1. Introduction

This Privacy Policy ("Policy") sets out how Global File Systems, Inc./ AdFreeway ("AdFreeway," "we," "us," or "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 www.adfreeway.com ("Site"), mobile application ("App") and platform (collectively, our "Services"). For the purpose of this Notice, "Personal Information" means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.

Our Services are used by our current and potential clients ("Clients"), Users who sign up for AdFreeway Rewards Program("Users") and individuals who visit our Site ("Site Visitors").

By using our Site or App or otherwise using our Services, you acknowledge this Policy. If you do not agree with 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 Wi-Fi networks, we do not operate or own these networks.

2. 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 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 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 Policy or convey any concerns about our handling of your Personal Information, please Contact Us.

3. What Personal Information Do We Collect?

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you. You are not required to provide any Personal Information to us to interact with our Site; however, if you do not provide your Personal Information, you may not be able to benefit fully from our Services. For example, if you do not provide your name and email address, we cannot create a member account and you will be unable to participate in the Rewards Program.

We collect Personal Information as follows:

A. 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, among others, 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)

B. Information That You Provide to Us

The types of Personal Information we collect about you may include information you provide to us directly as follows:

For Site Visitors

• Contact information such as your first and last name, email address, country of residence, telephone numbers, mobile numbers; and
• Social media account information, if you choose to interact with us through third-party social media such Facebook, Instagram and LinkedIn.

For Users

• Name(s);
• Contact details such as mailing 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 us;
• Audio and visual information, including any photos or videos you post;
• Comments, text, or other User Content (as defined in our Terms & Conditions)
• 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 transa
ctions, products and interaction with our digital Services and platforms;
• Financial information for monetary rewards such as your PayPal account;
• Records of communications and interactions with us and in connection with our Services; and
• Other Personal Information you provide to us.

For Clients

• Contact information such as your first and last name, job title, email address, business address, shipping address, telephone numbers, mobile numbers; and
• Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.

C. Information Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when Clients, Site Visitors and Users visit or interact with the Site, App or Services ("Usage Information"), including via cookies and other tracking technologies. This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device ("Device") whenever you visit or interact with our Services. (We call this information "Device Data.") Usage Information includes:

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
• Referring and exit web pages and URLs;
• The areas within the Site and App that you visit and your activities there, including remembering you and your preferences;
• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
• Your Device characteristics (such as device type) and ID, operating system, hardware);
• Certain other Device data, including the time of day you visit our Site or App or other information used to provide analytics or other usage information;
• Information about your engagement with our emails; and
• Statistical information about how both unregistered and registered users, collectively, use the Site, App and Services.

For more information, please see the "Device Data and Other Technologies" section below.

D. Information Collected from Third Parties

As a part of our business, we append Personal Information that we collect with information such as unique advertising identifiers from third party sources.

In addition, our Site and App include functionality that allows certain kinds of interactions between the Site or App and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Company from third parties. We might also provide links to make it easier to send a communication from the Site or App, or we may use third parties to make it easier to send emails or post to social media (like a "Share" or "Forward" button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Company.

We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

E. Information We Infer About You

We also may draw certain inferences drawn from other Personal Information to create a profile about you reflecting your preferences or behavior as related to certain advertisements. This may also be considered Personal Information in some jurisdictions.

4. 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 username, 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 Usage Information and Device Data) to curate the ads you receive to improve your online experience. Our platform may block, re-prioritize 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.

A. Third-Party Technologies

We believe in being transparent about how our Services work. As a part of our business model, we use the following 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.
• The Trade Desk: see privacy policy here, or you can opt out of their services here.

As allowed by applicable law, by using our Services, you consent to the collection, use and disclosure of any Personal Information contained in the Device Data in accordance with these Terms and the 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 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.

5. Children's Information

We are committed to protecting the online privacy of children. We do not knowingly collect Personal Information from children under 16 or allow them to create an account. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please Contact Us to request the deletion of that information.

6. How Do We 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.

7. Retention of Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, prevent fraud, resolve disputes and enforce our agreements and policies.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

• How long we have had a relationship with you or provided our Services to you;
• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;
• Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments; defend against potential legal claims; detect or prevent fraud or potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;
• The privacy impact on individuals of ongoing retention; and
• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

8. Why Do We Collect Your Personal Information?

We handle your Personal Information for the following purposes: 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.

9. 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 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.

10. To Whom Do We Disclose Your Personal Information?

We 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.

11. Do Not Track Disclosures

We respect 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 California and Delaware law. For more information about DNT signals, visit http://allaboutdnt.com.

12. 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 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.

13. Australia Privacy Rights

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

We disclose Personal Information, for some of the purposes described above, to organizations located in Australia and in other countries, including New Zealand, Brazil, European Union member states, 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, Brazil, European Union member states, 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, we 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 www.oaic.gov.au).

14. Brazil Privacy Rights

If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados ("LGPD"). These rights include:

• The right to confirmation of the existence of the processing;
• The right to access the data;
• The right to correct incomplete, inaccurate or out-of-date data;
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
• The right to the portability of data to another service or product provider, by means of an express request;
• The right to delete personal data processed with the consent of the data subject;
• The right to information about public and private entities with which the controller has shared data;
• The right to information about the possibility of denying consent and the consequences of such denial; and
• The right to revoke consent.

A. Legal Basis for Processing Data Under the LGPD

Our legal bases for collecting or processing your Personal Information are as follows:

• We need to provide a service to you;
• You have given us your consent to do so;
• The processing is in our legitimate interests, and it is not overridden by your rights; or
• To comply with the law.

B. Duration of Processing

For more information about how long we retain your Personal Information, please see the "Retention of Personal Information" section above.

C. Exercising Your Rights Under the LGPD

If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency to obtain the information. We will respond to your request within 15 days or let you know if we need additional time.

15. EU Privacy Rights

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area ("EEA"). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation ("GDPR"). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, we are considered the "data controller" of the Personal Information collected on the Site. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law. In other circumstances, we may be considered a "data processor" of Personal Information for Affiliates and Redemption Partners, and process the Personal Information at the direction of those parties.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have collected from you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

A. Legal Basis for Processing Personal Information

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:

We rely on the following legal bases for processing your Personal Information:

• Contract: To conclude or perform a contract with you; for example:
  • To provide other Services;
  • To manage our accounts and records;
  • To handle your inquiries and requests;
• Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
  • To respond to your customer service inquiries and requests for information;
  • To maintain, improve, and analyze our Site, App and Services we offer;
  • To conduct marketing activities;
  • To detect, prevent, or investigate security breaches or fraud; and
  • To facilitate the functionality of our Site and App;
• Legal Compliance: To comply with our legal obligations; for example:
  • To maintain appropriate records for internal administrative purposes and as required by applicable law, and
  • To provide important product safety information.
• Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

B. How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us here.

16. UK Privacy Rights

If you are based in the United Kingdom, the following provisions also apply:

If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission's Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner's Office.

17. California Privacy Rights

This section of the Policy applies solely to California residents. While we do not currently meet the thresholds for the applications of the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), we provide the information below as a courtesy to California residents. Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;
• To know the length of time we intend to retain each category of Personal Information;
• To know whether your Personal Information is sold or disclosed and to whom;
• To access your Personal Information;
• To delete the Personal Information you have provided to us, with certain exceptions;
• To correct your Personal Information;
• To opt out of the sale of Personal Information;
• To know if Sensitive Personal Information ("SPI") is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
• To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
• Not to be discriminated against, even if you exercise your privacy rights.

A. Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

• The categories of Personal Information collected about you;
• The categories of sources from which the Personal Information is collected;
• The business or commercial purpose for collecting, selling or sharing Personal Information;
• The categories of third parties to whom the business discloses Personal Information; and
• The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

B. Personal Information Collected

The categories of Personal Information from consumers within the last twelve (12) months are identified above in the "What Personal Information Do We Collect?" section.

Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.

C. Personal Information Sold, Shared or Disclosed for a Business Purpose

We have provided your Personal Information to third parties in the last twelve (12) months as detailed in the "To Whom Do We Disclose Your Personal Information" section above.

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

D. Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell a business operating under the CCPA not to sell Personal Information – this is called the "right to opt-out" of the sale of Personal Information. While we do not meet the threshold required for application of the CCPA, we have provided information about opting out in the "Device Data and Other Technologies" section above.

E. Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Please note that we do not collect any Sensitive Personal Information.

F. Right Not to Be Discriminated Against

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

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

G. Notice of Financial Incentives

While our activities are not subject to the CCPA, we wanted to inform you about certain financial incentives and benefits you receive by joining our Rewards Program. The information that we collect for enrollment in the program (listed above) allows us to provide our Services. This, in turn, helps us establish a stronger relationship with you – something we value.

If you participate in our Rewards Program, there are two types of financial incentives you may receive:

• Direct payment. We make direct payment to you via PayPal.
• Gift Cards. We provide you with gift cards to various stores via a third party such as Tango.

In determining the value of your Personal Information to us, we consider, among other things, the length of your relationship with us, your Voting Activity, your engagement with advertisements shown to you on or off our platform, and your assistance in reporting suspicious or undesirable content.

Participation in our Rewards Program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the Rewards Program, please Contact Us.

H. Third Party Marketing

California Civil Code Section 1798.83 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 their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.

I. Exercising Your California Privacy Rights

If you or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information, please Contact Us.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include "California Privacy Rights" as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

18. Privacy Rights under Other US State Laws

While we do not currently meet the thresholds for the application of several US state privacy laws, we provide the information below as a courtesy to residents of those states. Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

• To confirm whether or not a controller is processing your personal data and to access such personal data;
• To correct inaccuracies in your personal data;
• To delete your personal data;
• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
• Not to discriminate against you because you have exercised any of these rights, including by:
  • denying you Services;
  • charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
  • providing you a different level or quality of Services; and/or
  • suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, please Contact Us.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

A. Right to Opt Out

You may have the right to opt out of the sale of your Personal Information and targeted advertising. We have provided information about opting out in the “Device Data and Other Technologies” section above, or you may Contact Us.

B. Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. If required by applicable law, when we detect such a signal, we will make reasonable efforts to respect your choices.

C. Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

19. Contact Us

If you have any questions about this 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.