Privacy policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE ANDATA INC.'S WEBSITE, MOBILE APPLICATIONS, AND/OR SERVICES. BY ACCESSING AND USING THE ANDATA WEBSITE, MOBILE APPLICATIONS, AND/OR SERVICES, YOU WILL BE DEEMED TO HAVE WHOLLY ACCEPTED ANDATA INC.'S PRIVACY POLICY.

Last Updated February 9, 2023

Your use of the Andata Inc. ("Andata"), if and as applicable, Website, Mobile Applications, and Services, including any dispute concerning Your online privacy therewith, is subject to Andata's Privacy Policy ("Privacy Policy") and Andata's Terms of Service ("Terms of Service"). By using the Andata Website, Mobile Applications, and/or Services, You ACCEPT the practices set forth in this Privacy Policy and the Terms of Service. For this reason, please frequently refer to this Privacy Policy to ensure Your continued ACCEPTANCE of all Andata practices relating to Your personal and user information. Your continued use of any portion of the Website, Mobile Applications, and/or Services following the posting of an updated Privacy Policy will constitute Your full ACCEPTANCE of any changes.

Andata has created this privacy statement in order to fully disclose its information gathering and dissemination practices for the Andata Website, including the Platform as that term is defined in the Andata Terms of Service ("Website"), any mobile applications or any type of software that is designed to run on the mobile device ("Mobile Applications"), and the Services offered and provided through the Website ("Services").

Changes in Privacy Policy

Andata reserves the right to modify this Privacy Policy at any time and will notify You as to any changes via the Website, Mobile Applications, by email, or as outlined in the Terms of Service. Andata wants You to always be aware of what personal and other information it collects, how Andata uses that information, and under what circumstances Andata may disclose such information. All personal information that Andata collects will be handled in accordance with the Privacy Policy in effect at the time the information is collected. If the Privacy Policy changes in any significant respect in the meantime, Andata will not (without Your permission) use Your personal data in a manner that is inconsistent with the Privacy Policy in effect at the time Your information was collected.

Upon reading this Privacy Policy, You will be informed of the following:

(1) Description of the types of personally identifiable information (Yours and that of third parties) collected through the Website, Mobile Applications, and Services;

(2) How collected personally identifiable information is used;

(3) With whom the collected personally identifiable information may be shared;

(4) The choices available to You regarding the collection, use, and distribution of such information;

(5) Security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under Andata's control; and

(6) Instructions on how You can access and correct any inaccuracies in the information collected about You.

A note about the Website, Mobile Applications, and Services: Some of Andata's Services, data centers, service providers, affiliates or operating partners and servers may be located in other countries. As such, the Website, Mobile Applications, and Services may be subject to the laws of numerous countries and jurisdictions, some of which may require Andata to disclose certain information about its users. Andata is committed to keeping Your information private while using its best efforts to comply with all applicable laws in the jurisdiction(s) in which it operates.

Should You have any concerns or believe that there are problems or issues relating to compliance with the policies outlined in this Privacy Policy, please notify by email at legal@andata.io, as also outlined in Section G, below.

Andata has a strong commitment to providing superior service to all of its customers, users, and visitors, particularly with respect to their concerns about privacy. Andata understands that You may have questions about how the Website, Mobile Applications, and Services collect and use Your information. Accordingly, Andata prepared this statement to best inform You of the privacy principles that govern the Website, Mobile Applications, and Services. Andata will not sell or rent Your personally identifiable information or a list of its customers and/or users to third parties. However, as described in more detail below, there are limited circumstances in which some of Your information may be shared with third parties, under strict restrictions, so it is important for You to carefully review this Privacy Policy.

This Privacy Policy contains numerous general and technical details about the steps Andata takes to respect Your privacy. Andata has organized this Privacy Policy by major processes and areas so that You can quickly find the information of most interest to You. The bottom line is that meeting Your needs and expectations forms the foundation of everything Andata does, including the protection of Your privacy.

The Website does not collect personally identifiable information from Your computer when You browse the Website and request pages from Andata servers. Similarly, Mobile Applications do not collect personally identifiable information when You use the Mobile Applications and request pages from Andata servers. This means that, unless You voluntarily and knowingly provide Andata with personally identifiable information, Andata will not know Your name, email address, or any other personally identifiable information.

When You request a page from the Andata Website or Mobile Applications, Andata's servers log the information provided in the HTTP request header, JavaScript or similar technical tools, including the IP address, the time of the request, the URL of the request, and other technical information. Andata collects this information in order to make its Website and Mobile Applications function correctly and to provide You the functionality that You see on such platforms, as Andata's servers use this information to deliver the internet pages You request. Andata also uses this information to better understand how visitors use the Website and Mobile Applications and how Andata can better tune its Website, Mobile Applications, contents, and functionality to best meet Your needs. However, this information is not associated with any personally identifiable information of persons browsing the Website.

When You use the Website or the Mobile Applications, Andata, or trusted authorized third parties, may also collect certain technical and routing information about Your computer or device (also known as environmental variables) to facilitate Your use of the Website, Mobile Applications, and the Services enabled thereby. When You browse the Internet, Your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to Andata every time You access content on one of Andata's internet domains. Examples of such information include without limitation the URL of the particular web page You visited, the IP address of the computer You are using, or the browser version that You are using to access the Website. All of this information may be collected by Andata and used to help improve its offerings to You.

User Account holders may be permitted to upload certain content onto the Website, Mobile Applications, and Services ("User Content"). This information shall be private and, except in accordance with this Privacy Policy, will not be disclosed to third parties without Your prior permission.

You never have to provide personally identifiable information to Andata. However, should You choose to withhold certain required information, Andata may not be able to provide You with some or all of the Services. Some of the information Andata asks You to provide may be identified as mandatory or optional. If You do not provide the mandatory information with respect to a particular activity, You may not be able to engage in that activity or make such a purchase. Andata will inform You of the mandatory or optional nature of the requested or required information.

Andata is the sole owner of the information it gathers on the Website, Mobile Applications, and Services. Andata will only share Your information with outside parties in ways that are described in this Privacy Policy, if required to do so by law, or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, to cooperate with law enforcement agencies, to comply with a legal process served on Andata, or to otherwise comply with any current or future laws and regulations applicable to Andata.

You may be provided an opportunity on the Website and/or Mobile Applications to allow Andata to contact You from time to time regarding Andata news and product or Services updates. In order to do so, You may be required to provide certain personally identifiable information to Andata. Andata will treat this information in accordance with the policies set forth in this Privacy Policy.

When You submit personal information to Andata through the Website or Mobile Applications, You understand and AGREE that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which Andata and its affiliates and subsidiaries maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of Your information may be undertaken by trusted vendors of Andata. Andata may use vendors to aid in the facilitation of technical support services that may potentially receive limited access to Your personal information.

Andata may establish relationships with various third-party service providers whose services may become available to You from the Website, Mobile Applications, or otherwise. Typically, these providers would offer services that Andata users might find useful, such as those that can be used in conjunction with the Website, Mobile Applications, or Services. In order to use these third-party providers, You may be required to provide personal information to such services providers. Unless expressly provided to the contrary, personal information that You provide to such providers, whether visiting a provider's website or otherwise, will be subject to the privacy policy of such providers; however, personal information that You provide while on the Andata Website or Mobile Applications, in conjunction with a provider's service will be subject to Andata's Privacy Policy. For instance, credit card information entered in populating a purchase form or registration process is collected by the third-party registration services and subject to their respective privacy policies. You should be aware that Andata's agreements with these service providers often provide that they will share with Andata, personal information collected from You. In such instances, Andata may use this information in a manner consistent with this Privacy Policy.

PayPal, Stripe, and any other third-party payment service providers designated by Andata are responsible for payment information You provide through the Website, which will be subject to their respective privacy policies.

When registering for a User Account or otherwise contacting Andata in connection with Your interest in utilizing Andata Services, Andata may ask You to provide certain information. Such information may include Your name, email, address, phone number, and other personally identifiable information. It is completely optional and voluntary for You to register for a User Account, engage in activities requiring a User Account, or to provide any personal identifiable information. However, certain information and proper identification may be required in order for You to engage in certain services provided by Andata.

Once You create a User Account, You will be deemed a Registered User. You may also request to change information associated with Your User Account by taking the indicated actions in the Platform.

If You elect to use a third-party application, such as Facebook, Twitter, or Google, to register for a User Account in connection with the Website and/or Mobile Applications, Andata may receive Your personal information from the third-party application. Information received will consist of the public profile information You have provided to these third-party applications. This may include photographs, email addresses, phone numbers, mailing address(es), passwords, and user IDs. If You elect to use any third-party application in connection with the Websites, You should review its respective privacy policy in relation to any information transferred to Andata. If You wish to deactivate your User Account, You may send an email to legal@andata.io. When You deactivate Your personal account, all information stored and maintained as part of Your User Account may be retained for archival, backup, and record purposes in accordance with this Privacy Policy.

The Website and Mobile Applications may contain links to websites owned and operated by third parties. These links are presented for Your convenience and information. Andata does not control these third-party websites and is not responsible for their privacy practices or content. Andata does not control the information collection and distribution policies on such websites other than those that are under the control of Andata itself. Content on third-party websites may not reflect products, services, and/or information provided by Andata. Third parties may also set their own cookies and/or use web beacons, which may be used to identify some of Your preferences or to recognize You if You have previously had contact with these third parties. Andata does not control the use of such technology by third parties, the information they collect, or how they use such information. You should direct all concerns regarding any third-party website directly or to the site administrator or webmaster.

Andata may make third party applications available to You through the Website, Mobile Applications, or Services. The information collected by Andata when You enable a third-party application is processed under this Privacy Policy. Information collected by the third-party application provider is governed by the provider's privacy policy(ies).

The Children's Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit www.ftc.gov. The Andata Website, Mobile Applications, and any Content, or Services available thereon are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, Andata recognizes that children under the age of 13 may potentially access the Website, Mobile Applications, and Services. Parents and Legal Guardians may request Andata to review, delete or stop the collection of any personally identifiable information of their child(ren). You may do so by contacting Andata by email at legal@andata.io.

The Website and Mobile Applications use "cookie" and "web beacon" technology. "Cookies" are short pieces of data generated by a web server that a website stores on a user's computer and/or user's mobile device. Certain pages on Andata's Website may require the use of a cookie for purposes of keeping information You enter on multiple pages together. Cookies also enable Andata to customize the Website, Mobile Applications, and offerings to Your needs and provide You with a better online experience with Andata. In addition, cookies are used to:

• Measure usage of various pages on Andata's Website to help make Andata's information more pertinent to Your needs and easier for You to access;
• Identify and categorize the internet webpages from which a visitor came to the Website and in order to observe browsing patterns; and
• Provide functionality such as online orders, Andata Services, and other functionalities that Andata believes would be of interest and value to You.

The types of cookies that Andata uses are referred to as "session" cookies and "persistent" cookies. Session cookies are temporary and are automatically deleted once You leave the Website. Persistent cookies remain on Your computer hard drive until You delete them. Andata does not use cookies to gather information concerning Your visits to other websites, nor ascertain any personally identifiable information about You apart from what You voluntarily provide in your dealings with Andata. Cookies do not, under ordinary circumstances, corrupt or damage Your computer, programs, or computer files.

In addition, the service providers Andata uses to serve and host its advertisements may use session or persistent cookies to track the number of times the Website is accessed and whether the Website was accessed via an advertisement. There are no automatically-placed cookies within these advertisements, a cookie is placed on Your computer only if and when You click on an advertisement. The cookie generated from the advertisement does not contain any personally identifiable information and will remain on Your hard drive until You delete it. Furthermore, Andata may use email tracking services in order to receive read receipts and related information when sending emails, however, these services are used by Andata for these reasons and not to collect any personal information about You.

You may set your browser to block cookies (consult the instructions for Your particular browser on how to do this), although doing so may adversely affect Your ability to perform certain transactions, use certain functionality, and access certain content on Andata's Website.

Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1-pixel x 1-pixel) that is placed on a website. As opposed to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of web beacons allows a website to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited on a website. Andata uses the information provided by web beacons to develop a better understanding of how the Website's visitors use the Website, and to facilitate those visitors' interactions with the Website. Andata may make the aggregate data obtained from web analytics (including from its third-party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.

Andata collects information from You in order to record and support Your participation in the activities provided by Andata. Andata may use Your email address to send a confirmation email when You sign up for a User Account and, if necessary, may use other information You provide to contact You for help to process or provide a purchase or Service You have selected. Your personal information also may be used to keep You informed about new services, service upgrades, special offers, and other Services.

As described above, Andata may collect information about Your use of the Website, Mobile Applications, and Services. This information is collected in aggregate form and usually sent in JavaScript snippets, without explicitly identifying any particular user. Andata may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

Andata recognizes and appreciates the importance of responsible use of information collected on the Website. Without Your CONSENT, Andata will not communicate any information to You regarding the Website, Mobile Applications, Services, or special offers available from Andata or its affiliates, although Andata may find it necessary to communicate with You regarding Your use of the Website, Mobile Applications, or Services in certain limited circumstances. Except in the particular circumstances described in this Privacy Policy, Andata will not provide Your name to other companies or organizations without Your CONSENT.

Although Andata will always strive to guard Your identity, Andata may disclose Your personally identifiable information without Your permission in limited circumstances. Andata will only do so if it has a good-faith belief that disclosure is reasonably necessary to (1) comply with laws, regulations, or government requests or (2) to investigate or protect against harmful activities to its guests, visitors, associates, or property (including the Website, Mobile Applications, or Services), or to others. If Andata is required by law enforcement or judicial authorities to provide Your personally identifiable information, Andata will only do so upon receipt of appropriate documentation. Andata may also disclose Your information to investigate violation of and enforce its Terms of Service and this Privacy Policy. Please know that Andata does not take this responsibility lightly. Your privacy is of paramount importance to Andata.

Andata may use the services of third parties, email service providers, payment systems, SMS services, phone services, online chat services, and marketing companies that act as independent contractors on behalf of Andata. These parties are prohibited from using personally identifiable information for any purpose other than for the purpose Andata specifies. Andata does provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to Andata. Andata prohibits the sale or transfer of personal information to entities outside of the Andata's affiliates for their use without Your approval.

Andata operates secure data networks protected by industry-standard firewall and password protection systems. Andata security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by Andata users. Andata takes steps to ensure that Your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no data transmission over the Internet can be guaranteed secure. As a result, while Andata strives to protect Your personal information, it cannot guarantee the security of any information You transmit to Andata or from the Website, Mobile Applications, or Services. Your use of the Website, Mobile Applications, and Services is at Your own risk.

Andata treats the information You provide to Andata, including the information about your winnings and your withdrawals, as confidential information; which is, accordingly, subject to Andata's company security procedures and corporate policies regarding protection and use of confidential information. After personally identifiable information reaches Andata it is stored on a server with physical and electronic security features as customary in the industry, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access outside of Andata. Because laws applicable to personal information vary by country, Andata offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this Privacy Policy is processed and stored in the United States and possibly other jurisdictions and also in other countries where Andata and its service providers conduct business. All Andata employees are aware of Andata privacy and security policies and are required by Andata to abide by these policies. Your information is only accessible to those employees who need it in order to perform their jobs.

In the event that all or substantially all of Andata's stock and/or all or substantially all assets are transferred or sold to another entity, Andata may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, Your personally identifiable information will be used in a materially different manner, You will be given notice as to such changes and the opportunity to re-consent or object to such material changes.

You may always choose whether or not to disclose personally identifiable information and that choice will not prevent You from using the Website or Mobile Application, and having limited access to the Website, Mobile Applications, and Services. Please note, however, if You should choose to withhold certain requested information, Andata may not be able to provide You with some or all of the Services dependent upon the collection of this information. You will be given an opportunity to "opt-in" and select Your preference choices for any items that are optional and which are not prerequisite for Andata rendering of Services.

You can choose at any time to opt-out of receiving emails from Andata in your User Account or by contacting Andata directly at legal@andata.io. If You elect to opt-out, Andata will not, as applicable, send You emails or share Your personal information with third parties for such purpose. However, Andata may continue to use Your personal information for internal purposes, to enhance Your user experience or as necessary to administer the Website, Mobile Applications, or comply with applicable law.

Andata reserves the right to send registration notices, payment confirmation emails, service alert messages to users to inform them of specific changes that may impact their ability to use a service that they have previously signed up for, purchased, or used, regardless of email contact opt-in status, and any other communication relating to the Website, Mobile Applications, and/or Services. Andata also reserves the right to contact You if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty, or purchase agreements. Andata is retaining this right because in limited cases Andata feels that it may need to contact You as a matter of law or regarding matters that will be important to You. This does not allow Andata to contact You to market a new or existing service if You have asked Andata not to do so, and issuance of these types of communications are rare.

When You create a User Account with Andata and/or provide Your email address and other personal identification information, subject to Your personal preferences, unless You are a Qualified Individual, You CONSENT to allowing Andata to periodically contact You via email and provide information about special offers and promotions that may be of interest to You. These communications will relate to Andata offers and/or the promotions of select, reputable third parties with whom Andata has a strategic marketing relationship because they offer products or services that Andata believes would be of interest to You. Andata may use a third-party email service provider to send emails to You. This service provider is prohibited from using Your email address for any purpose other than to send Andata-related email. If You do not wish to receive emails with updates and information, please unsubscribe at legal@andata.io. In addition, every time You receive an email, You will be provided the choice to opt-out of future emails by following the "unsubscribe" (or similar) instructions provided in the email.

To ensure that Your request is honored, You must provide Andata with information sufficient for Andata to accurately identify and access Your records. The information Andata requires is Your full name, address and the email address You provided to Andata when You requested Services. This information or any other information per each individual case, requested is viewed as sufficient for Andata to ensure You are who You proclaim to be. Andata reserves the right to contact You to verify that it has accurately identified Your record.

The California Consumer Privacy Act or "CCPA" provides consumers residing in California certain rights with respect to their personal information. If You are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information Andata collects, uses, and discloses; (2) request deletion of Your personal information; (3) opt out of sale of Your personal information (if any); and (4) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting Andata as described in Section G below. Note that Andata may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that You gave that person authority to submit requests to exercise rights on your behalf. Andata will not discriminate against You if you exercise your rights under the CCPA.

In the past 12 months, Andata has collected the following categories of personal information, as described in the CCPA:

• Identifiers (such as email addresses);
• Demographic information (like ages);
• Commercial information (including entitlements or purchase history);
• Internet or electronic network activity (for example, gameplay or website usage details);
• Audio, electronic, visual, or similar information (like voice chat);
• Geolocation information (such as may be derived from your IP address or included in your billing information);
• Other "personal information" as defined under California law (like your credit or debit card information); and
• Inferences drawn from any of these categories (for example, about the genres of games you may prefer to play based on your purchase history).

(i) Right to Know

You may obtain confirmation of whether or not Your personal data is being processed. If You wish to exercise Your right of confirmation, You may contact Andata using the contact information as provided in Section G, below. You may request to receive Your personal data in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without interference.

(ii) Right to Delete

You may request the erasure of Your personal information by contacting Andata at legal@andata.io. Please note that while any changes You make will be reflected in active user databases within a reasonable time, Andata may retain all information You submit for the prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where Andata otherwise reasonably believes that it has a legitimate reason to do so, such as for archiving purposes within the public interest.

(iii) Right to Correct

You may request the rectification of any inaccurate personal data. Taking into account the purposes of the processing, You have the right to have inaccurate or incomplete personal data completed or deleted, by means of first appropriately identifying Yourself and then providing a supplementary statement. If You wish to exercise Your right of rectification, please may contact Andata in accordance with Section G, below.

(iv) Right to Limit Use and Disclosure

You may request that any sensitive personal information be processed only for limited purposes, such as providing You with the services you requested. Sensitive personal information under the CCPA includes certain government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify a consumer; information concerning a consumer's health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership

Andata only retains personally identifiable information about You for as long as Your User Account remains active and for as long as it needs to provide You with Services or otherwise fulfill the purposes for which Andata had initially collected such information, unless otherwise required by law. Andata will retain and use information as necessary to comply with its legal obligations, for archival purposes, to assist in the resolve of disputes, and to enforce its agreements.

Andata complies with the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 "On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) ("GDPR"). If You are a natural person of the EU within the meaning of the GDPR ("Qualified Individual"), You are afforded certain additional rights by the GDPR as further described within this Section.

If and when Andata receives Your personal information directly from You via its Website, Mobile Applications, or Services, it performs the functions of a Data Controller, as defined by the GDPR, and has the ability to determine how personal data is collected, for what purposes, and how this data is to be processed. As the data controller, Andata has implemented many technical and operational measures to ensure the most complete protection of personal data processed through its Website, Mobile Applications. and Services.

Andata processes Your information in accordance with this Privacy Policy and uses industry standard safeguards to secure it.

If You are a Qualified Individual, consents concerning Your personal information are handled in compliance with the GDPR. If and when consent requirements under this Privacy Policy conflict with the GDPR, the GDPR will prevail if You are a Qualified Individual.

Article 6(1)(a) of the GDPR serves as the legal basis for processing operations for which Andata obtains consent for a particular purpose. If the processing of personal data is necessary for the performance of a contract to which You are a party, as is the case, for example, when processing operations are necessary to provide a service, the processing is based on Art. 6(1)(b). The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning Andata products or Services. If Andata is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c). If the processing of personal data may be necessary to protect Your vital interests or that of another Qualified Individual, then the processing is based on Art. 6(1)(d). Finally, processing operations could be based on Article 6(1)(f) if processing is necessary for the purposes of the legitimate interests pursued by Andata or by a third party, except where such interests are overridden by Your fundamental rights and freedoms under the GDPR.

(i) Right of Confirmation

You may obtain confirmation of whether or not Your personal data is being processed. If You wish to exercise Your right of confirmation, You may contact Andata using the contact information as provided in Section G, below.

(ii) Right of Access

You may obtain from information about Your stored personal data at any time and a copy of this information. If You wish to exercise Your right of access, You may contact Andata using the contact information as provided in Section G, below.

(iii) Right to Rectification

You may request the rectification of any inaccurate personal data. Taking into account the purposes of the processing, You have the right to have inaccurate or incomplete personal data completed or deleted, by means of first appropriately identifying Yourself and then providing a supplementary statement. If You wish to exercise Your right of rectification, please may contact Andata in accordance with Section G, below.

(iv) Right to Erasure (Right to be Forgotten)

You may request the erasure of Your personal information by contacting Andata at legal@andata.io.. Please note that while any changes You make will be reflected in active user databases within a reasonable time, Andata may retain all information You submit for the prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where Andata otherwise reasonably believes that it has a legitimate reason to do so, such as for archiving purposes within the public interest.

(v) Right to Restriction of Processing

As a Qualified Individual, You have the right to restrict processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of the controller's use of such data;
• The controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims; or
• The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

(vi) Right to Data Portability

You may request to receive Your personal data in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without interference.

Furthermore, You may have the personal data transmitted directly from one controller to another, where technically feasible and where such transmission does not adversely affect the rights and freedoms of others.

(vii) Right to Object to Automated Decision Making

You may object to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects You, as long as the decision is not (i) necessary for entering into, or the performance of, a contract between You and Andata; (ii) authorized by European Union or Member State law to which You are subject; or (iii) based on the data subject's explicit consent.

(viii) Right to Object to Processing

You may object to the processing of Your personal data using the contact information provided in Section G below, unless there are legitimate grounds for the processing within the public interest, or for the establishment, exercise, or defense of legal claims. If Andata processes personal data for direct marketing purposes, You shall have the right to object at any time to the processing of Your personal data for such purposes. This right also applies to profiling to the extent that the processing is related to such direct marketing purposes. If You object to Andata processing Your personal data for direct marketing purposes, then Andata will no longer process the personal data for such purposes.

Andata only retains personally identifiable information about You for as long as Your User Account remains active and for as long as it needs to provide You with Services or otherwise fulfill the purposes for which Andata had initially collected such information, unless otherwise required by law. Andata will retain and use information as necessary to comply with its legal obligations, for archival purposes, to assist in the resolve of disputes, and to enforce its agreements.

If and when sharing of information involves cross-border data transfers, for instance to the United States of America and other jurisdictions, Andata uses EU Standard Contract Clauses or other suitable contracts and safeguards to permit data transfers from the EU to other countries. The Standard Contractual Clauses commit companies transferring and receiving Your personal information to protecting the privacy and security of Your data. Copies of Andata's current Standard Contractual Clauses are available on request using the contact details listed below.

Andata takes and addresses its users' privacy concerns with the utmost respect and attention. Andata will investigate and attempt to resolve all complaints regarding use and disclosure of Your personal information by reference to the principles of this Privacy Policy. If You believe that there was an instance of non-compliance with this Privacy Policy with regard to Your personal information (an inquiry) or You would like to make or follow-up on a complaint, please contact Andata at:

Andata Inc.

Email: eu.legal@andata.io

ATTN: Privacy Matter

Mailing Address:

In Your message, please describe in as much detail as possible the nature of Your inquiry or the ways in which You believe that Andata's Privacy Policy has not been complied with. Andata will investigate Your inquiry or complaint promptly.

Please note that if You provide Andata with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact You with marketing offers and indicating on another occasion that they may not), Andata cannot guarantee that Your most recent privacy preference will be immediately honored.

If You are a Qualified Individual, You may lodge a free complaint with the DPA in the country where You live if You are unsatisfied with how Your complaint is handled by Tunetank. If You are an EU resident, You can find Your DPA by visiting the European Commission Website on Data Protection Authorities.




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