Catuik Privacy Policy. Introduction

Catuik respects your privacy and is committed to protecting your personal data. This Privacy Policy provides you information on how Catuik(hereinafter “we/us/our”) looks after your personal data when you visit our website, www.catuik.com and other services, if we collect data from you as an advertiser or a publisher or any other applicable category of data subject, and/or if you are a user of our advertisers’ or publishers’ websites and platforms.

1. Data Controller

The data controller is Catuik, as described in your contractual relationship with Admitad and Catuik..

Should you have any questions about our data protection measures, the processing of your data, or the protection of your rights as a data subject, you can contact us at: data-support@admitad.com

2. Definitions

2.1 Personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.2 Processing

“Processing” means any operation or set of operations performed on data such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of said data.

3. Collecting and processing personal data

The scope of how we collect and process your personal data depends on the way you interact with us or our technologies and services. In the course of providing our business services we may collect, use, store and transfer different kinds of personal data about the following categories of the Data Subjects (Please consult clause 12 Glossary):

· website visitors and users of www.catuik.com

· our newsletter subscribers

· our counterparties and their representatives and users, including, but not limited to Catuik publishers and advertisers and their users

(Together Data Subjects)

We have grouped the personal data that we may process about you and your Data Subjects together as follows:

· Identity Data may include the first name, last name, email address, username or similar identifier.

· Contact Data may include billing address, business or residence address, email address and telephone numbers.

· Financial Data may include the bank account and payment details.

· Technical Data includes the internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, domain names, access dates and times, referring website addresses, online transactions, browsing and search activity, details of products and services that have been purchased from us or via our services and other technology on the personal devices.

· Profile Data includes the username and password.

· Marketing and Communications Data includes the preferences in receiving marketing communications from us and your communication preferences.

We do not knowingly collect any Special Categories of Personal Data about you or your subscribers (this includes details about your or your subscribers’ race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the contractual relationship we have with you, and you fail to provide that data when requested, we may not be able to perform the contractual relationship we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

Cookies

We and our subsidiaries and affiliates use cookies, web beacons, tracking pixels, clear gifs and other similar tracking technologies (collectively "Cookies") to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Function cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Measurement cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Preferences cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Marketing cookies. These cookies record your visit the website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, called pixel tags (or web beacons or clear gifs). Tracking pixels are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs”, that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

Cookies used on our website are categorized on our Consent Management Platform displayed when you first visit our website and you can read about each category and allow or deny some or all of them, except for Necessary Cookies which are required to provide core website functionality. When categories that have been previously allowed are disabled, all cookies assigned to that category will be removed from your browser.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Social plugins and third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Catuik website uses the following social media plug-ins:

Facebook (Meta), see https://www.facebook.com/policy.php

LinkedIn, see https://www.linkedin.com/legal/privacy-policy

TikTok, see https://www.tiktok.com/legal/privacy-policy?lang=en

Instagra

Analytic tools

We use Google Analytics and Microsoft Clarity tools on our website for the purposes of the adequate design and continuous optimization of our website, as well as reporting on website usage.

Newsletters

We may send out newsletters, emails, and other electronic notifications with promotional information (hereinafter “Newsletter”) from us subject to the data subject’s consent and where data subject have not opted out of receiving those marketing communications.

3.1. Personal data we may collect if you are our website visitor for visitor of Catuik website

If you visit Catuik website, we will collect the following categories of personal data:

· Technical data

· Cookie data when you consented us to do so

3.2. Personal data we may collect if you’re a publisher or advertiser

Registering and participating in our network

To obtain access to our technologies and services, you must register in our network. After that, in addition to the data described in the policy for visitors, we may collect and process the following categories of personal data about you:

· Identity Data

· Contact data

· Financial data

· Technical data

· Profile data

· Marketing and Communications Data

Cookies

In addition to the cookies specified in section 3, we use strictly necessary cookies on publishers’ and advertisers’ account pages for the website to function properly.

Analytics tools

We use Google Analytics and tools on our website for the purposes of the adequate design and continuous optimization of our website, as well as reporting on website usage.

Information on first-party and third-party cookies

As a publisher or advertiser, you must inform users of your website about first-party and third-party cookies, including those placed by Catuik, i.e., the names and purposes of the cookies, as well as how users may prevent cookies from being placed on their device. Users must consent to the use of both first-party and third-party cookies on your website before a cookie is placed.

3.3 Use of Tracking URLs for publisher

What are tracking URLs?

A tracking URL is a special web address that we use to monitor user activity within our affiliate programs. This tool assists both us and our partners in understanding how specific traffic sources, activities, or user actions are associated with user registrations, purchases, and other target actions.

Purpose of tracking

Tracking URLs are fundamental to the services we provide on our platform to our partners as part of our contract with third parties (Advertisers and Publishers) in accordance with Article 6(1)(b) of the GDPR. These URLs are optimized to analyze user click behavior and supply our partners with valuable feedback on their advertising strategies.

Data we collect

When a user interacts with a tracking URL, we may collect the following information:

click_id: A distinct online identifier generated when a user clicks a link.

referrer_url: It identifies the web page from which the resource was requested.

The country where the click was made.

The date and time of the user’s visit to the URL.

Information about the user’s device and browser.

Other parameters related to specific affiliate programs.

We also collect the following data components: website_id, website_name, banner_id, publisher_id, publisher_name, channel_id, group_id, uid (synonymous with click_id), referrer_url, country_code, and timestamp (a component that converts the time of the click into a UNIX timestamp).

For our publishers’ users (users who follow a publisher’s affiliate link):

User privacy is our priority. We do not collect the personal data of users who click on a publisher’s affiliate link (such as names or email addresses) using tracking URLs. We only aggregate anonymized data about these users.

For publishers:

We do not collect the personal data of publishers (publisher_name, email addresses) using tracking URLs unless explicitly stated in the context of a specific affiliate program.

Third parties

We collaborate with various partners and advertisers. Some of them may use our tracking URLs to evaluate the effectiveness of their affiliate programs.

3.4. Stripe for advertiser

We use Stripe, a payment processing software, for billing advertisers. Stripe may store your bank account and/or credit card details (referred to as “Payment Information”). We connect with those third parties to bill you for payments associated with using the Service. We do not store or process payment information, such as your credit or debit card number, or your bank account number.

For more information, see Stripe Privacy Policy: https://stripe.com/privacy

3.5 Data we may collect about publisher and advertiser users

Use of Tracking URLs

What are tracking URLs?

Purpose of tracking

Tracking URLs are fundamental to the services we provide on our platform to our partners as part of our contract with third parties (Advertisers and Publishers). These URLs are optimized to analyze user click behavior and supply our partners with valuable feedback on their advertising strategies.

Data we collect

When a user interacts with a tracking URL, we may collect the following information:

· click_id: A distinct online identifier generated when a user clicks a link.

· referrer_url: It identifies the web page from which the resource was requested.

· The country where the click was made.

· The date and time of the user’s visit to the URL.

· Information about the user’s device and browser.

· Other parameters related to specific affiliate programs.

For our publishers’ users (users who follow a publisher’s affiliate link):

For publishers:

We do not collect the personal data of publishers (publisher_name, email addresses) using tracking URLs unless explicitly stated in the context of a specific affiliate program.

Third parties

We collaborate with various partners and advertisers. Some of them may use our tracking URLs to evaluate the effectiveness of their affiliate programs.

Cookies

We store cookies on the devices of users who visit the websites/platforms and use the online services of our Publishers and Advertisers.

These cookies store information about:

· When and on what device a click on an advertisement occurred

· The Advertiser’s affiliate program

· The Publisher

· The specific time of the user’s action.

While tracking via the cookie, we may also collect information on the device used to perform a conversion, such as its operating system and browser.

The purpose of this data processing is to track conversions (leads and sales such as installing an application or placing an order in an online shop) and to allocate them to proper Publishers. Doing so is necessary as part of our contract with third parties (our Advertisers and Publishers) that use our services.

Behavioral targeting

Catuik does not conduct behavioral advertising and does not collect data for these purposes. However, our Publishers may use cookies for behavioral advertising purposes.

For this reason, we would like to draw your attention to your ability to object to the collection of data for purposes of targeted advertising on the following websites http://www.aboutads.info/choices/ and https://www.youronlinechoices.com/

Online identifiers

The Publishers are obliged to send data regarding online identifiers after receiving in advance your consent to send such data to Catuik. Catuik processes your data based on the agreement with the Publisher and at the instruction of the Publisher, who transfers this data with your consent.

4. Legal Basis

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal obligation.

· Based on your consent where you have given such consent.

Please consult clause 12 to find out more about the types of lawful basis that we will rely on to process your personal data.

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Data is stored in a safe environment that is not open to public access.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your personal data may be encrypted before transmission in certain cases (e.g., processing your login data). This means that communication between your device and our servers will include recognized encryption measures if your browser supports doing so.Your personal data may be encrypted before transmission in certain cases (e.g., processing your login data). This means that communication between your device and our servers will include recognized encryption measures if your browser supports doing so.

Our staff has been trained in privacy matters and responsibly handling personal data and information to which they gain access.

6. Disclosures of personal data

We may share your personal data with the parties set out below for the purposes set out in clause 4 above.

· Internal Third Parties as set out in clause 12 (Glossary).

· External Third Parties as set out in clause 12 (Glossary).

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. If we are acquired by or merged with a third party, we reserve the right, in either of these circumstances, to transfer or assign the information we have collected from you as part of such a merger, acquisition, sale, or other change of control.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We may share your personal data within the Group. We only transfer personal data to third countries where we can ensure the careful handling of personal data by employing contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. User Rights

You have the following rights concerning our processing of your personal data:

· The right to access

· The right to rectification

· The right to erasure

· The right to restrict processing

· The right to data portability

· The right to object (on grounds related to your particular situation) if your personal data is processed based on our legitimate interest

· The right to withdraw your consent at any time in the event of any consent-based processing of your personal data without affecting the lawfulness of processing said data based on consent before your withdrawal

· The right to lodge a complaint with a supervisory authority.

You may exercise your legal rights by contacting us via email at data-support@admitad.com.

If you are registered as a publisher or an advertiser on our website, you may access your account and correct or delete some of your data by yourself.

While observing applicable privacy legislation, we will erase your data without any action required by you if retention of your data is no longer necessary for the purpose pursued or retention is no longer allowed for any legal reason. We may restrict processing instead of erasing your data where it is legally not allowed to erase (e.g., legal obligations to maintain your personal data).

10. Amendments

We may modify this Privacy Policy and our data security provisions at any time, particularly if new laws and/or regulations need to be adopted or if we regard amendments as reasonable.

11. Questions/Contacts

For all questions and requests related to the security of your personal data, please contact us at data-support@admitad.com.

12. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies affiliated with us acting as joint controllers or processors (the Group).

External Third Parties

· Service providers acting as processors, for example, our hosting services providers, email sending services (For example Mindbox), order providers

· Tax regulators and other authorities who require reporting of processing activities in certain circumstances.

· Payment processors