<p align="center" style="text-align: left; font-family: Raleway; font-size: 30px;"><span style="font-size: medium;">We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Members (Section 2), Contacts (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.</span></p><p style="font-family: Raleway; font-size: medium;">If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.</p><p style="font-family: Raleway; font-size: medium;"><b>1. The Basics</b></p><p style="font-family: Raleway; font-size: medium;"><b>A. About Us</b></p><p style="font-family: Raleway; font-size: medium;">Radar108 is an online marketing platform (the "Services") operated by 108Digital LLC, a company headquartered in the State of Connecticut in the United States ("we," "us," "our," and "108Digital").</p><p style="font-family: Raleway; font-size: medium;">The Services enable our Members to, among other things, send and manage email campaigns and serve advertisements. We also provide other related services, such as real-time data analytics. Find out more about our Services here.</p><p style="font-family: Raleway; font-size: medium;"><b>B. Key Terms</b></p><p style="font-family: Raleway; font-size: medium;">In this privacy policy, these terms have the following meanings:</p><p style="font-family: Raleway; font-size: medium;">"Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's Distribution List or about whom a Member has given us information. For example, if you are a Member, a subscriber to your email marketing campaigns would be considered a Contact.</p><p style="font-family: Raleway; font-size: medium;">"Distribution List" is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).</p><p style="font-family: Raleway; font-size: medium;">"Member" means any person or entity that is registered with us to use the Services.</p><p style="font-family: Raleway; font-size: medium;">"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.</p><p style="font-family: Raleway; font-size: medium;">"Website(s)" means any website(s) we own and operate (such as www.108Digital.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.</p><p style="font-family: Raleway; font-size: medium;">"Visitor" means any person who visits any of our Websites.</p><p style="font-family: Raleway; font-size: medium;">"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.</p><p style="font-family: Raleway; font-size: medium;"><b>2. Privacy for Members</b></p><p style="font-family: Raleway; font-size: medium;">This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.</p><p style="font-family: Raleway; font-size: medium;"><b>A. Information We Collect</b></p><p style="font-family: Raleway; font-size: medium;">The Personal Information that we may collect broadly falls into the following categories:</p><p style="font-family: Raleway; font-size: medium;">(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with 108Digital), or communicate with us in any other way.</p><p style="font-family: Raleway; font-size: medium;">We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.</p><p style="font-family: Raleway; font-size: medium;">This information may include:</p><ul style="font-family: Raleway; font-size: medium;"><li>Registration information: You need a 108Digital account to use the Services as a Member. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number (for example, if you are using two-factor authentication).</li><li>Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address, or information pertinent to other forms of payment. 108Digital will also maintain a record of your billing transactions and purchases, and any communications and responses.</li><li>Information we process on your behalf: In order to send an email campaign or use certain features in your account, you need to upload a Distribution List that provides us information about your Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.</li></ul><p style="font-family: Raleway; font-size: medium;">(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;">This information may include:</p><ul style="font-family: Raleway; font-size: medium;"><li>Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.</li><li>Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.</li><li>Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.</li></ul><p style="font-family: Raleway; font-size: medium;">(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.</p><p style="font-family: Raleway; font-size: medium;">Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.</p><p style="font-family: Raleway; font-size: medium;">(iv) Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.</p><ul style="font-family: Raleway; font-size: medium;"><li><p>Device information: We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile apps or Services.</p></li><li><p>Product usage data: We may use mobile analytics software to better understand how people use our application. We may collect information about how often you use the application and other performance data.</p><p></p></li></ul><p style="font-family: Raleway; font-size: medium;"><b>B. Use of Personal Information</b></p><p style="font-family: Raleway; font-size: medium;">We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:</p><ul style="font-family: Raleway; font-size: medium;"><li>To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.</li><li>To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.</li><li>To communicate with you about your account and provide customer support. For example, if you use our mobile apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.</li><li>To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content of our Members’ email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms of Use. Our employees or independent contractors may review those particular email campaigns. This benefits all Members who comply with our Terms of Use because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability. Email was not built for confidential information. Please do not use 108Digital to send confidential information.</li><li>To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.</li><li>To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.</li><li>To prosecute and defend a court, arbitration, or similar legal proceeding.</li><li>To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.</li><li>To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.</li><li>To provide suggestions to you. This includes adding features that compare Members’ email campaigns, using data to suggest other publishers your Contacts may be interested in, or using data to suggest products or services that you may be interested in or that may be relevant to you or your Contacts. Some of these suggestions are generated by use of our data analytics projects, which are described below. For more information about our use of cookies and other tracking technologies for this purpose, and instructions about how to opt out of having data collected through the use of cookies, please see our Cookie Statement here.</li></ul><li style="font-family: Raleway; font-size: medium;">For our data analytics projects. Our data analytics projects use data from 108Digital accounts, including Personal Information of Contacts, to provide and improve the Services. We use information like your sending habits and your Contacts’ details and purchase history, so we can make more informed predictions, decisions, and products for our Members. If you or your Contact prefers not to share this data, you can opt out of data analytics projects at any time by emailing us at dataoffice@radar108.com</li><li style="font-family: Raleway; font-size: medium;">For example, we use data from 108Digital accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. We will act as a data controller to process data for our data analytics projects in reliance on our legitimate business interests of improving and enhancing our products and services for our Members. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.</li><li style="font-family: Raleway; font-size: medium;">Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.</li><li style="font-family: Raleway; font-size: medium;">Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.</li><p style="font-family: Raleway; font-size: medium;"><b>C. Cookies and Tracking Technologies</b></p><p style="font-family: Raleway; font-size: medium;">We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.</p><p style="font-family: Raleway; font-size: medium;">Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;"><b>D. Member Distribution Lists</b></p><p style="font-family: Raleway; font-size: medium;">A Distribution List can be created in a number of ways, including by importing Contacts, such as through a CSV or directly from your email client. Your Distribution Lists are stored on a secure 108Digital server. We do not sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. You may export (download) your Distribution Lists from 108Digital at any time.</p><p style="font-family: Raleway; font-size: medium;">If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.</p><p style="font-family: Raleway; font-size: medium;">If a Contact chooses to use the Forward link in an email campaign a Member sends, it will allow the Contact to share the Member’s email content with individuals not on the Member’s Distribution List. When a Contact forwards an email to a friend, we do not store the Contact’s email address or their friend’s email address, and no one is added to any Distribution List as a result of the Forward link. The Member who created the email campaign only sees an aggregate number of times their email campaign was forwarded by a Contact and does not have access to the email addresses used to share or receive that forwarded content.</p><p style="font-family: Raleway; font-size: medium;"><b>E. Other Data Protection Rights</b></p><p style="font-family: Raleway; font-size: medium;">You and your Contacts may have the following data protection rights:</p><p style="font-family: Raleway; font-size: medium;">To access, correct, update or request deletion of Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage many of your individual account and profile settings within the dashboard provided through the 108Digital platform, or you may contact us directly by emailing us at dataoffice@radar108.com</p><ul style="font-family: Raleway; font-size: medium;"><li>You can also manage information about your Contacts within the dashboard provided through the 108Digital platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Contacts.</li><li>In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us at dataoffice@radar108.com. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.</li><li>Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Contacts, you can segment your lists within the 108Digital platform to ensure that you only market to Contacts who have not opted out of receiving such marketing.</li><li>The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</li><li>We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.</li></ul><p style="font-family: Raleway; font-size: medium;"><b>3. Privacy for Contacts</b></p><p style="font-family: Raleway; font-size: medium;">This section applies to the information we process about our Members’ Contacts as a data controller pursuant to our legitimate business interests, as explained in the "Legal Basis for Processing" section below. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. 108Digital is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts.</p><p style="font-family: Raleway; font-size: medium;"><b>A. Information We Collect</b></p><p style="font-family: Raleway; font-size: medium;">The Personal Information that we may collect or receive about you broadly falls into the following categories:</p><p style="font-family: Raleway; font-size: medium;">(i) Information we receive about Contacts from our Members: A Member may provide Personal Information about you to us through the Services. For example, when a Member uploads their Distribution List or integrates the Services with another website or service (for example, when a Member chooses to connect their e-commerce account with 108Digital), or when you sign up for a Member’s Distribution List on a 108Digital signup form, they may provide us with certain contact information or other Personal Information about you such as your name, email address, address or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Member.</p><p style="font-family: Raleway; font-size: medium;">(ii) Information we collect automatically: When you interact with an email campaign that you receive from a Member or browse or purchase from a Member’s connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><ul style="font-family: Raleway; font-size: medium;"><li>Device information: We collect information about the device and applications you use to access emails sent through our Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.</li><li>Product usage data: We collect usage data about you whenever you interact with emails sent through the Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other electronic communications our Members send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.</li></ul><p style="font-family: Raleway; font-size: medium;">(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as social media platforms and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us, and we use this information to provide publicly available social media information about you to Members who have enabled the "Social Profiles" feature in their 108Digital accounts.</p><p style="font-family: Raleway; font-size: medium;"><b>B. Use of Personal Information</b></p><p style="font-family: Raleway; font-size: medium;">We may use the Personal Information we collect or receive about you for our legitimate business interests, including:</p><ul style="font-family: Raleway; font-size: medium;"><li>To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.</li><li>To protect the rights and safety of our Members and third parties, as well as our own. For example, sometimes we review the content of our Members’ email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms of Use. Our employees or independent contractors may review those particular email campaigns, which may include your contact information. This reduces the amount of spam being sent through our servers and helps us maintain high deliverability.</li><li>To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.</li><li>To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.</li><li>To prosecute and defend a court, arbitration, or similar legal proceeding.</li><li>To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.</li><li>To provide, support and improve the Services. For example, this may include sharing your information with third parties in order to provide and support our Services or to make certain features of the Services available to our Members. When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.</li></ul><p style="font-family: Raleway; font-size: medium;">For our data analytics projects. Our data analytics projects use data from 108Digital accounts, including your Personal Information, to provide and improve the Services. We use information, like your purchase history, provided to us by Members, so we can make more informed predictions, decisions, and products for our Members. For example, we use data from 108Digital accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. If you prefer not to share this data, you can opt out of data analytics projects at any time by emailing us at dataoffice@radar108.com</p><p style="font-family: Raleway; font-size: medium;">Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes.</p><p style="font-family: Raleway; font-size: medium;"><b>C. Cookies and Tracking Technologies</b></p><p style="font-family: Raleway; font-size: medium;">We and our partners may use various technologies to collect and store information when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the 108Digital platform was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Members’ email campaigns, and to provide analytics information and enhance the effectiveness of our Services.</p><p style="font-family: Raleway; font-size: medium;">Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;"><b>D. Legal Basis for Processing</b></p><p style="font-family: Raleway; font-size: medium;">We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services and our Website.</p><p style="font-family: Raleway; font-size: medium;"><b>E. Other Data Protection Rights</b></p><p style="font-family: Raleway; font-size: medium;">You may have the following data protection rights:</p><p style="font-family: Raleway; font-size: medium;">To access, correct, update or request deletion of your Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date.</p><ul style="font-family: Raleway; font-size: medium;"><li>You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at dataoffice@radar108.com. We will consider your request in accordance with applicable laws.</li><li>In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at dataoffice@radar108.com</li><li>You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</li></ul><p style="font-family: Raleway; font-size: medium;">As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by 108Digital as a processor on behalf of our individual Members, you should contact the relevant Member that is using the 108Digital Services, and refer to their separate privacy policies.</p><p style="font-family: Raleway; font-size: medium;">If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.</p><p style="font-family: Raleway; font-size: medium;">We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.</p><p style="font-family: Raleway; font-size: medium;"></p><p style="font-family: Raleway; font-size: medium;"><b>4. Privacy for Visitors</b></p><p style="font-family: Raleway; font-size: medium;"></p><p style="font-family: Raleway; font-size: medium;">This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.</p><p style="font-family: Raleway; font-size: medium;"><b>A. Information We Collect</b></p><p style="font-family: Raleway; font-size: medium;">(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to sign up for a free or paid 108Digital account, apply for a role with 108Digital, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.</p><p style="font-family: Raleway; font-size: medium;">The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.</p><p style="font-family: Raleway; font-size: medium;">(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.</p><p style="font-family: Raleway; font-size: medium;">Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;"><b>B. Use of Personal Information</b></p><p style="font-family: Raleway; font-size: medium;">We may use the information we collect through our Websites for a range of reasons, including:</p><ul style="font-family: Raleway; font-size: medium;"><li>To provide, operate, optimize, and maintain our Websites.</li><li>To send you information for marketing purposes, in accordance with your marketing preferences.</li><li>For recruitment purposes if you have applied for a role with 108Digital.</li><li>To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.</li><li>To manage our Websites and system administration and security.</li><li>To improve the navigation and content of our Websites.</li><li>To identify any server problems or other IT or network issues.</li><li>To process transactions and to set up online accounts.</li><li>To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.</li><li>To carry out research and development to improve our products and services.</li><li>To customize content and layout of the Websites.</li><li>To carry out other legitimate business purposes, as well as other lawful purposes.</li></ul><p style="font-family: Raleway; font-size: medium;">In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.</p><p style="font-family: Raleway; font-size: medium;"><b>C. Public Information and Third-Party Websites</b></p><p style="font-family: Raleway; font-size: medium;">Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.</p><p style="font-family: Raleway; font-size: medium;">Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.</p><p style="font-family: Raleway; font-size: medium;">Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.</p><p style="font-family: Raleway; font-size: medium;">Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.</p><p style="font-family: Raleway; font-size: medium;"><b>D. Cookies and Tracking Technologies</b></p><p style="font-family: Raleway; font-size: medium;">We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;"><b>E. Other Data Protection Rights</b></p><p style="font-family: Raleway; font-size: medium;">You have the following data protection rights:</p><p style="font-family: Raleway; font-size: medium;">To access, correct, update, or request deletion of your Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at dataoffice@radar108.com. We will consider your request in accordance with applicable laws.</p><p style="font-family: Raleway; font-size: medium;">In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at dataoffice@radar108.com.</p><p style="font-family: Raleway; font-size: medium;">Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.</p><p style="font-family: Raleway; font-size: medium;">You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</p><p style="font-family: Raleway; font-size: medium;">We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.</p><p style="font-family: Raleway; font-size: medium;"><b>5. General Information</b></p><p style="font-family: Raleway; font-size: medium;"><b>A. How We Share Information</b></p><p style="font-family: Raleway; font-size: medium;">We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):</p><p style="font-family: Raleway; font-size: medium;">(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.</p><p style="font-family: Raleway; font-size: medium;">For example, if it is necessary to provide Members something they have requested (like enable a feature such as Social Profiles), then we may share Members’ or Contacts’ Personal Information with a service provider for that purpose. Other examples include analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content.</p><p style="font-family: Raleway; font-size: medium;">These third-party service providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this privacy policy.</p><p style="font-family: Raleway; font-size: medium;">(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Members and Visitors with them for this purpose. We do not sell or market to any of our Members’ Contacts. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our Cookie Statement here.</p><p style="font-family: Raleway; font-size: medium;">(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.</p><p style="font-family: Raleway; font-size: medium;">(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.</p><p style="font-family: Raleway; font-size: medium;">(v) Any other person with your consent.</p><p style="font-family: Raleway; font-size: medium;"><b>B. Legal Basis for Processing Personal Information (EEA Persons Only)</b></p><p style="font-family: Raleway; font-size: medium;">If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.</p><p style="font-family: Raleway; font-size: medium;">However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.</p><p style="font-family: Raleway; font-size: medium;">If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.</p><p style="font-family: Raleway; font-size: medium;">If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.</p><p style="font-family: Raleway; font-size: medium;">Where required by law, we will collect Personal Information only where we have your consent to do so.</p><p style="font-family: Raleway; font-size: medium;">If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.</p><p style="font-family: Raleway; font-size: medium;"><b>C. Your Choices and Opt-Outs</b></p><p style="font-family: Raleway; font-size: medium;">Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.</p><p style="font-family: Raleway; font-size: medium;">Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your 108Digital account.</p><p style="font-family: Raleway; font-size: medium;"><b>D. Our Security</b></p><p style="font-family: Raleway; font-size: medium;">We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at dataoffice@radar108.com.</p><p style="font-family: Raleway; font-size: medium;">108Digital accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s 108Digital account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.</p><p style="font-family: Raleway; font-size: medium;"><b>E. International Transfers</b></p><p style="font-family: Raleway; font-size: medium;">(i) We operate in the United States</p><p style="font-family: Raleway; font-size: medium;">Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.</p><p style="font-family: Raleway; font-size: medium;"><b>F. Retention of Data</b></p><p style="font-family: Raleway; font-size: medium;">We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:</p><ul style="font-family: Raleway; font-size: medium;"><li>Whether we have a legal or contractual need to retain the data.</li><li>Whether the data is necessary to provide our Services.</li><li>Whether our Members have the ability to access and delete the data within their 108Digital accounts.</li><li>Whether our Members would reasonably expect that we would retain the data until they remove it or until their 108Digital accounts are closed or terminated.</li></ul><p style="font-family: Raleway; font-size: medium;">When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.</p><p style="font-family: Raleway; font-size: medium;"><b>G. California Privacy</b></p><p style="font-family: Raleway; font-size: medium;">Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email us at dataoffice@radar108.com.</p><p style="font-family: Raleway; font-size: medium;"><b>H. Changes to this Policy</b></p><p style="font-family: Raleway; font-size: medium;">We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.</p><p style="font-family: Raleway; font-size: medium;"><b>I. Questions &amp; Concerns</b></p><p style="font-family: Raleway; font-size: medium;">If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:</p><p style="font-family: Raleway; font-size: medium;">For EEA Residents:</p><p style="font-family: Raleway; font-size: medium;">For the purposes of EU data protection legislation, 108Digital LLC is the controller of your Personal Information. Our Data Protection Officer can be contacted at dataoffice@radar108.com</p><p style="font-family: Raleway; font-size: medium;">For Non-EEA Residents:</p><span style="font-family: Raleway; font-size: medium;">108Digital LLC<br>Attn. Privacy Officer<br>dataoffice@radar108.com<br>31 Country Way<br>Bethel CT 06801 USA</span><div><span style="font-family: Raleway; font-size: medium;"><br></span></div><div><p align="center" style="text-align: left; font-family: Raleway; font-size: 30px;"><span style="font-size: medium;">Last updated: November 28, 2018</span></p></div>

<div style=' background:#FFFFFF;color:#000000;font-family:Verdana;width:auto;padding:5px;'><span><p>We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Members (Section 2), Contacts (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.</p><p>If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.</p><p><b>1. The Basics</b></p><p><b>A. About Us</b></p><p>Radar108 is an online marketing platform (the "Services") operated by 108Digital LLC, a company headquartered in the State of Connecticut in the United States ("we," "us," "our," and "108Digital").</p><p>The Services enable our Members to, among other things, send and manage email campaigns and serve advertisements. We also provide other related services, such as real-time data analytics. Find out more about our Services here.</p><p><b>B. Key Terms</b></p><p>In this privacy policy, these terms have the following meanings:</p><p>"Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's Distribution List or about whom a Member has given us information. For example, if you are a Member, a subscriber to your email marketing campaigns would be considered a Contact.</p><p>"Distribution List" is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).</p><p>"Member" means any person or entity that is registered with us to use the Services.</p><p>"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.</p><p>"Website(s)" means any website(s) we own and operate (such as www.108Digital.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.</p><p>"Visitor" means any person who visits any of our Websites.</p><p>"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.</p><p><b>2. Privacy for Members</b></p><p>This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.</p><p><b>A. Information We Collect</b></p><p>The Personal Information that we may collect broadly falls into the following categories:</p><p>(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with 108Digital), or communicate with us in any other way.</p><p>We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.</p><p>This information may include:</p><p>Registration information: You need a 108Digital account to use the Services as a Member. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number (for example, if you are using two-factor authentication).</p><p>Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address, or information pertinent to other forms of payment. 108Digital will also maintain a record of your billing transactions and purchases, and any communications and responses.</p><p>Information we process on your behalf: In order to send an email campaign or use certain features in your account, you need to upload a Distribution List that provides us information about your Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.</p><p>(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><p>This information may include:</p><p>Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.</p><p>Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.</p><p>Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.</p><p>(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.</p><p>Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.</p><p>(iv) Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.</p><p>Device information: We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile apps or Services.</p><p>Product usage data: We may use mobile analytics software to better understand how people use our application. We may collect information about how often you use the application and other performance data.</p><p><b>B. Use of Personal Information</b></p><p>We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:</p><p>To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.</p><p>To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.</p><p>To communicate with you about your account and provide customer support. For example, if you use our mobile apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.</p><p>To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content of our Members’ email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms of Use. Our employees or independent contractors may review those particular email campaigns. This benefits all Members who comply with our Terms of Use because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability. Email was not built for confidential information. Please do not use 108Digital to send confidential information.</p><p>To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.</p><p>To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.</p><p>To prosecute and defend a court, arbitration, or similar legal proceeding.</p><p>To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.</p><p>To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.</p><p>To provide suggestions to you. This includes adding features that compare Members’ email campaigns, using data to suggest other publishers your Contacts may be interested in, or using data to suggest products or services that you may be interested in or that may be relevant to you or your Contacts. Some of these suggestions are generated by use of our data analytics projects, which are described below. For more information about our use of cookies and other tracking technologies for this purpose, and instructions about how to opt out of having data collected through the use of cookies, please see our Cookie Statement here.</p><p>For our data analytics projects. Our data analytics projects use data from 108Digital accounts, including Personal Information of Contacts, to provide and improve the Services. We use information like your sending habits and your Contacts’ details and purchase history, so we can make more informed predictions, decisions, and products for our Members. If you or your Contact prefers not to share this data, you can opt out of data analytics projects at any time by emailing us at dataoffice@radar108.com</p><p>For example, we use data from 108Digital accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. We will act as a data controller to process data for our data analytics projects in reliance on our legitimate business interests of improving and enhancing our products and services for our Members. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.</p><p>Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.</p><p>Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.</p><p><b>C. Cookies and Tracking Technologies</b></p><p>We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.</p><p>Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement here.</p><p><b>D. Member Distribution Lists</b></p><p>A Distribution List can be created in a number of ways, including by importing Contacts, such as through a CSV or directly from your email client. Your Distribution Lists are stored on a secure 108Digital server. We do not sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. You may export (download) your Distribution Lists from 108Digital at any time.</p><p>If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.</p><p>If a Contact chooses to use the Forward link in an email campaign a Member sends, it will allow the Contact to share the Member’s email content with individuals not on the Member’s Distribution List. When a Contact forwards an email to a friend, we do not store the Contact’s email address or their friend’s email address, and no one is added to any Distribution List as a result of the Forward link. The Member who created the email campaign only sees an aggregate number of times their email campaign was forwarded by a Contact and does not have access to the email addresses used to share or receive that forwarded content.</p><p><b>E. Other Data Protection Rights</b></p><p>You and your Contacts may have the following data protection rights:</p><p>To access, correct, update or request deletion of Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage many of your individual account and profile settings within the dashboard provided through the 108Digital platform, or you may contact us directly by emailing us at dataoffice@radar108.com</p><p>You can also manage information about your Contacts within the dashboard provided through the 108Digital platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Contacts.</p><p>In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us at dataoffice@radar108.com. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.</p><p>Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Contacts, you can segment your lists within the 108Digital platform to ensure that you only market to Contacts who have not opted out of receiving such marketing.</p><p>The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</p><p>We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.</p><p><b>3. Privacy for Contacts</b></p><p>This section applies to the information we process about our Members’ Contacts as a data controller pursuant to our legitimate business interests, as explained in the "Legal Basis for Processing" section below. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. 108Digital is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts.</p><p><b>A. Information We Collect</b></p><p>The Personal Information that we may collect or receive about you broadly falls into the following categories:</p><p>(i) Information we receive about Contacts from our Members: A Member may provide Personal Information about you to us through the Services. For example, when a Member uploads their Distribution List or integrates the Services with another website or service (for example, when a Member chooses to connect their e-commerce account with 108Digital), or when you sign up for a Member’s Distribution List on a 108Digital signup form, they may provide us with certain contact information or other Personal Information about you such as your name, email address, address or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Member.</p><p>(ii) Information we collect automatically: When you interact with an email campaign that you receive from a Member or browse or purchase from a Member’s connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><p>Device information: We collect information about the device and applications you use to access emails sent through our Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.</p><p>Product usage data: We collect usage data about you whenever you interact with emails sent through the Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other electronic communications our Members send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.</p><p>(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as social media platforms and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us, and we use this information to provide publicly available social media information about you to Members who have enabled the "Social Profiles" feature in their 108Digital accounts.</p><p><b>B. Use of Personal Information</b></p><p>We may use the Personal Information we collect or receive about you for our legitimate business interests, including:</p><p>To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.</p><p>To protect the rights and safety of our Members and third parties, as well as our own. For example, sometimes we review the content of our Members’ email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms of Use. Our employees or independent contractors may review those particular email campaigns, which may include your contact information. This reduces the amount of spam being sent through our servers and helps us maintain high deliverability.</p><p>To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.</p><p>To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.</p><p>To prosecute and defend a court, arbitration, or similar legal proceeding.</p><p>To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.</p><p>To provide, support and improve the Services. For example, this may include sharing your information with third parties in order to provide and support our Services or to make certain features of the Services available to our Members. When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.</p><p>For our data analytics projects. Our data analytics projects use data from 108Digital accounts, including your Personal Information, to provide and improve the Services. We use information, like your purchase history, provided to us by Members, so we can make more informed predictions, decisions, and products for our Members. For example, we use data from 108Digital accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. If you prefer not to share this data, you can opt out of data analytics projects at any time by emailing us at dataoffice@radar108.com</p><p>Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes.</p><p><b>C. Cookies and Tracking Technologies</b></p><p>We and our partners may use various technologies to collect and store information when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the 108Digital platform was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Members’ email campaigns, and to provide analytics information and enhance the effectiveness of our Services.</p><p>Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement here.</p><p><b>D. Legal Basis for Processing</b></p><p>We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services and our Website.</p><p><b>E. Other Data Protection Rights</b></p><p>You may have the following data protection rights:</p><p>To access, correct, update or request deletion of your Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date.</p><p>You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at dataoffice@radar108.com. We will consider your request in accordance with applicable laws.</p><p>In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at dataoffice@radar108.com</p><p>You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</p><p>As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by 108Digital as a processor on behalf of our individual Members, you should contact the relevant Member that is using the 108Digital Services, and refer to their separate privacy policies.</p><p>If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.</p><p>We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.</p><p><b>4. Privacy for Visitors</b></p><p>This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.</p><p><b>A. Information We Collect</b></p><p>(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to sign up for a free or paid 108Digital account, apply for a role with 108Digital, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.</p><p>The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.</p><p>(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.</p><p>Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.</p><p><b>B. Use of Personal Information</b></p><p>We may use the information we collect through our Websites for a range of reasons, including:</p><p>To provide, operate, optimize, and maintain our Websites.</p><p>To send you information for marketing purposes, in accordance with your marketing preferences.</p><p>For recruitment purposes if you have applied for a role with 108Digital.</p><p>To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.</p><p>To manage our Websites and system administration and security.</p><p>To improve the navigation and content of our Websites.</p><p>To identify any server problems or other IT or network issues.</p><p>To process transactions and to set up online accounts.</p><p>To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.</p><p>To carry out research and development to improve our products and services.</p><p>To customize content and layout of the Websites.</p><p>To carry out other legitimate business purposes, as well as other lawful purposes.</p><p>In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.</p><p><b>C. Public Information and Third-Party Websites</b></p><p>Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.</p><p>Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.</p><p>Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.</p><p>Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.</p><p><b>D. Cookies and Tracking Technologies</b></p><p>We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our Cookie Statement here.</p><p><b>E. Other Data Protection Rights</b></p><p>You have the following data protection rights:</p><p>To access, correct, update, or request deletion of your Personal Information. 108Digital takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at dataoffice@radar108.com. We will consider your request in accordance with applicable laws.</p><p>In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at dataoffice@radar108.com.</p><p>Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.</p><p>You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.</p><p>We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.</p><p><b>5. General Information</b></p><p><b>A. How We Share Information</b></p><p>We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):</p><p>(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.</p><p>For example, if it is necessary to provide Members something they have requested (like enable a feature such as Social Profiles), then we may share Members’ or Contacts’ Personal Information with a service provider for that purpose. Other examples include analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content.</p><p>These third-party service providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this privacy policy.</p><p>(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Members and Visitors with them for this purpose. We do not sell or market to any of our Members’ Contacts. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our Cookie Statement here.</p><p>(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.</p><p>(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.</p><p>(v) Any other person with your consent.</p><p><b>B. Legal Basis for Processing Personal Information (EEA Persons Only)</b></p><p>If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.</p><p>However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.</p><p>If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.</p><p>If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.</p><p>Where required by law, we will collect Personal Information only where we have your consent to do so.</p><p>If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.</p><p><b>C. Your Choices and Opt-Outs</b></p><p>Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.</p><p>Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your 108Digital account.</p><p><b>D. Our Security</b></p><p>We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at dataoffice@radar108.com.</p><p>108Digital accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s 108Digital account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.</p><p><b>E. International Transfers</b></p><p>(i) We operate in the United States</p><p>Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.</p><p><b>F. Retention of Data</b></p><p>We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:</p><p>Whether we have a legal or contractual need to retain the data.</p><p>Whether the data is necessary to provide our Services.</p><p>Whether our Members have the ability to access and delete the data within their 108Digital accounts.</p><p>Whether our Members would reasonably expect that we would retain the data until they remove it or until their 108Digital accounts are closed or terminated.</p><p>When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.</p><p><b>G. California Privacy</b></p><p>Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email us at dataoffice@radar108.com.</p><p><b>H. Changes to this Policy</b></p><p>We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.</p><p><b>I. Questions &amp; Concerns</b></p><p>If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:</p><p>For EEA Residents:</p><p>For the purposes of EU data protection legislation, 108Digital LLC is the controller of your Personal Information. Our Data Protection Officer can be contacted at dataoffice@radar108.com</p><p>For Non-EEA Residents:</p><p>108Digital LLC</p><p>Attn. Privacy Officer</p><p>dataoffice@radar108.com</p><p>31 Country Way</p><p>Bethel CT 06801 USA</p><span></div>