PRIVACY POLICY

Last updated: May 24, 2018

Introduction

This document explains the privacy practices and personal data protection standards implemented by Content Insights, Inc. and its subsidiary Content Insights EAD (jointly hereinafter: the Company).

Here we describe how the Company uses, collects, stores and protects your information when you use our services and/or our clients' products and services. We hereby state the Company is fully compliant with all relevant European Union (hereinafter: EU) applicable legislation pertaining to protection of personal data, especially General Data Protection Regulation (hereinafter: GDPR). All terms in this Statement shall be interpreted as in the GDPR.

Which data do we process?

The Company collects and processes the following two types of personal data:

• Personal data that the Company collects for its own purposes relating to the provision of its services or relating to its governance (such as employees' and clients' personal data), where the Company has the position of the data controller. Personal data collected in the context of the Company's relationship with its clients are processed solely for the purpose of the optimal fulfilment of the contracts entered into with the clients and enhancing the clients' experience.
• Personal data of the clients' website visitors that are processed as part of the Company's services, i.e. web analytics operations, where the Company has the position of the data processor. Processing of such online identifiers (e.g. IP addresses, cookie identifiers) is limited to what is strictly necessary for purposes of conducting Company's web analytics services. Clients' website visitors data are anonymized upon collection so that visitors are no longer identifiable. However, raw personal data of clients' websites visitors are stored for the purpose of possible re-processing for a period of maximum 7 days. The raw data can be used solely and exclusively for the re-processing purposes in cases when the Company experiences certain technical or other problems. Clients' website visitors data will not under any circumstances be used for profiling and/or automated processing of personal data.

Which data do we process?

As a client of the Company you have the right to submit the following requests in regards to your personal data:

• Confirmation as to whether the Company is processing any of your personal data;
• Access your personal data;
• Correct your personal data in case or errors;
• Delete your personal data;
• Restrict and/or object to the processing of your personal data.

It should be noted that the above only refers to clients and NOT clients' website visitors, since there is no way of identifying them and answering their requests

Personal data transfers

Clients' data are stored in the EU and United States of America (in accordance with the EU-US Privacy Shield). There is a possibility of clients' data being transferred to another country but in that case, they will be additionally notified in accordance with requirements of GDPR.

Clients' website visitors' data (raw data) are stored on Amazon Web Services, in accordance with the EU-US Privacy Shield.

We don't sell, share or lend any personal data!

This is the case with both clients' data and clients' website visitors data.

Privacy Of Application Users

This section covers your rights as a user of any application developed by Content Insights.

We may contact you:

• for administration reasons related to the Services (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us);
• to provide you with information about our Services, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us, e.g. on our website, by email;
• to invite you to participate in surveys about our services (participation is always voluntary). Where we wish to use Your Data in any other way, we will ensure that we notify you and get your consent first.

What Rights Do You Have

As a user, you have the rights to withdraw your consent, to inquire about Personal Data that we have on you and to request deletion of Personal Data at any given moment. We will reply to those requests in 5 business days and delete requested data in period no longer than 15 business days. You can exercise your rights by sending us an email to dataprivacy@contentinsights.com.

Who can I contact to exercise my personal data rights as a client of Content Insights?

The Company's Personal Data Contact Person is Darko Đorđević. This person can be contacted for all information regarding the Company's use of your personal data at: dataprivacy@contentinsights.com.

Effectiveness and changes to this Statement

This Statement is in effect upon publication on the Company website. All changes made to this Statement will be published on the Company website with prompt notification during the next visit of the website. All previous versions of this Statement will be available on the Company website in the future.