privacypolicies or contact us pursuant to Section 5 of this Policy. In the case of any discrepancies between this Privacy Policy and your rights under the GDPR Policy, your rights under the GDPR Policy will govern.

10. CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS.

California residents are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et. seq.) and the "Shine the Light" Law (California Civil Code section 1798.83). To learn more about your rights under these laws, please visit our "California Privacy Policy" at www.portalme.com/californiapolicy or contact us pursuant to Section 5 of this Policy. In the case of any discrepancies between this Privacy Policy and your rights under the California Privacy Policy, your rights under the California Privacy Policy will govern.

11. NEVADA RESIDENTS: YOUR PRIVACY RIGHTS.

Nevada Senate Bill No. 220 requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your Personal Information to third-parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. To make such a request or learn more about our compliance with Nevada law, please contact us using the methods described in the "Contact Information and Requests" section of this Policy. In the case of any discrepancies between this Privacy Policy and your rights under relevant Nevada statutes, your rights under the statutes will govern.

California Privacy Policy

1. YOUR CALIFORNIA PRIVACY RIGHTS.

This policy is a supplement to our general privacy policy ("Privacy Policy") for those individuals covered by California laws. California residents are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et. seq.) and the "Shine the Light" Law (California Civil Code section 1798.83). All defined terms in the Privacy Policy shall retain the same meaning as this page.

2. CALIFORNIA CONSUMER PRIVACY ACT.

California residents have the right to request (1) more information about the categories and specific pieces of Personal Information we have collected, sold, and disclosed for a business purpose in the last 12 months, (2) deletion of your Personal Information, and (3) that we stop selling your Personal Information. We will not discriminate against you if you exercise your rights under the CCPA.

3. COLLECTION AND USE, DISCLOSURE, AND SALE OF PERSONAL INFORMATION.

Generally, in the preceding 12 months, we have collected and used, may have disclosed, and may have sold the following categories of Personal Information: identifiers, characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual, or similar information, inferences drawn about you, and other categories of Personal Information that relate to, describe or are reasonably capable of being associated with you.

For a list of the specific data that we collect, may disclose and sell, the sources from which we collect this Personal Information, and Personal Information we use for the business and commercial purposes, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies.

4. CCPA OPT-OUT.

California Civil Code Section 1798.120 permits users who are California residents to opt out of the sale of their Personal Information to third-parties. Please be assured that this does not mean that we have received money in exchange for your Personal Information. Instead, there are instances where we have shared information about you, collected through cookies, to provide you with personalized services. In abundance of caution, if this sharing is considered or in the future determined to be a "sale" pursuant to California law, or if you would like to exercise any other California privacy rights, requests can be made by either (1) calling our toll-free number at 1-844-443-4100 or (2) contacting us pursuant to the "Contact Information and Requests" section of our general Privacy Policy at www.portalme.com/privacypolicies.

5. SHINE THE LIGHT LAW.

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding the disclosure of Personal Information to third-parties, including our information sharing practices, including the names and addresses of those businesses with whom we have shared your Personal Information, for direct marketing purposes. To make such a request, please contact us pursuant to the "Contact Information and Requests" section of our general Privacy Policy at www.portalme.com/privacypolicies.

GENERAL DATA PROTECTION REGULATION POLICY

This policy is a supplement to our general privacy policy ("Privacy Policy") for those individuals covered by European law. General Data Protection Regulation ("GDPR") permits users who are in the European Economic Area ("EEA") or European Union ("EU") and the United Kingdom ("UK") to request certain information regarding the control, disclosure, and use of their Personal Information. In summary, those rights include the right to: fair processing of information and transparency over how we use your Personal Information, requires us to provide you with information regarding the information that we have about you and how we use that information, requires us to correct any mistakes in your information which we hold, requires the erasure of Personal Information concerning you in certain situations, and your right to object at any time to the processing, use, and automation of your data. All defined terms in the Privacy Policy shall retain the same meaning as this page.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office ("ICO") on individuals' rights under the GDPR. If you would like to exercise any of those rights, please contact us pursuant to the "Contact Information and Requests" section of our general Privacy Policy at www.portalme.com/privacypolicies.

1. HOW WE COLLECT INFORMATION UNDER THE GDPR.

Consistent with the Privacy Policy, and subject with applicable law of the GDPR and the choices and controls available to you as set forth herein, we may collect your Information in any way we feel necessary to provide you with the best experience when using our Services or in our dealings with you, to protect your interests, communicate our interests, or generally become better informed about you as our valued customer. Additionally, we may collect information as described in the "How We Collect Information" section of the general Privacy Policy. For more detailed information on the information we collect, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies.

2. HOW WE USE INFORMATION UNDER THE GDPR.

Generally, we have collected and used, may have disclosed, and may have sold the following categories of Personal Information: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual, or similar information, inferences drawn about you, and other categories of Personal Information that relate to, describe or are reasonably capable of being associated with you.

For a list of the specific data that we collect, disclose, and sell, the sources from which we collect this Personal Information, and Personal Information we use for the business and commercial purposes, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies.

3. TRANSFER YOUR INFORMATION OUT OF EUROPEAN ECONOMIC AREA.

We may transfer your Personal Information to areas outside of the EEA. Such countries do not have the same data protections as the EEA and the UK. The European Commission has determined some territories or countries are inadequate to receive certain data. While we take efforts to restrict transfer to those countries, we may in some instances transfer such data because it is necessary for us or we have determined it is a compelling legitimate interest. Where we transfer your Personal Information to countries outside of the EEA, we will take steps to ensure that your Personal Information will continue to be protected. In those instances, we will implement appropriate safeguards for the transfer of Personal Information to our service providers in accordance with the applicable law, such as relying on our service providers' Privacy Shield certification or implementing standard contractual clauses for data transfers. For a list of the data transferred, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies.

4. AUTOMATED DECISION MAKING.

We may subject you to a decision based solely on automated processing, including profiling, in a manner which produces legal effects or similarly significantly affects you, without your express consent. For a list of the purposes in which we make automated decision processing, please visit our "Privacy Disclosures Page" at www.portalme.com/privacypolicies.

5. HOW TO COMPLAIN UNDER GDPR.

The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred. We invite you to raise your concerns with us first, so that we can try to resolve them.

6. GDPR RIGHTS.

You have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected or erased and to port your Personal Information. You may also have the right to object to, or request that we restrict, certain processing or to withdraw consent you have previously provided. If you have any requests regarding your Personal Information, have any inquiries regarding this Privacy Policy, or you would like to exercise your rights or receive any information about your rights, please contact us pursuant to the "Contact Information and Requests" section of our general Privacy Policy at www.portalme.com/privacypolicies.

PRIVACY DISCLOSURES PAGE
1. CALIFORNIA DISCLOSURES.

This section explains your rights regarding your Personal Information that we collect, as set forth in the California Consumer Privacy Act or the ("CCPA"). All defined terms in the California Privacy Policy shall retain the same meaning as this page. The following chart summarizes our Personal Information collection, use, and sharing practices in the preceding 12 months since we last updated this Policy on January 1, 2020.

Category of Information Source of Information Purpose of Collection Vendors and other third-party entities with whom we share this information Disclosed or sold for a business or commercial purpose
Identifiers, such as, your name, address, email address, and username You and your devices To process your requests for products, services, or information, to communicate with you, to improve our services, to enforce our agreements, to enforce our Terms of Use, to register your account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.
If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.
Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code ยง 1798.80(e)) You and your devices To process your requests for products, services, or information, to communicate with you, to improve our services, to enforce our agreements, to enforce our Terms of Use, to register your account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.
If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.
Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
Protected Classification characteristics under California law, such as, your racial or ethnic origin, religion, or sexual orientation You and your devices If you are in the U.S. ONLY and you opt-in to do so, to improve our services, better understand our customer base, meet our diversity and inclusion goals; and to help our business partners do the same. Service providers who assist in providing services on our behalf. If you are in the U.S. ONLY and you opt-in to do so, our business partners. No
Commercial Information, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies You and your devices To fulfill your requests for products or services, to improve our services Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
Internet or Electronic Network Activity Information, e.g., browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, or questions and other messages you address to us directly through online forms or by email You and your devices To process your requests for products, services, or information, to communicate with you, to improve our services, to enforce our agreements, to enforce our Terms of Use, to register your account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes. Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
Other Identifiers and Internet Activity Information, e.g., IP address; similar information You and your devices To process your requests for products, services, or information, to communicate with you, to improve our services, to enforce our agreements, to enforce our Terms of Use, to register your account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes. Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
Inferences about personal preferences and attributes drawn from profiling You and your devices To improve our services, to help us better understand our customer base and to help our business partners improve their offerings. Service providers who assist in providing services on our behalf.
If you opt-in to do so, our business partners.
No
2. EUROPEAN DISCLOSURES.

This section explains your rights regarding your Personal Information that we collect, as set forth in the General Data Protection Regulation or the ("GDPR"). All defined terms in the GDPR Privacy Policy shall retain the same meaning as this page. The following chart summarizes our Personal Information collection, use, and sharing practices since we last updated this Policy on January 1, 2020.

Purpose Type of Data Lawful Basis
Recognize you and analyze how you, and other users, navigate our Services and apps and what type of content you're interested in, and to manage and improve our services and products by testing new features. Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details. Legitimate Interest.
Recognize you and analyze how you, and other users, interact with ads on our services and what type of ads you're interested in. Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details. Consent.
Communicate legal information to you. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile). Legitimate Interest.
Analyze comments and feedback you have given us including comments, feedback and reviews you have posted on our Services in order to use the information to carry out journalistic activities, to improve our services and content offerings, and to enforce our Terms of Service. Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data). Legitimate Interest.
Provide you with communications and services you've signed up, for such as our newsletters. Data that directly identifies you such as your name, username, email address and location data. Creation or performance of a contract.
Register you as a user of our Services and other products and services and administer your account. Data that directly identifies you (such as your name, username, and email address and other information included in your user profile). Creation or performance of a contract.
Publish content including articles, feedback, reviews, and user comments about our posts. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile). Creation or performance of a contract.
Fulfill orders for our products or services. Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data. Creation or performance of a contract.
Collect money you owe use. Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data. Legitimate interest.
Verify or obtain payments due to us when you buy something from a third party after clicking on an "affiliate" link in our content, measure the performance of affiliate links, analyze, and develop this part of our business. Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data). Legitimate interest.
Communicate our terms, notify you about changes to them and communicate with you about non-compliance. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address). Creation or performance of a contract.
Communicate our Privacy Policy and notify you of changes to them. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address). Creation or performance of a contract.
Conduct surveys or undertake similar types of research so that we can improve and develop our business, our services. ata that directly identifies you such as your name, username, name, email address and location data. Consent.
Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity. Data that directly identifies you such as your name, username, and email address. Creation or performance of a contract.
Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address). Legitimate interest.
Send marketing communications to you if you subscribe to our newsletters or other products and services. Data that directly identifies you such as your name and email address. Consent.
Communicate with you about our services that you sign up to receive when you create an account and transactions that you conduct using our services, including published content you visit, content you submit for publication on our Services, and content posted by you relating to our Services (including your comments on content, feedback and reviews). Data that directly identifies you such as your name and email address. Creation or performance of a contract.
Comply with applicable laws, regulations, and legal and regulatory processes. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address). Creation or performance of a contract.

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