Last updated: August 24, 2022

This privacy policy ("Policy") describes how https://www.adpal.com, AdPal iOS, and Android apps, Widgets, WordPress, and Shopify plugins (together or separately referred to as the "Services") which are provided by AdPal, Inc., and its related companies (referred to as “AdPal”, "us" or "we") described how and why we may collect, use, and share personal information of users of the Services. This page is used to inform visitors regarding our policies regarding the collection, use, and disclosure of Personal Information for anyone who decides to use our Services.

Questions or concerns regarding the Policy? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. Questions and concerns can be directed to privacypolicy@adpal.com.

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TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. LEGAL BASIS WE RELY ON TO PROCESS YOUR INFORMATION?
4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. COOKIES AND OTHER TRACKING TECHNOLOGIES.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. WE DO NOT COLLECT INFORMATION FROM MINORS
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. DO-NOT-TRACK CONTROL FEATURES
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW YOU CAN CONTACT US ABOUT THIS NOTICE?
16. HOW YOU CAN REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

We get information about you in a range of ways.

AdPal is compliant with the Google API Services User Data Policy and respects Limited Use requirements. For full policy details, visit: Google API Services User Data Policy

Personal Information You Disclose To Us.We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include the following:

·Names

·Phone Numbers

·Email Addresses

·Mailing Addresses

·Usernames

·Passwords

·Contact Preferences

·Contact or Authentication Data

·Billing Addresses

·Debit/Credit Card Information

Sensitive Information. We do not process sensitive information.

Payment Information Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by (

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

·Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider, and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

·Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

·Log and Usage Data.Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

·Device Data.We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

·User Website Management/Ownership.Users will be required to validate their website ownership using meta tags, DNS records, and/or file uploads.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

·To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

·To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.

·To respond to user inquiries/offer support to users.We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

·To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

·To fulfill and manage your subscriptions. We may process your information to fulfill and manage your subscriptions, and payments, made through the Services.

·To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

·To send you marketing and promotional communications.We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).

·To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including investigating, and deterring fraudulent, unauthorized, or illegal activity.

·To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

·To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

·To save or protect an individual's vital interest.We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

This section applies to you if you are located in the EU or UK.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

·Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.

·Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

·Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

oSend users information about special offers and discounts on our products and services

oAnalyze how our services are used so we can improve them to engage and retain users Support our marketing activities

oDiagnose problems and/or prevent fraudulent activities

oUnderstand how our users use our products and services so we can improve user experience

·Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

·Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

This section applies to you if you are located in Canada.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

·If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

·For investigations and fraud detection and prevention.

·For business transactions provided certain conditions are met.

·If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

·For identifying injured, ill, or deceased persons and communicating with next of kin.

·If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.

·If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

·If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

·If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

·If the collection is solely for journalistic, artistic, or literary purposes.

·If the information is publicly available and is specified by the regulations

4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share personal information in specific situations described in this section and/or with the following third parties:

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (hereinafter "third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:

·Invoice and Billing - Apple Pay, Google Pay, PayPal, Shopify, Stripe

·Social Media Sharing and Advertising – Discord, Facebook advertising, Meta for Business, Telegram, Twitter,

·User Account Registration and Authentication – Apple, Facebook Login, and Google Sign-In

·Web and Mobile Analytics – Google Analytics and Meta Pixel

·Website Hosting – Amazon Web Services (AWS)

We also may need to share your personal information in the following situations:

·Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act and thus will not distribute your personal information to outside parties without your consent or as specifically described above.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook login). When you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA) or the United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than two (2) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. WE DO NOT COLLECT INFORMATION FROM MINORS

We do not knowingly solicit data from or market to children, or anyone under 18 years of age. By using the Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from anyone under the age of 18, please contact us at datacollection@adpal.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW YOU CAN CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW YOU CAN CONTACT US ABOUT THIS NOTICE?" below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW YOU CAN CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

·Log in to your account settings and update your user account.

·Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@adpal.com.

12. DO-NOT-TRACK CONTROL FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

·(1) every individual who is in the State of California for other than a temporary or transitory purpose and

·(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months: