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Last Modified: May, 2020

Subject to the requirements of applicable law, Media Arena Ltd and its affiliated companies and subsidiaries (referred to as "Company," "we," or "us") will provide individuals with the opportunity to exercise their rights regarding their Personal Data.
We highly value the privacy rights of our users. Therefore, we have created this Privacy Rights Policy ("Privacy Rights Policy" or "Policy") to provide you with an overview of your rights regarding your Personal Data under the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act of 2018 ("CCPA" or "Act"), where applicable.

(A) Access to Specific Information and Data Portability Rights

You have the right to request confirmation of whether we process certain Personal Data related to you. Additionally, you have the right to obtain a copy of such Personal Data, along with additional information regarding how and why we use this data. The GDPR and CCPA provide different protections in this regard. The GDPR grants access to all Personal Data processed by the controller, while the CCPA "Access Right" applies only to Personal Information collected in the 12 months preceding the request. Once we receive your request, we will assess its validity and provide you with the relevant confirmation of processing, a copy of the Personal Data, or a description of the Personal Data and categories of data processed. We will also disclose the purpose for which such data is held and processed, as well as details about the source of the Personal Data not provided by you. Our response will be provided within the time period required by law (please refer to "Response Timing and Format" below for more details).

(B) Deletion Request Rights

The Company is legally obligated to comply with a request to delete Personal Data under the following circumstances:

• The data is no longer needed for the original purpose, and there is no new lawful purpose for continued processing.
• The lawful basis for processing is the data subject's consent, and such consent has been withdrawn.
• The data subject exercises their right to object to the Company's processing of their Personal Data, and the Company has no overriding grounds for processing the data.
• The Personal Data is processed unlawfully. Erasure of the Personal Data is necessary to comply with applicable laws.
• If the Company has shared Personal Data with a third party, the data subject also has the right to require the Company to inform those third parties about the need to erase the information.

The right to erasure is not absolute. Even if a data subject falls into one of the aforementioned categories, the Company may reject the request and continue processing the data subject to applicable law in the following cases:

• When processing is necessary to comply with legal obligations.
• When processing is necessary to establish, exercise, or defend legal claims.
• When processing is necessary for scientific research, etc. When processing is necessary to perform a contract between you and us.
• When processing is necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity.
• When processing is necessary to debug and identify and repair errors that impair existing intended functionality.
• When processing enables solely internal uses that are reasonably aligned with your expectations based on our relationship with you.

(C) Right to Object/Right to Opt Out

You have the right to object to our processing of your Personal Data based on our legitimate interests, such as direct marketing. However, even if we receive your objection, we may continue processing the Personal Data if:
• Our legitimate interests for processing override your rights, interests, and freedoms.
• The processing is necessary to establish, exercise, or defend a legal claim or right, etc.

(D) Your Right to be Informed

You have the right to be informed about the Company's details (e.g., name, address) and the reasons and lawful basis for processing Personal Data. This right includes knowing the identity of the business, the reasons and lawful basis for processing Personal Data, and additional information necessary to ensure the fair and transparent processing of Personal Data. Furthermore, you have the right to be informed about the categories of Personal Information collected, sold, and disclosed by us in the previous 12 months. We ensure that our privacy policy discloses all of the above and is updated every 12 months. Please refer to our Privacy Policy for further details.

(E) The Right of Rectification

The Company is responsible for ensuring the accuracy of all Personal Data it holds and uses about a data subject. If the data is not accurate, you have the right to request the Company to update it accordingly. Additionally, if the Company has shared incorrect information about you with a third party, you have the right to oblige the Company to inform those third parties that the information should be updated.

(F) Rectification Access

If we hold inaccurate Personal Data about you, you can request us to update it with accurate information. Furthermore, if we have shared incorrect information about you with a third party, you have the right to require us to inform those third parties that the information needs to be updated.

(G) The Right of Restriction

You may limit the purposes for which the Company processes your Personal Data. The Company's processing activities may be restricted if:
• The accuracy of the data is contested.
• Processing is unlawful, and the data subject requests restriction instead of erasure.
• The Company no longer needs the data for its original purpose, but the data is still required to establish, exercise, or defend legal rights.
• Consideration of overriding grounds in the context of an erasure request.

(H) Data Portability

You may request us to send or "port" your Personal Data held by us to a third-party entity. However, please note that the GDPR and CCPA differ in their application of this right, and thus, we will handle your request accordingly based on the jurisdiction you are subject to.

(I) Nondiscrimination

Under the CCPA, you cannot be discriminated against for exercising any of your rights. This includes being denied goods or services, being charged different fees, receiving different prices or rates for goods or services, or being subjected to penalties. However, the Company is allowed to establish schemes for providing financial incentives, which you may choose to opt into.

(J) Response Timing and Format

We strive to respond to verifiable consumer requests without undue delay and, in any event, within 30 days from the receipt of the request under GDPR, or between 10-45 days from the receipt of a request under CCPA. If we require more time, we will inform you in writing, explaining the reasons and providing an extension period. Our response will also clarify the reasons why we cannot comply with a request, if applicable. For data portability requests, we will select a format that allows your Personal Data to be readily usable and transferrable between entities without hindrance.

Please note that under the CCPA, your rights only apply to Personal Information collected within the 12 months preceding the request, and you are limited to submitting no more than 2 requests within a 12-month period.

This Policy exclusively addresses your rights concerning Personal Data/Personal Information (as defined under applicable law) processed by us.

(K) Please Submit a Request By:

Filling out the Privacy Rights Request form.
Emailing us at: support@mediaarenaltd.com