Privacy policy

Effective date: September 2, 2021

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:

How do we collect personal information?

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

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

Children's Information

GFS is 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.

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:

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:

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, you are authorizing us to 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. Some of these technologies may operate without collecting or using any personal information. Please note this Privacy Policy applies to our collection, use, disclosure and storage of personal information only.

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.

By using our Services, you consent to:

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

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 include Google AdSense. 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

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.

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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