This Privacy Policy sets out how Global File Systems, Inc. (GFS, we, us, our) collects, holds, uses and discloses your personal information in accordance with applicable law, in connection with the ADFREEWAY Rewards Program (Rewards Program) and your use of our services, website, and platform (collectively, our Services).

If you do not agree with the terms of this Privacy Policy or our Terms & Conditions, then you should immediately discontinue use of our Services without providing us any personally identifiable information.

Although our Services may be available via Affiliate (defined below) or other third-party WiFi networks, we do not operate or own these networks.

Updates to this Privacy Policy

This Privacy Policy is effective as of the date above and will remain in effect until a new policy supersedes it. We may update this Privacy Policy, at our sole discretion, from time to time at ADFREEWAY.com/Privacy. The most recent version of the Policy will be reflected by the “Effective” date noted at the top of the page. In the event of a material change to this Privacy Policy, we will provide a conspicuous message either through our website, or platform, or we may also notify you by email of any material changes to this Policy. Your affirmative consent or continued use of our Services will constitute your acknowledgment of the Policy in its current version and your understanding of the terms of this Policy.

To receive a copy of this Privacy Policy or convey any concerns about our handling of your personal information, please refer to "How to contact us or make a complaint" below.

What personal information do we collect?

The types of personal information we collect about you may include:

• name(s);
• contact details (e.g. address(es), origin, email address(es), telephone number(s));
• response when voting on ads or User Content displayed via our platform by clicking on the "thumbs-up" or "thumbs-down" (or similar) buttons (Voting Activity);
• information about ads you consider inappropriate, annoying or unwanted;
• relevant employment details (e.g. role title) and any other personal information Rewards Program Redemption Partners provide to GFS;
• audio and visual information, including any photos or videos you post;
• comments, text, or other User Content (as defined in our Terms & Conditions)
• device information when you use the Services, including: MAC and IP address; device configuration; and selected packet, hashed URL, browsing and location data (Device Data) (see below for more information);
• user ID and/or user name associated with a third-party social media service, any information or content you have permitted such social media service to share with the Affiliate network or us, such as your profile picture, email address, followers or friends lists, and any information you have disclosed in connection with that social media service;
• transaction information and history relating to redemption of Tokens (including details and value of your redemptions);
• details and history of preferences, interests and behavior relating to transactions, products and interaction with our digital Services and platforms;
• records of communications and interactions with us and in connection with our Services;
• Inferences drawn from any information to create a profile about you reflecting your preferences or behavior; and
• other personal information you provide to us.

How do we collect personal information?

We may collect your personal information relating to our Services including when you:

• sign-up to become a member of the Rewards Program;
• browse the Internet or access selected apps;
• log-in to your social media service account;
• use or access the website or platform-related functionality, such as the voting buttons;
• upload content;
• redeem rewards from Redemption Partners;
• email, contact or otherwise communicate with us; or
• in the course of receiving a requested product, service or benefit from (or having any other dealings with) us.

We may also collect personal information from third-parties including:

• entities with whom we partner to carry out a campaign, including inter alia an advertiser, advertising agency, advertising network, demand side platform (or DSP), Internet network provider, sponsor, venue, website publisher, app publisher, app developer, device provider (collectively, Affiliates);
• Affiliates and third-party sponsors who participate in the ADFREEWAY Rewards Program and make Rewards available via the redemption of tokens by members (Redemption Partners ) and their service providers (such as point of sale vendors);
• other members who upload content;
• third-party social media services when you sign-in through such social media networks;
• other ADFREEWAY group companies; and
• your representatives (including legal representatives)

Children's Information

GFS is committed to protecting the online privacy of children. We do not knowingly collect personal information from children under 13 or allow them to create an account.

How do we hold and protect your personal information?

We maintain personal information in a combination of our secure online systems, paper-based files and other records, both at our own premises and with the assistance of service providers located in Australia and/or the United States.

In doing so, we take reasonable steps to protect your personal information from misuse, interference and loss, and unauthorized access, modification or disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us.

Consequences if you do not provide us with your personal information

You are not required to provide any personal information to us, however, if you do not provide your personal information, we may not be able to provide products, services or benefits in connection with the Rewards Program. For example, if you have not provided your name and email address, we will not be able to create a member account and you will not be able to participate in the Rewards Program.

Why do we collect, hold, use and disclose your personal information?

We handle your personal information for the purposes of providing, administering, improving and personalizing the Rewards Program, our products and services, and the products and services of other Redemption Partners. This can include registering you to participate in the Rewards Program; enabling you to access the Rewards Program platform; providing Rewards Program benefits; procuring ads and online content matching your interests and voting feedback; verifying your identity, communicating with you (including through direct marketing, where we are permitted to do so); understanding your interests and preferences to help us tailor our communications and offers to your needs; handling your queries and complaints; assessing the performance of the Rewards Program website and platforms and improving their operation; analyzing data; conducting surveys, market and product research; producing analytics to improve their advertising and marketing services; otherwise providing goods, services and benefits you have requested or are eligible to receive in connection with the Rewards Program; working with our service providers; and any other purposes which we have notified to you at the time of collection of the information, or to which you have provided consent.

We may also handle your personal information:

• to enforce our legal rights and obtain professional advice;
• to comply with industry standards and our policies;
• as required or authorized by law or a court or tribunal order; and
• to facilitate purchases or potential purchases of, or investments in, our business or a group company.

Legal basis for processing your personal information

This section only applies if you are located within the UK/EU.

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a service from us and we need to use your contact details and payment information in order to process your order and provide the services.
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

Direct marketing choices

Where we have your consent or are otherwise permitted by law to do so, we may also use and disclose your personal information to provide you with marketing communications and targeted advertising on an ongoing basis by sending electronic messages (such as SMS or email), through our Services and by other means.

These communications may relate to the products and services we, other Rewards Program participants (such as our Redemption Partners) and other group companies provide, promotions run by us or for which there is automatic entry for Rewards Program members, and other products or developments which may be of interest to you.

You may opt-out of receiving future electronic and telephone direct marketing communications through the unsubscribe function that will be made available to you with each direct marketing communication. Please Contact Us to understand the consequences of unsubscribing from email communications.

To whom do we disclose your personal information?

ADFREEWAY may disclose your personal information to:

• various third-party service providers we or our group companies engage in connection with the Rewards Program, including service providers who assist with the development, administration, marketing or improvement of the Rewards Program, or with Rewards Program-related data processing/analysis;
• other Rewards Program participants, including Redemption Partners or other rewards providers as is reasonable or necessary for the operation of the Rewards Program including inter alia anonymized and aggregated data;
• public users who vote on User Content
• our Affiliates;
• our professional advisers such as accountants, solicitors, business advisers and consultants;
• government bodies and regulatory authorities, including if required or authorized by law;
• companies that we plan to merge with or be acquired by or who may invest in our group companies; and
• our related group companies, for their internal purposes only.

Social Media Login

As noted above, if you register as a member by accessing or logging-in to an Affiliate network through a third-party social media service, the information we may collect and use are your user ID and/or user name associated with that social media service, any information or content you have permitted the third-party social media service to share with the Affiliate network or us, such as your profile picture, email address, followers or friends lists, and any information you have disclosed in connection with that social media service. When you log-in to access our Services through third-party social media services, we may collect, store, use and disclose such information and content in accordance with this Privacy Policy. If you do not want your personal information collected, stored, used or disclosed in this way, please do not log-in through a third-party social media service. We do not collect your passwords from these third-party social media services.

Device Data and other technologies

We may use digital technologies such as cookies, location services, web server logs and web beacons, ad optimization technology, machine learning and user profile algorithms in connection with the Rewards Program website, platform, social pages and other digital portals. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information, such as a session ID which the website uses to track the pages you have visited. Other technologies we use include web beacons. We allow cookies and other digital technologies to be used:

• so that your preferences for a particular website can be stored;
• to improve your browsing experience; and
• to help tailor advertising and promotions to you.

Generally, the cookies we use fall into the following categories:

• Session cookies: These allow our site to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
• Persistent cookies: These are stored on your device in between browser sessions. They allow your preferences or actions across the site to be remembered. These will remain on your device until they expire, or you delete them from your cache.
• Strictly necessary cookies: These cookies are essential for you to be able to navigate the site and use its features. Without these cookies, the services you have asked for could not be provided.
• Performance cookies: These cookies collect information about how you use our site, e.g. which pages you go to most often.
• Functionality cookies: These cookies allow the site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features.
• Advertising/third party cookies: see below.

Our ad optimization technology relies upon information we collect (including your preferences and Device Data) to curate the ads you receive to improve your online experience. Our platform may block, re-prioritise or substitute ads that you would have otherwise received based on your Voting Activity, Device Data, online activity, and other information we have collected about you.

The Rewards Program website may use cookie data to track user traffic patterns and to provide better service when you revisit our website.

Whenever a URL or ad is accessed via the Rewards Program platform, information is recorded such as the time, date, URL hash, ad and Voting Activity.

In some cases, we and third-parties (or our or their respective Affiliates) may use cookies and other technologies in connection with the Rewards Program website, any Rewards Program app and digital marketing initiatives to track online activities over time and across different websites, for example in relation to online behavioral advertising, surveys and website analytics and email campaign tracking. The third-party technologies we may use from time-to-time are listed below. You can find more details online about these technologies, the data they collect and how to opt-out of certain conduct in the privacy policies and other consumer-facing documentation for those technologies. You may need to opt-out separately from each technology. Please be aware, however, that if you disable these technologies, you may not be able to experience the full functionality of the Rewards Program website and associated services.

Third Party Technologies:

• Google tag manager/Google analytics/Google Adsense/Youtube: see privacy policy here.
• Facebook: see privacy policy here.
• LinkedIn: see privacy policy here.
• theTradeDesk: see privacy policy here.

By using our Services, you (where not located in the UK/EU) consent to:

• collection, use and disclosure of any personal information contained in the Device Data in accordance with these Terms;
• interception of any communications (to the extent contained in the Device Data) to provide our Services including curating and improving your online experience with ad optimization technology.

If you are located in the UK/EU, we will collect the relevant consents for cookie use separately. For other activities, we may not require your consent all the time, and we may rely on other legal basis to process your personal data – see “Legal basis for processing your personal information” above, for further details.

If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.

Please note that if you have accepted third-party cookies and subsequently wish to remove them, you must do so from your own browser (as per the instructions above).

Additional Disclosures for Australian Users

As applicable, this Policy is subject to and does not limit the rights and/or exceptions available to ADFREEWAY under the Australian Privacy Principles of the Privacy Act 1988 (Cth) (the Privacy Act).

ADFREEWAY discloses personal information, for some of the purposes described above, to organizations located in Australia and in other countries, including New Zealand, the United States, United Kingdom, Israel and South Africa. We or our service providers may also make personal information held in Australia or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as New Zealand, United States, United Kingdom, Israel and South Africa. We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information, and only use it for the purpose for which it was disclosed.

At your request, ADFREEWAY will provide a copy of any personal information we hold about you, unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will obtain your prior consent.

When your personal information is no longer required, we take reasonable steps to destroy or permanently de-identify the information.

We will promptly acknowledge and investigate any complaint about the way we manage personal information.

We will take reasonable steps to remedy any issues resulting from our failure to comply with privacy obligations. If our response to you does not satisfactorily address your concerns, you may have the right to make a complaint to a competent regulator (e.g. Office of the Australian Information Commissioner at oaic.gov.au).

California Do-Not-Track Disclosures

GFS respects your privacy, but we do not alter the information we collect or change our services upon receiving “do-not-track” signals, as the term appears in Cal. Bus. & Prof. Code §§ 22575(b)(5). For more information about DNT signals, visit http://allaboutdnt.com.

How you can access and correct your personal information

We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can ensure certain personal details (i.e., name, address, email, phone, etc) are updated in your account settings on ADFREEWAY.com or Contact Us.

If you are located in the UK/EU, you have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information. We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details below. You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

How to contact us

If you have any questions about this Privacy Policy, wish to update information we hold about you or wish to make a complaint about our collection, use or disclosure of your personal information in connection with the Rewards Program, please Contact Us.

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