REFLEX MEDIA GROUP PRIVACY POLICY

Update date: 1/10/2023

Thank you for visiting the website of the network of performance marketing partners Reflex Media Group (the “Site”) published by the company GET UP MEDIA SPAIN SL, data controller, whose registered office is Plaza de Europa, 17- 19, L’Hospitalet de Llobregat, 08908 Barcelona, Spain and registered under the number CIF B66744251 and VAT ESB66744251.

GET UP MEDIA SPAIN SL has appointed the law firm CLERY DEVERNAY as its Personal Data Protection Officer (DPO), who will be your contact for any questions relating to the processing of your Personal Data (Data) and can be contacted at the e-mail address: “[email protected]”

Reflex Media Group (“we”, “our”) is committed to protecting the privacy of your personally identifiable information.

This Privacy Policy is intended to provide you with information on how GET UP MEDIA SPAIN SL uses and protects, as data controller, your personal data collected through its Site.

Get Up Media Spain SL strives to provide you with a high level of protection for your Data, in compliance with Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights and Regulation (EU ) 2016/679 of the European Parliament and of the Council of 27 April 2016 relating to the protection of natural persons and with regard to the processing of personal data and the free movement of such data.

You must agree to this Privacy Policy in its entirety to: register an account (“Account”) with the Reflex Media Group performance marketing partner network (“Performance Marketing Partner Network”) and log in to your Account as a member of the Performance Marketing Partner Network. If you do not agree to this Privacy Policy in its entirety, you are not authorized to create a Performance Marketing Partner Network Account.

For more information regarding this Privacy Policy, you can contact us at: [email protected]

Personal data collected:

Personal identifying information:

We collect personally identifiable information when you register for an Account or when you choose to provide us with personally identifiable information.

Personally identifiable information is any information that can be used to identify or locate a particular person or entity.

This may include, but is not limited to, the Business Entity name and/or your title within the relevant Business Entity, as well as your personal and/or Business Entity-related email address. , your mailing address, daytime and/or mobile phone numbers, fax number, account information (or other information we need to pay amounts owed to you in the as part of the Performance Marketing Partner Network), your IP address and/or any other information requested on the applicable subscriber registration form. 2

Non-personally identifiable information:

We may collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or register for a Performance Marketing Partner Network Account, such as the type of browser you use (for example , Chrome, Internet Explorer), the type of operating system you are using (for example, Windows or Mac OS), and the domain name of your Internet Service Provider (ISP). We use the non-personally identifiable information we collect to improve the design and content of the site and to allow us to personalize your Internet experience. We may also use this information in the aggregate to analyze site usage.

Purposes of the Data used:

We use your personally identifiable information:

a) to send you information regarding your account and your contractual relationship with us

b) to respond to your application when you apply on our website;

c) to verify your compliance with the Terms and Conditions (“Terms and Conditions”);

and or

d) for purposes of validation, removal or improvement of content

Additionally, we may use your IP address for the purposes identified above, as well as to analyze trends, administer the site, track users’ movements, gather broad demographic information for aggregate use, and to confirm that a particular individual has asserted consent to specific legal terms (eg, a clickwrap license agreement). You agree that we, or our technical service provider, may contact you at any time regarding your account and/or any other information we deem appropriate to communicate to you in connection with your account. You can update your contact preferences as shown below.

Legal basis for collection:

Where we act as a data controller under European data law, our legal basis for collecting and using the information described in this Privacy Notice will depend on the information concerned and the specific context in which we collect or use such information. information.

We collect and use information about you:

where we have obtained your consent to do so,

where we need the information to perform a contract with you,

where the processing is in our legitimate interests and does not override your data protection interests or fundamental rights and freedoms.

More specifically, we use your Personal Data to:

o create or manage an account/application, we need it to provide the relevant services;

o for marketing purposes, in this case with your consent (which you can revoke at any time);

o collect usage data and analyze it to improve the site, based on our legitimate interest in safeguarding and improving the site. 3

If you have any questions about how information is processed, including questions about how to exercise your rights as a data subject, please contact us using the contact details provided in this privacy notice.

Data retention period:

Subject to any data deletion obligations, your information may be retained by us, our server logs, databases and records.

We will retain your information for no longer than is necessary for the purposes for which it is processed.

Where technical limitations prevent deletion or anonymization, we will safeguard and limit use of the information as required by applicable law.

Information Sharing:

Your Data is processed by GET UP MEDIA SPAIN SL for the purposes referred to above and is accessible :

– to staff members of GET UP MEDIA SPAIN SL and the GET UP MEDIA group, who need to know about it in the performance of their duties, and according to a strict authorization policy;

– to our technical service providers to meet your needs.

We may, in fact, from time to time, provide your Data to our IT, technical or accounting service providers, in their capacity as subcontractor, for the purposes of efficiency in the provision of our services or management in connection with your account. All of these service providers have agreed to protect the confidentiality of the information that we transmit to them.

In addition, we reserve the right to share your personally identifiable information:

(a) when required by law or when required by a court of competent jurisdiction;

(b) in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of our business, assets or stock;

(c) when you are in breach of this Privacy Policy, the Terms and Conditions and/or the Services Agreement;

(d) in the event of a dispute; Or

(e) when we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The above includes exchanging information with other companies and organizations for fraud protection.

International Data Transfer:

We may transfer the information we collect about you, including Personal Information, to affiliated entities or our service providers beyond the European Union and your country or jurisdiction, to other countries or jurisdictions around the world . 4

Please note that you authorize the transfer of this information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

For transfers outside the European Union, we can provide you with a sufficient and appropriate level of protection for your data with regard to the regulations in force.

Indeed, we have either chosen service providers in countries in line with European regulations, or asked our service providers for appropriate guarantees by means of contractual clauses, agreements relating to data protection and/or internal rules.

Security:

We strive to safeguard and protect the information of our account holders.

When account holders submit personally identifiable information to us, that information is protected both online and offline. When our registration process asks registrants to submit information such as bank account and/or credit card information (“Sensitive Information”), and when we transmit such Sensitive Information, it is encrypted and protected. . The online payment provider’s servers that we use to store personally identifiable information are kept in a secure physical environment. This provider has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.

We will notify you, in the event that we learn of an information security breach involving your personally identifiable information. You will be notified by email in the event of such a violation. Please note that notification may be delayed in order to meet the needs of law enforcement, determine the extent of damage to the network, and take corrective action.

Rights of the data subject

When we process your personal data, you have a series of rights set out below.

You can exercise the rights of access, rectification, erasure, opposition, limitation of processing, as well as the portability of your data, at any time and completely free of charge.

You can revoke your consent to the processing of your Data at any time when the legal basis is your consent.

To exercise your rights, simply send an email to [email protected] and specify the indications on the right you wish to exercise.

GET UP MEDIA SPAIN SL will respond to you as soon as possible and in any event within one month of receipt of your request. This period may be extended by two months to take into account the complexity of the request or the number of requests received.

In the event of a request for the deletion of Data, the Data may be archived by GET UP MEDIA SPAIN SL only to meet its legal obligations and only for the period of said legal obligation.

You have the right to lodge a complaint with a supervisory authority at any time of a possible difficulty. 5

The lead supervisory authority to which the GET UP MEDIA group is subject is the Spanish Agency for Data Protection (AEPD).

Spanish Protection Agency of Datos

C/ Jorge Juan, 6

28001-Madrid

91 266 35 17

https://www.aepd.es

Deleting and updating your information:

If you wish to delete or update the personally identifiable information, we have collected from you, simply email us.

We will process your request, to the extent possible and subject to the terms and conditions contained herein, within a reasonable time of receipt. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

Opt-out of receiving e-mails: You can opt out of receiving e-mails containing general information about us and our group at any time by following the instructions at the end of each such e-mail or by contacting us. There may be a short delay of up to several business days while your request is verified, deployed and processed on our servers.

Notification of changes:

We reserve the right to modify or update this Privacy Policy at any time by posting a clear and prominent notice on the Site explaining that we are changing our Privacy Policy. All changes to the Privacy Policy will take effect immediately upon posting to the Site.

Please check the site regularly for any changes. By continuing to use the Site and/or accepting our email communications following the posting of changes to this Privacy Policy, you agree to all changes.

Cookies, Web Beacons and Advertising Identifiers

To improve your experience on the Site, we use “cookies”.

Cookies are small data packets stored on your computer and used to save your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. You can configure your browser to warn you about the use of cookies or to block the use of cookies.

We use strictly necessary cookies to allow you to move around the site and log in to your account, and functional cookies to improve the services and support offered to you. You can control the use of these cookies by means of the Cookies banner on our site.

Cookies can be managed for us and by third parties; in this case, we do not allow the third party to use cookies for any purpose other than that necessary to provide the services.

We may also collect information using web beacons, commonly known in the industry as “web bugs”, “pixel tags” or “Clear GIFs”. Web beacons are electronic images that can be used on the Site, in your account, or in our emails to deliver cookies, count visits, and determine whether an email has been opened and acted upon. 6

End users can also opt out of the collection of advertising identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Advertising ID using their smartphone’s privacy settings.

Contact us:

If you have any questions about this Privacy Policy or would like more information about our privacy practices, please contact us.