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PRIVACY POLICY


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THE PRIVACY POLICY OF THE LIQUIDM TECHNOLOGY GMBH IN ACCORDANCE WITH THE GENERAL
DATA PROTECTION REGULATION (GDPR)

This Privacy Policy applies to the web services and websites of  LiquidM
Technology GmbH, Invalidenstr. 74, 10557 Berlin, Germany, represented by Philipp
Simon and Thomas Hille, hereinafter referred to as LiquidM. “This Privacy Policy
is always to be regarded as part of the respective web presence which directly
refers to this site (e.g. under “Privacy” or “Privacy Policy”).

As a controller in accordance with the EU General Data Protection Regulation
(“GDPR”), LiquidM takes the protection of your personal data very seriously. We
would like to inform you about when we collect what data and how we use it. We
have implemented extensive technical and organizational measures (Art. 32 GDPR)
to ensure compliance with and adherence to applicable provisions on data
protection and data security by LiquidM and as well contracted third party
providers. Please note that amendments to this Privacy Policy may be required
due to the ongoing development of our websites and the implementation of new
technologies to improve our web services. We, therefore, recommend frequently
referring back to this Privacy Policy and reading through the current up-to-date
version, which is always available online under
https://www.liquidm.com/privacy-policy.

I. WHAT IS PERSONAL INFORMATION?

According to Art.4 No. 1 GDPR, personal data is any information relating to an
identified or identifiable natural person, therefore can be used to obtain
personal or factual details about the data subject (such as name, address,
telephone number, date of birth or e-mail address). Information that cannot
(directly or indirectly) be associated with a natural person (or only with
disproportionate effort), for example, anonymous information, is not personal
information.

II. WHAT INFORMATION DO WE COLLECT AND PROCESS?

You can use a portion of our online content without providing personal
information.

a) Contact forms

If you, however, decide to request further information via the contact forms
provided on our website, we may ask for your name and further personal
information in order to handle your personal request or to provide the services
you requested from us or our customers. You can freely decide whether or not you
want to provide that information. However, without this information, we are
unable to make the desired services available to you.

b) User account (LiquidM Platform)

Certain services of our Online-Service called “LiquidM Platform” with which you
can create and display advertising campaigns on your own, upload list of
advertising IDs for retargeting campaigns and specify targeting criteria for
your campaigns, can only be used by registered users with a user account. We
store your e-mail address during registration. The e-mail address serves as a
username to identify your member account, and to conduct relevant correspondence
with you (e.g. setting up and maintaining your user account). As part of the
registration process, we also collect your first and last name, your salutation
and information about your company affiliation, mailing address, to ensure that
you receive personalized, competent service. All mandatory information required
in order to register is marked accordingly. All further information is provided
voluntarily; this data is used for the purposes stated, or to improve our online
services.

By registering with our websites, you declare your agreement with the General
Terms and Conditions of LiquidM and the use of your abovementioned personal
information in accordance with this Privacy Policy.

If you wish to register as a user of our LiquidM App and open a user account,
please select for your own safety a secret and secure password in order to
ensure the confidentiality of your data. Your password is transmitted to and
stored on our servers in encrypted form, in the event that you forget your
password, please use the “Forgot your password?” function provided on the
website to create a new, secure password.

If you want to delete your account, please contact us at info@liquidm.com. If
deletion is not possible for legal reasons, access to the data in question shall
instead be blocked. Please note, however, that we may be unable to continue
offering some or all of the services provided on our websites requiring
registration in the event that your data is deleted or blocked.

c) LiquidM newsletter

As part of our web services, we offer a regular subscription to our LiquidM
newsletter. When requested, the newsletter provides you with free, up-to-date
information on our services. To register without LiquidM newsletter service, we
need your first and last name, your gender, and the e-mail address at which you
wish to receive the newsletter. If you wish to subscribe to the LiquidM
newsletter, we ask that you provide us with the following declaration of
consent:

I would like to regularly receive the LiquidM newsletter and agree that my
e-mail address, my first and last name, and my gender, as well as any data
voluntarily provided, be used for this purpose. I can revoke this declaration of
consent at any time by using the “Opt-Out function” in the respective LiquidM
Newsletter or via an e-mail notice to newsletter@liquidm.com, as well as by
writing to LiquidM GmbH, Invalidenstr. 74, 10557 Berlin, Germany, such
revocation to take effect for the future. No additional fees beyond the normal
transmission fees of my e-mail or Internet provider shall apply. In the event
that my consent is revoked, I shall not, or shall no longer, be able to receive
the LiquidM newsletter. I have read and accepted the current privacy policy.

III. DELIVERY OF PERSONALISED OR BEHAVIOUR-BASED ADVERTISING (BEHAVIORAL
TARGETING)

In certain cases, we showcase advertising to you on the websites of our partners
and for our customers, which are automatically selected on the basis of your
surfing behaviour, in order to optimise the quality of the advertising notices
for you (so-called “personalised” or “behaviour-based” advertising delivery and
“behavioral targeting”). The objective of this system is to only demonstrate to
you content that corresponds to your interests. Advertisements which are
unlikely to be of interest to you or which are irrelevant will not be shown to
you by the activated behavioral targeting system of LiquidM and will be
disabled.

In such a case, this section IV. of the data protection declaration applies as
part of the respective web-based services of our partners or customers, from
which (for example under “data protection” or “data protection declaration”
direct reference was made or a link was created. We wish to disclose to you in a
transparent manner how the behavioral targeting works, which data is gathered in
the process, how this data is used and for what purpose and how you can object
to the behavioral targeting function at any time and block it.

As a German/European company, the protection of your data is a priority for
LiquidM, also in the course of the delivery of behavior-based advertising and
LiquidM only uses anonymized data to improve advert quality. Therefore, an
identification of your person is not possible either for LiquidM or the
respective operator of the website of our partners and customers which you are
visiting. You can yourself decide at any time whether you would like to continue
seeing the personalized banner from LiquidM.

a) How does behavioral targeting work in individual cases?

We take part in a programmatic auction system where placements for advertisement
in apps and websites are sold. In this process, we may collect information about
you and your use of the website or app. This information cannot be used to
identify you in real life but it does enable us to recognize your device when
you use sites or apps that have partnered with us.

Another way we may deliver personalized advertising to you is when you visit the
website of one of our partners or customers. On some of these sites, a cookie
file is stored on your computer. Cookies are small text files which are
deposited by your web browser in a folder on your computer which is designated
for this purposes and which contains a single character string as a means of
identification. (The cookie does not store your IP address.) The same character
string is also saved on our servers. The next time you visit one of our
partners’ websites, only the character string is read which identifies the
Internet browser you are using. This allows us, for example, to identify which
page you have accessed for our partner and which advert you have been shown,
without this being linked to your identity. Furthermore, all of the cookies
created by us are given an expiry data and automatically expire after no more
than 13 months. Without a valid cookie file, the character strong saved on our
servers is no longer to be assigned for us.

Important: Using cookies we cannot ever collect any other personal data. For
example, when you enter an email address or delivery address, or any other
personal data, we cannot see your input and cannot, therefore, process or store
it. We do not know your name, address or workplace, nor do we know your gender,
age, email address or any other personally identifiable information about you.
Even the IP address of your computer is not stored! You can view the data stored
in the cookie on your computer. Please refer to your web browser’s help
directory or your web browser’s FAQ to learn how cookies are stored and how to
read their content. The information contained within the cookie is the exact
data that we can see Cookie technology does not allow viruses, trojans or other
harmful programs to be placed on your computer.

A full list of the cookies used by LiquidM and their individual functions can be
downloaded here at any time. Should you not agree to the saving of cookies on
our part, you can examine your cookie status at the very top of this page at any
time, and also deactivate the saving of behavioral targeting cookies by us.
Therefore you can object to the personalized adverts from LiquidM at any time.

b) How can I disable personalized advertising from LiquidM banners?

If you do not agree to the storing of cookies by us, you can check your cookie
status at any time at the very top of this page and disable the storage of
retargeting cookies by us and therefore decline personalized adverts from
LiquidM.

This means that in future you will receive random advertising that is not
targeted to your interests.

Please note that the “opt-out” and “opt-in” functions offered are, for technical
reasons, also controlled via cookies. This means that deleting all cookies on
your computer means that you will have to opt-out again.

It is also the case that the deletion of all cookies on your computer does not
lead to no personalized advertising being notified to you on a permanent basis.
Therefore, you must use the  “opt-out” function as described.

Finally, please note that we are continuously expanding our range of products.
As this will technically involve a new system, the introduction of a new opt-out
may be necessary, even if you have already opted prior to its introduction.

c) Can other forms of personalized advertising be disabled in addition to
LiquidM?

The options described in this section refer only to the personalized adverts
offered by LiquidM. If you wish to disable personalized advertising from other
providers, you can do this via their respective websites.

There is an option to change your settings collectively for various providers
under preference management on “Your Online
Choices”: http://www.youronlinechoices.com/de/praferenzmanagement/.

If you want to opt-out from the usage of the Advertising ID, please refer to
your operating system settings, or follow the instructions below:

Android Users (version 2.3 and above) To use the “opt-out of interest-based
advertising” option, follow the instructions provided by Google here: Google
Play Help.

iOS users (version 6 and above) To use the “Limit Ad-Tracking” option, follow
the instructions provided by Apple here: Apple Support Center

Please note that these are device settings and will disable interest-based ads
from all providers, and not just for us

d) We also collect information about the advertisements that have been served to
you by LiquidM and match them we the Advertising ID from the programmatic buying
process.

Information about the ads can contain:

 * the details of the ad delivered (e.g. advertiser’s name, type of advert,
   etc);
 * the website or the app where the ad was delivered;
 * your interaction with the ad (i.e. whether you clicked, hid, muted or
   otherwise interacted with the ad);
 * whether you performed certain actions after clicking on the ad (e.g.
   downloading an application, making a purchase, etc).

e) How do we use the collected information?

We use the information we collect to display interest-based advertising
customized to individuals’ inferred interests, preferences and locations, and to
perform analysis aimed at improving our services and technologies. We also need
the information in the billing process with our customers and to validate the
billings we receive from our partners. The information we collect also helps us
to provide filtering options for publishers and developers to manage ads
appearing on their sites and in their apps, and to provide targeting options for
advertisers. In the end, this helps publishers and developer clients, for
example, not to present you ads that you have already seen, and helps our
advertiser clients serve adverts that are most likely to be of interest to you.

Important: We do not store the IP-Addresses un-anonymized or the Geographic
location

f) LiquidM and Google Authorized Buyers Program

As part of the Google Authorized Buyers Program, LiquidM has agreed to adhere to
the following Program guidelines. We highly encourage you to learn more about
how Google’s products use data from sites and apps that use their services from
the following partner-facing documentation. For more information, please consult
Google’s Platform program policies.

IV. ANONYMOUS DATA/USE OF COOKIES

We also use cookies on the LiquidM websites. Cookies are small text files,
stored by your web browser in a dedicated directory on your computer or mobile
device. Cookies are solely used to identify your web browser in an anonymous
manner. Our cookie files only contain automatically generated ID numbers and a
time stamp. We neither know your name, the place you live or work nor do we know
your gender, your age, your e-mail address or any other similar information
about you. The IP address of your device will also not be stored. You can view
the data stored in the cookie on your computer. Please refer to your web
browser’s help directory to learn how cookies are managed. The information
contained within the cookie is the exact data that we can see Cookie technology
does not allow viruses, trojans or other malware to be placed on your computer.

You can also use our websites without the use of cookies enabled. Most browsers
accept cookies automatically. You can disable the storage of cookies or set your
browser to notify you before accepting the storage of cookies. Please note that
users who do not accept the storage of cookies may not be able to access certain
functionality of our websites, or can only use our websites with considerable
difficulty.

Further information and a full list of the cookies which are used by LiquidM on
its own websites or on those of customers or partners, as well as their
individual functions, can be downloaded here at any time. In addition, you can
generally prevent the storing of cookies by adjusting your browser settings
accordingly.

V. LEGAL BASIS

The legal bases for the processing of your data could be the following:

 * Your consent to the use of data in accordance with Art. 6 (1) lit. a) GDPR;
 * The performance of our service obligations arising from contracts concluded
   with you in order to provide the services you request in accordance with
   Article 6 (1) lit. (b) GDPR;
 * Our legitimate interest in accordance with Art. 6 (1) lit. f) GDPR, e. g. 
   * Our business interests in improving our services so that we can better
     understand your needs and expectations and thus improve the services we
     provide to you;
   * To prevent fraud and to ensure that our websites are used completely and
     without any fraudulent behavior;
   * To ensure and guarantee the security of our services, making sure that our
     offer is technically secure and properly functioning;
   * to ensure and enforce our contractual requirements and claims.
 * Legal reasons in accordance with Art. 6 (1) lit. c) GDPR if the collection,
   storage, transfer or other processing of data is prescribed by law or
   processing is necessary to fulfill our legal obligations.

VI. DATA STORAGE

We store personal information you submit to us only for as long as is necessary
to fulfill the purposes for which such information was transmitted, or as
required by law:

 * If you conclude contracts with us, we store and process your personal data
   for the duration of the contractual relationship and beyond for the
   fulfillment of post-contractual obligations and handling of issues as well as
   for the duration of statutory retention periods (maximum 10 years);
 * If you have consented to the promotional use of your e-mail address, we will
   store your e-mail address with our mail service provider until you
   unsubscribe, requesting us to delete the data;
 * If you send us an inquiry, we process your personal data while we handle your
   request.

VII. IS PERSONAL INFORMATION FORWARDED TO THIRD PARTIES?

We forward your Advertising ID  we received from our Partners to companies
running the advertising campaigns on our service or companies providing
anonymous audience data in case we register that you saw one of our
advertisements or in case you clicked on an advertisement. This is only done for
billing and statistical reasons. In certain cases, we are also required by law
to disclose your personal information to third parties. This is, for example,
the case when the suspicion of a criminal offense or a misuse of our websites
occurs. We are then required to disclose your data to law enforcement
authorities.

Outside of the cases described in this data protection declaration, your data is
not forwarded on to third parties and, your information is solely stored in our
databases / on our servers (or on the servers of third-party providers).

VIII. HYPERLINKS TO OTHER WEBSITES

In addition, our websites contain hyperlinks to websites offered by third
parties When clicked, the hyperlinks redirect you from our website directly to
the website of another provider. You can recognize this redirection process by
the change of the URL in your web browser’s address bar. If you have been
forwarded to the website of a cooperation or promotional partner, the use of
your personal information will only be subject to the privacy policy of the
relevant provider. We cannot take any responsibility for the privacy practices
of third parties´ websites because we do have no control over their compliance
with data protection regulations.

IX. PROTECTION OF MINORS

Persons under 18 years are excluded from our services and from providing any
personal information without the consent of their parents or guardians. We do
not request personal information from children and adolescents. We do not
knowingly gather or collect such data and do not disclose it to third parties.

X. HOW WE KEEP YOUR INFORMATION SECURE

When we collect information, we solely store your data on highly protected
servers in Germany and the EU. Access to our IT infrastructure is strictly
limited to authorized persons who are involved in the technical, commercial or
editorial support.

In order to avoid loss or misuse of data stored by us, we have taken all
necessary and extensive technical and organizational safety precautions, which
are regularly checked and updated based on technological advancements in
accordance to the GDPR.

However, we would like to inform you that because of the nature of the Internet,
the provisions of data protection and data security measures described in this
Privacy Policy may not be observed by any third parties or institutions beyond
our control. Especially unencrypted data transmission – even when sent via
e-mail – can be read by third parties. We have no technical influence on this.
The user has the responsibility to protect the information he provides from
misuse by encryption, selection of a secure password or other means.

XI. RIGHTS OF THE “DATA SUBJECT” ACCORDING TO THE RULES OF THE GDPR:

According to the EU General Data Protection Regulation, you deserve the right to
request access to your personal data (see Art. 15), as well as rectification
(see Art. 16), erasure (see Art. 17) or at least restriction of processing (see
Art. 18) of your personal data.

Furthermore, you have a right to data portability (see Art. 20) and, of course,
the right to revoke any consent given to the processing of personal data at any
time (see Art. 7) and to object to processing based on the balancing of
legitimate interests (see Art. 21(4) GDPR). In addition, you have a right to
appeal to the competent data protection supervisory authority.

If you have any questions or other feedback on the subject of data protection or
would like to exercise your rights regarding data protection, please contact our
Data Protection Officer or ourselves:

Rechtsanwalt Stephan Krämer, LL.M.,

Kinast & Partner Rechtsanwälte

https://www.kinast-partner.de/

LiquidM Technology GmbH

Invalidenstr. 74

10557 Berlin

Germany

E-Mail: privacy@liquidm.com

--------------------------------------------------------------------------------

Version: May 2018 – We reserve the right to adapt this data protection
declaration and will announce any changes in good time.


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