│ PRIVACY POLICY │

Effective Date:  May 24, 2018

1.         Privacy Statement.

This Website is owned and operated by Active Sun Network, LLC (“Company” “we” or “our”) is committed to advising you of the right to your privacy, and strives to provide a safe and secure user experience.  This Privacy Policy explains how we collect, store and use personal information, provided by you on our website.  It also explains how we collect and use non-personal information. By accessing and using our website, you explicitly accept, without limitation or qualification, the collection, use and transfer of the personal information and non-personal information in the manner described in this Privacy Policy.  Please read this Policy carefully, as it affects your rights and liabilities under the law.  If you disagree with the way we collect and process personal and non-personal information, please do not use this website. This Policy may be amended or updated at our discretion from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or any changes in applicable law.  Please note that this Privacy Policy addresses only our practices with respect to information we collect in the course of using our services and does not apply to information about you that might be collected by a third-party website or an offering linked to or otherwise accessible from our services. Any information collected, obtained and/or used by any such third parties is subject to the privacy policies of those third parties. We encourage you to review the policies of such third parties.

2.         Personal Data Collection.  The categories of Personal Data we may collect, Control or Process pertaining to you and subject to applicable law, are as follows:

•          Personal Information: Name(s); login names; nickname(s), gender; date of birth; age; marital status;  social security number; passport number(s); other government   issued   tax identification number(s) ;  driver’s license  number(s); nationality;  lifestyle  and social  circumstances;   photo images   of passports, drivers  licenses,   and  signatures;  authentication   data (passwords, mother's maiden name, challenge/response questions and answers, and PINs;  and personal appearance and behavior.

•          Contact Information: address; telephone number; cell phone number, email address; and social media profile details.

•          Employment:  industry; role;  business  activities; names  of  current and  former  employers; work address; work telephone number; work email address;  and work-related social media profile details.

•          Education history:  schools attended, degrees held, or other qualifications.

•          Financial information: billing address, bank   account   numbers;  credit   card    numbers; debit card numbers, cardholder or account holder name and details;   instruction records; transaction details.

•          Electronic Identifying Data: IP addresses; cookies; activity logs; online identifiers; unique device identifiers; and geolocation data.

3.         Collection of Personal Information.  We collect Personal Information about you from a variety of sources:

•          Directly from you in the ordinary course of business;

•          Public information including social media or information provided by third parties who collected the same.

•          We collect or obtain Personal Information when you visit our Website or use any features or resources available on or through our Website. When you visit our Website, your device  and  browser may  automatically collected and disclose certain information (such as device type, operating system,  browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal  Data.

4.         The Legal basis for Collecting and Processing your Personal Data. We seek to collect or otherwise Process your Personal Data, for the following legal basis:

•          As necessary for compliance with a legal obligation under a contract with you;

•          As necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;

•          As necessary for the establishment, exercise or defense of legal rights;

•          We have, in accordance with applicable law, obtained your explicit consent prior to collecting your Personal Data. This legal basis is only  used in relation to collection that is voluntary in doing business with us and is not used  for collection that is  necessary or obligatory;  or

•          Collection is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.

6.         Age Limitations. We do not direct our Website or Services to children under the age of 13. We do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use our Website or services. If we obtain actual knowledge that we have collected personal data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

7.         Purposes For Which we may Use or Process your Personal Data.  The purposes for which we may Process Personal Data are as follows:

•          Signing up new clients; and compliance with our internal compliance requirements, policies and procedures.

•          Maintaining and updating your contact information where appropriate.

•          Marketing and promotional activities.

•          Providing you with information or assistance that you request from us;

•          Conducting verifications, monitoring and reporting in accordance with anti-money laundering and counter terrorist financing laws;

•          Providing you with the services requested;

•          Notifying you about changes to our services;

•          Monitoring and improving the quality of our services;

•          Quality assurance and training purposes;

•          Complying with our legal and regulatory requirements.

8.         Disclosure of Personal Data to Third Parties.  We disclose your Personal Data to other entities for legitimate business purposes including providing services to you, in accordance with applicable law.  In addition, we may disclose your Personal Data to:

•          Your representatives as requested or authorized;

•          Our vendors, subcontractors and service providers. We may share your data with our services providers who process your personal data to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else or using it for other purposes.

•              We may share your information with our parent company and our affiliates, which are entities under common ownership or control of our ultimate parent company. Our accountants, auditors, financial advisors, lawyers and other outside professional advisors to us, subject to binding contractual obligations of confidentiality;

•          Governmental, legal, regulatory, or similar authorities, central and/or local government agencies, upon court order, request or where required, including reporting any actual or suspected breach of applicable law or regulation or our contractual agreements;

•          We may disclose the personal information we collect about our users when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.

•          We may share your information with advertisers and advertising networks that place ads (including sponsored links) on our Website. These companies may collect information, such as your computer’s IP address, browser information, and search queries, as you use our Website and services. They also may use cookies and other technologies to collect this information when you visit our site as described below.

•          Accreditation bodies;

•          Third party processors located anywhere in the world,

•          Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary to respond to a court order, or in the exercise or defense of legal rights in accordance with applicable law;

•          Any relevant party for the purposes of prevention, investigation, detection or prosecution of a civil or criminal offence or the execution of civil or criminal penalties, including safeguarding against and the  prevention of threats to public security in accordance with applicable law;

•          In the event that we sell or transfer all or any relevant portion of our business or assets including in the event of a reorganization, dissolution or liquidation, the information is transferred automatically to the new owner; 

•          If we engage a third-party Processor to Process your Personal  Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and  (ii)  use measures  to  protect the  confidentiality  and security  of the  Personal Data;  together with  any additional requirements  under applicable  law.

9.         International transfer of Personal Data.  Because of the international nature of our business, we may need to transfer your Personal Data to third parties as noted above in connection with the purposes for which you provided it to us and as set forth in this Privacy Policy.  For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws which are of a lower standard to those that apply in the country in which you are located or are a citizen.

We transfer your Personal Data to other countries on the following basis:

• Adequacy decisions;

• Binding Corporate Rules; or

• Standard Contractual Clauses; or

• Other valid transfer mechanisms.

If you want more information about the safeguards applied to international transfers of personal data, please contact us.

10.       Data Security.  We have implemented appropriate technical and organizational security measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access in accordance with applicable law. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorized. You are responsible for ensuring that any Personal Data that you send to us are sent securely. 

11.       Data Accuracy.  We take reasonable steps designed to ensure that:

• Personal Data that we Process is accurate and kept up to date as necessary; and

• Personal Data that we Process which is inaccurate and not necessary to retain is timely

   destroyed and expunged

From time to time we may ask you to confirm the accuracy of your Personal Data.

12.       Data Minimization and Retention.  We take reasonable steps designed to ensure that Personal Data in our systems is limited to that which is reasonably required to be retained in connection with our business purposes including those set out in this Privacy Policy. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

13.       European Union Citizen Legal Rights (GDPR).  We may transfer your Personal Information to countries other than the one in which you live. In particular, your personal data will be transferred to and processed in the United States where many of our central databases operate. By using the Services, you acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your personal data being collected, processed and transferred as set forth in this Privacy Policy and US law. To the extent we are aware that you are a European Union Member Citizen we have Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for you. If you are a European Union Member Citizen or business entity, subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

•          the  right to request access to, or copies of, your Personal Data that we Process or control, together with information  regarding the nature,  processing and disclosure of those  Personal  Data;

•          the right to request rectification of any inaccuracies in your Personal Data that we Process or control;

•          the right to request, on legitimate grounds:

•          erasure of your Personal Data that we Process or control; or

•          restriction of Processing of your Personal Data that we Process or control;

•          the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;

•          where we Process your Personal Data on the basis of your consent, the right to withdraw that consent;

•          the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.

Subject to applicable law, as a European Union Member Citizen you may also have the following additional rights regarding the Processing of your Personal Data:

•          The right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us or on our behalf; and

•          The right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes.

•              Subject to applicable law, you also have the right to (i) restrict our use of your personal data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to your lead supervisory authority. 

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please contact us.

14.       California Resident Rights.  California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared.  In addition California residents have the right to know if we respond to do not track signals or cookies.  We do not respond to such signals or cookies.

            As stated in this Policy, you have agreed to allow us to share information with third parties for their direct marketing purposes until you remove your information; and thus, you have agreed to this disclosure.  California customers may request further information about our compliance with this law by sending us an email at privacy@activesunnetwork.com.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

15.       Cookies and Technology Tracking.  We use cookies, pixel tags, web beacons, and similar files or technologies to collect and store the information we automatically collect about your computer, device, and product usage. We use the term "cookies" in this policy to refer to cookies and all such similar technologies that collect information automatically when you are using our Website where this policy is posted. We may Process your Personal Data through cookie technology. We use cookies on our website to enhance the experience while using the Website. Where applicable this Website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer / device. The Website complies with recent European Union Member legislation requirements for Websites under such directive to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer / device. If you wish to deny the use and saving of cookies from this Website on to your computer’s hard drive, you should take necessary steps within your web browsers security settings to block all cookies from this website and its external serving vendors. If you continue to use this Website without taking action to prevent the storage of this information, you are effectively agreeing to this use.

Cookies are small files saved to the computer’s hard drive that track, save and store information about the user's interactions and usage of the website. The use of Cookies helps us analyze data about web page traffic and improve our website in order to customize it to the users' needs. We use this information for statistical analysis purposes and then the data is removed from the system.

16.       Log Files.  We automatically collect and store certain information in server logs the following:

Search activity when you use web search services (such as search queries) (“Search Data”).

·   Internet protocol address (“IP Address”)

·   The type of browser you are using when using our Services, including your browser's "user agent" (e.g., Internet Explorer, Safari, and other browsers)

·   Device event information such as crashes, system activity, hardware settings, browser language, and the date and time of your request and referral URL

·   Your geographic location

·   The Domain name of your Internet Service Provider

•  The source of traffic acquisition

•  Date of traffic acquisition,

•  Views on landing page, clicks on an action button on landing page, order pages and abandonment.

17.       Contact details

If you have any comments, questions or concerns about our privacy practices, please contact our Chief Privacy Officer via email at privacy@activesunnetwork.com

Address:

C/O Chief Privacy Officer
privacy@activesunnetwork.com