At Adgat Reach, accessible from https://adgatreach.com, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by Adgat Reach and how we use it.

In principle, we will only use your personal data in accordance with applicable data protection laws, in particular the Delaware Online Privacy and Protection Act (“DOPPA”), the General Data Protection Regulation (“GDPR”), and only as described in this privacy policy.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Adgat Reach. This policy is not applicable to any information collected offline or via channels other than this website.

What is Personal Data?

Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.

What are the relevant legal bases?

In accordance with Art. 13 GDPR the following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:

Consent

This is where we have asked you to provide explicit permission to process your data for a particular purpose. (Art. 6 Para. 1 lit. and Art. 7 GDPR)

Contract

This is where we process your information to fulfil a contractual arrangement we have made with you. (Art. 6 Para. 1 lit. b GDPR)

Answering your business enquiries

This is where we process your information to reply to your messages, e-mails, posts, calls, etc. (Art. 6 Para. 1 lit. b GDPR)

Legitimate Interests

This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. (Art. 6 Para. 1 lit. f GDPR). Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

Legal Obligation

This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime. (Art. 6 Para. 1 lit. b GDPR)

Vital interests

This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights. (Art. 6 para. 1 lit. d GDPR)

Your Rights - GDPR Specific Rights

• You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
• You have according to. Article 16 GDPR the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
• In accordance with Art. 17 GDPR, you have the right to demand that data concerning you be deleted without delay or, alternatively, in accordance with Art. 18 GDPR, to dexmand restriction of the processing of the data.
• You have the right to demand that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to demand that it be transferred to other data controllers.
• You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
• You have the right to revoke given consents according to Art. 7 para. 3 GDPR with effect for the future.
• You may object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against the processing for purposes of direct advertising.

If you wish to rely on any of your data subject rights or have a request, please contact us.

California Specific Rights

• If you are a California resident, you have the following rights:
• You have the right to:
• request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
• request that we delete personal information that we collect from you, subject to applicable legal exceptions.
• “opt out” of the “sale” of your “personal information” to “third parties”
• In addition under California’s “Shine the Light” law, California residents who provide personal information (as defined in the statute) to obtain services are entitled to request and obtain from us, once per calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediate prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain the information about data we hold about you or to effect the opt out, please contact us.

What are the purposes for processing?

Provision of the online offer, its contents and the website functions. Provision of contractual services, service and customer care. Answering contact enquiries and communication with users. Marketing, advertising and market research. Security measures.

What Personal Data is Collected? Information you provide to us

When you participate in, access, request or use any of our services, activities or online content, we receive personal information about you which we use to provide these services. This may consist of data such as your name, email address, postal address and telephone number.

Content you share with us

When you participate in, access, request or use any of our services, activities or online content, we receive personal information about you which we use to provide these services. This may consist of data such as your name, email address, postal address and telephone number.

Information collected online

We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.

Email communications

We use web beacons in our emails to track the success of our marketing campaigns. If you open an email from us, we can see which of the pages of our website you visited. Our web beacons don’t store any information on your computer but communicate with our cookies and tell us when you have opened an email from us. Data collected is linked, for example if you have used our service and later choose us again, we will link your data and treat that linked data as Personal Data.

How personal data is collected, We collect personal data in the following ways:

• Direct interactions you may provide personal data when you complete online forms, request products/services, use our contact form or otherwise or correspond with us (by post, phone or email).
• Automated Technology we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.

General information on data processing

• In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the USA, India and the EEA. Where we transfer data outside Switzerland or EEA, we have highlighted this accordingly below.
• All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the respective legal regulations mentioned above or with your consent. In particular, only when data processing is permitted and if:
• you have given your consent, the data is necessary for the fulfilment of a contract / pre-contractual measures, the data is necessary for the fulfilment of a legal obligation or the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
• SwagClix processes and stores your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Processing of Automatically Collected Data

• a) Hosting To provide our website, we use the services of Digital Ocean who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.
• b) Collection of access data and log files We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider,
• c) Use of cookies We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.
• d) Google Analytics On our website we use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by the users is usually sent to a Google server in the USA. The legal basis for the data processing is your consent.
• e) Google TagManager We use Google Tag Manager, a web analytics service provided by Google, Inc. This service allows website tags to be managed via an interface. The Google Tag Manager only implements tags. No cookies are set, and no Personal Data is collected. The Google Tag Manager triggers other tags that may collect data. The Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it remains in place for all tracking tags, insofar as these are implemented with the Google Tag Manager. More information on the Google Tag Manager can be found at the following link: http://www.google.com/tagmanager/use-policy.html. The legal basis for this processing is our legitimate interest.
• f) Google Fonts We integrate the fonts of the provider Google Inc, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on my legitimate interest in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. The legal basis for this processing is our legitimate interest.
• g) reCAPTCHA We also use Google`s reCAPTCHA from Google Inc of 1600 Amphitheatre Parkway Mountain View, CA 94043, US to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for the data processing is our legitimate interest in operating a secure and spam free website

What Personal Data do we process?

We may process the following data which may contain Personal Data: information that you provide by filling in forms, including information provided at the time of contacting us, subscribing to any services provided by us, posting material, reporting a problem, or requesting further services; information, data, documents or images that you share with us; details of transactions you carry out with us when you use services we offer; details of your visits to our website, resources that you access and actions you are working on through the website; if you contact us, a record of that correspondence; and We process Personal Data within the scope of our services. In doing so, we process: inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment usage data and metadata (e.g., in the context of you visiting our website).

Data processing when you submit it to our website and when you use our services.

When you contact us through our website or use our services, some data is collected and processed by us or on our behalf by our selected third-party providers.
• a) Contacting us If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our overriding legitimate interest in processing your request.
• b) Data management and customer support For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data may be stored on our website and or our customer relationship management system ("CRM system"). This data processing is based on our legitimate interest in providing our customer service.
• c) Contract processing We process your first name, last name, e-mail address, and the data related to your contract with us data to handle the contractual relationship between you and us. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations.
• d) When using our services including surveys We process the data of our clients and registered users, in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information. Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation, interest-based and behavioral marketing, profiling. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your Consent

Consent

By providing your Personal Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy. Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us. Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Personal Data in accordance with this privacy policy. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

Duration of data storage

We only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.

Transfer of personal data

We will not disclose or otherwise distribute your personal data to third parties unless this: is necessary for the performance of our services, you have consented to the disclosure, or the disclosure of data is permitted by relevant legal provisions. However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DOPPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DOPPA and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.

Automated decision-making

Automated decision-making including profiling does not take place at SwagClix.

Your data subject rights

These rights are standardized in the DOPPA and GDPR. These include: the right to information,

• the right to rectification,
• the right to erasure,
• the right to restriction of data processing,
• the right to data portability,
• the right to object to data processing,
• the right to revoke any consent you have given, and
• the right to lodge a complaint with the competent supervisory authority

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject. We encourage you to contact us if you have any information requests, requests for information or objections about data processing or concerns. However, you also have the right to file a complaint with your local supervisory authority. However, we would appreciate it if you would contact us with your concern before turning to a supervisory authority.

Exercising Your Privacy Rights

You may also designate an authorized agent to make a request on your behalf as provided under California law and we reserve the right to request proof of such authorization. Further, you can also make a verifiable consumer request on behalf of your minor child. However, please note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you, or if you do not provide us with sufficient detail to allow us to understand and respond to your request. Our response will explain any reasons we cannot comply with a request, if applicable.

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

Personal information and children

Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

How we use your information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our website
• Improve, personalize, and expand our website
• Understand and analyze how you use our website
• Develop new products, services, features, and functionality
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
• Send you emails
• Find and prevent fraud

Log Files

Adgat Reach follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like any other website, Adgat Reach uses 'cookies'. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

Google DoubleClick DART Cookie

Google is one of a third-party vendor on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.website.com and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – https://policies.google.com/technologies/ads

Our Advertising Partners

Some of advertisers on our site may use cookies and web beacons. Our advertising partners are listed below. Each of our advertising partners has their own Privacy Policy for their policies on user data. For easier access, we hyperlinked to their Privacy Policies below.

• Google - https://policies.google.com/technologies/ads

Advertising Partners Privacy Policies

You may consult this list to find the Privacy Policy for each of the advertising partners of Adgat Reach.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Adgat Reach, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that Adgat Reach has no access to or control over these cookies that are used by third-party advertisers.

Third Party Privacy Policies

Adgat Reach's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Adgat Reach does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.