EU-U.S. Privacy Shield Framework

ASIGNAL NETWORKS, INC. d/b/a Fiksu Media Group ("Asignal Networks", or “we”, or “our”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Asignal Networks has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

This Privacy Shield Policy Statement (this “Policy”) applies to all personal information received by Asignal Networks in the United States from European Union member countries, in any format, including electronic, paper or verbal.

In compliance with the EU-US Privacy Shield Principles, Asignal Networks commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this Policy should first contact Asignal Networks at: info@fiksumediagroup.com

Asignal Networks has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

For complaints left unresolved by all other available channels, individuals may invoke binding arbitration before a Privacy Shield Panel.

US-Swiss Safe Harbor

Asignal Networks complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Asignal Networks has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this Policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/

This Safe Harbor Privacy Policy Statement applies to all personal information received by Asignal Networks in the United States from Switzerland, in any format, including electronic, paper or verbal.

In compliance with the US-Swiss Safe Harbor Principles, Asignal Networks commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this Policy should first contact Asignal Networks at: info@fiksumediagroup.com

Asignal Networks has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Definitions

For purposes of this Policy, the following definitions shall apply:

Privacy Principles

The privacy principles in this Policy have been developed based on the EU-U.S. Privacy Shield Framework and the US-Swiss Safe Harbor Framework.

Notice

Asignal Networks is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Asignal Networks may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Where Asignal Networks collects personal information directly from individuals in the European Economic Area (EEA), it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Asignal Networks discloses that information, the choices and means, if any, Asignal Networks offers individuals for limiting the use and disclosure of personal information about them, and how to contact Asignal Networks. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Asignal Networks, or as soon as practicable thereafter, and in any event before Asignal Networks uses or discloses the information for a purpose other than that for which it was originally collected.

Specifically – Asignal Networks is a marketing service company focusing on the mobile application marketplace.

Website of Asignal Networks

When individuals use certain features of fiksumediagroup.com (the “Website”), Asignal Networks may collect personally identifiable information from them that may include their email address and mobile phone number. Asignal Networks automatically collects non-personally identifiable information such as IP addresses and Website usage information from them when they visit this Website.

Asignal Networks may disclose and use personally identifiable information to resolve disputes, troubleshoot problems, enforce its Terms of Service or to alert individuals to changes in its policies or agreements that may affect their use of its Website. Asignal Networks may also disclose personally identifiable information when, in its sole discretion, it believes it is necessary or appropriate, in connection with a sale or transfer of some or all of its assets in the Website, or when, in good faith, it believes that the law requires it to do so.

Asignal Networks Application Marketing Service

Asignal Networks buys mobile advertising space on behalf of its clients. When individuals click on a client ad or application link delivered by Asignal Networks, Asignal Networks servers receive and store a mobile identifier (“Mobile ID”) which is a pseudonymous number that is associated with their mobile device. Asignal Networks cannot use the Mobile ID to identify them personally, but it does enable Asignal Networks to deliver relevant advertising to each mobile device. In addition to the Mobile ID, Asignal Networks collects information about the kind of mobile device they use (e.g., iPhone, Samsung), the operating system for their mobile device (e.g., Android, Apple O/S), IP address, the applications they download from Asignal Networks clients, when, how, and how often they use those applications.

Asignal Networks uses their device’s Mobile ID and other information about client applications they download to help their clients understand which ads are most effective at generating downloads of the client’s applications. Asignal Networks also use your Mobile ID and the information associated with their device Mobile ID over time (e.g., the applications they download, when and how they use those applications, and any publisher-provided demographic data) to enhance our services and to select Asignal Networks client ads that are most likely to be of interest to them.

Mobile Information Sharing, Onward Transfer

Asignal Networks discloses the information in its systems from its application marketing services, including Mobile IDs and/or the information associated with Mobile IDs over time for the following purposes:

Except as described above Asignal Networks does not share data to non-Agent third parties. Where Asignal Networks receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

Choice

Asignal Networks will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Individuals with concerns about how their data is being used can contact Privacy Officer of Asignal Networks at the address below.

Data Integrity

Asignal Networks will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Asignal Networks will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Transfers To Agents

Asignal Networks will obtain assurances from its agents that they will safeguard personal information consistently with this Policy, by means of a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Principles, Where Asignal Networks has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Asignal Networks will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Asignal Networks is potentially liable.

Access and Correction

Asignal Networks provides individuals the right to access personal information that it holds about them. In addition, Asignal Networks will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. In most cases personal information can be accessed and modified by the individual by logging into their account and self-managing their personal information. In an instance where the specific personal information cannot be self-managed the individual should contact the site administrator for support.

Security

Asignal Networks will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Asignal Networks will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Asignal Networks determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

Limitation on Application of Principles

Adherence by Asignal Networks to these privacy principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Privacy Policy

Asignal Networks recognizes the importance of maintaining the privacy of information collected online and has created a Privacy Policy (the “PP”) governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the EEA or Switzerland to the U.S., the PP is subordinate to this Policy. However, the PP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Privacy Policy of Asignal Networks can be found at http://fiksumediagroup.com/privacy-policy.html.

Contact Information

Questions or comments regarding this Policy should be submitted to the Privacy Office of Asignal Networks by mail to:
ASIGNAL NETWORKS, INC.

126 Newbury Street
6th Floor
Boston, MA 02116

Or by e-mail to info@fiksumediagroup.com

Changes to Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Framework and US-Swiss Safe Harbor Principles.

EFFECTIVE DATE: November 29, 2016