Privacy Policy

Introduction

This Privacy and Cookie Policy (“Policy”) applies to your use of:

The websites of Sourcepoint Technologies, Inc. (“we”, “us”, “our”) www.sourcepoint.com, www.altpayservices.com and all underlying content pages (“Websites”); and our services, including AltPay, that enable you to pay a publisher for the right to access and engage with content on publisher’s owned or controlled websites, apps, and other digital media properties of a publisher using the ad block software you have installed and are using in connection with such access (collectively, “Services”).

This Policy describes what data we collect when you use the Websites or the Services, why we collect it and what we do with it. It also explains the choices that you have with regard to how we use this data.The Policy applies in addition to the Terms of Service (“Terms”) applicable to your use of the Services. The Terms are available at http://altpayservices.com/terms.html. We may amend this Policy from time to time by uploading a replacement Policy to the Websites. We will inform you in advance of substantial changes to this Policy by e-mail. This Policy is current as of August 16, 2018.

‍Data Controller

‍Sourcepoint Technologies, Inc. is the data controller for any personal data provided to us or otherwise collected by us. You can contact us by writing to our corporate mailing address in 228 Park Avenue South, #87903, New York, NY 10003-1502, United States or using our contact form under https://www.sourcepoint.com/contact.

Use Of Your Personal Data

‍We will process your personal data in the following ways:

In connection with your use of the Websites

‍In connection with your use of the Websites, we process the following personal data:

Types Of Personal Data Why Processed (Purpose)

‍Data relating to your use of the Websites and/or the Services, obtained through your Internet browser, such as your (anonymized) IP address (which is a number that is automatically assigned to your computer when you use the Internet and can be used to identify the location from which your computer is connecting to the Internet) and usage data (e.g. what pages you view, where you click, what operating system you use).

To analyse, administer, support, improve and develop your access to and use of the Websites and the Services.Information on your use of the Websites that is tracked via cookies.

See section 4 on cookies and the link provided there for details.Personal data relating to your job application that you provide us with via the Websites, such as your name, contact details, academic curriculum, professional qualifications, professional experience, date of birth, gender and photos.

We process your personal data to evaluate your job application and to contact you in this regard.

In connection with marketing

‍In connection with marketing and news on our products, we process the following personal data:

‍Types Of Personal Data Why Processed (Purpose)

‍Your email address and country code provided by you.To send you information on our new products as well as the latest industry news & information that is relevant for your area.Your full name, email address, your company’s name and possible messages provided by you to be contacted by us to learn more about our technologies, e.g. Altpay or the CMP solution.

To contact you to provide you with information regarding our technologies that you would like to learn about.Depending on the Website: your name, email address, your company’s name, access code (optional for Altpay) and possible messages provided by you in our general contact forms.

To contact you to respond to your inquiry (e.g. regarding technical or business related matters)

In connection with our  Altpay product

‍In connection with our Altpay product, we process the following personal data:

‍Types Of Personal Data Why Processed (Purpose)

‍Your email address provided by you at the time you access the Services as well as your order, your contact and invoicing details such as price, name and address.

To enable us to provide you with access to the Services and invoice you.
To contact you regarding your access to the Services or to notify you of important changes to the Services.
To provide you with a list of access codes and your payment history for your AltPay purchases.

Your email address provided by you when you suggest a new website for our Altpay technology. To assess the suggested website and contact you in this regard.Your email address and related information to your use of the Altpay Service. To send you marketing emails about products or services of Sourcepoint similar to the Services you subscribed to (see marketing above.

How We Use Cookies

‍The Websites use cookies and similar technologies. These cookies are used to make it easier for you to use the Websites during future visits, monitor traffic on our Websites, personalise the content of the Websites for you and provide you with interest-based advertising. Please read more about the cookies we use on the Websites in our Cookie preferences information https://www.sourcepoint.com/terms-of-use and http://altpayservices.com/terms.html.

‍Recipients Of Your Personal Data

Service providers

‍We share information with vendors who assist us with hosting the Websites, sending newsletters, storing data in clouds, website tracking (cookies and similar technologies) and processing your job applications.  In some cases, we authorize these vendors to collect data on our behalf.

‍Transfers to third parties

‍Payment processing Where you elect to access the Altpay Services, our payment services provider Braintree Payments, a part of PayPal, Inc. (“Braintree”), will process payment information (including card number, security code associated with your card, expiry date) that you provide to Braintree in order to enable payment processing services that you request from us. To enable payment with Braintree, we will inform Braintree about your name and the invoice details. We will receive from Braintree only general information about your payment (e.g. method used, some digits of your credit card), but not your complete payment information.

‍Legal requirements Moreover, in processing your personal data, we may disclose your personal data: if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of us or our employees, or of other users of the Websites and/or the Services. We process your personal data for these purposes either to comply with legal obligations or based on our legitimate interests in safeguarding us and others; to potential purchasers or investors (and their advisers) on the sale of the whole or any related part of our business and/or assets. Depending on the stadium of the transaction such transfers may be based on our legitimate interests to conclude the transaction or as disclosure is necessary for the performance of the contract between you and us.

‍Security Measures We employ security measures to protect your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. The transmission of information using Wi-Fi networks and cellular data networks may not be completely secure. Although we will use reasonable endeavours to protect your personal data, we cannot guarantee the security of data transmitted to us using the Websites and/or the Services and any such transmission is made at your own risk.

‍Further information for EU Users The following additional information and rights only apply to users who visit the Websites from the EU/EEA.

Legitimate Interests “Legitimate interests” means the interests of our company in conducting and managing our business. For example, we may have a legitimate interest in processing personal data of our customers for direct marketing purposes and to analyse how the Websites and the Services are being used by you.When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law.You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section below.

Legal bases for processing and retention of personal data In addition to the information provided in sec. 3 (“Use Of Your Personal Data”), please find details on the legal bases for processing your personal data and on retention periods for your personal data below:

Use of Websites

Purpose Legal Basis For Processing Retention period  To analyse, administer, support, improve and develop your access to and use of the Websites and the Services.It is in our legitimate interests to analyse how the Websites and the Services are being used by you as a user of our services. This helps us improving the Websites and our services. For more information about what we mean by legitimate interests, and when we may process your data for our legitimate interests, please see “Legitimate Interests” section below.

Please check section 4 on cookies and the link provided there to learn more about how long this personal data is stored. Purposes related to cookies as explained in section 4 on cookies and the link provided there. See section 4 on cookies and the link provided there for details.See section 4 on cookies and the link provided there for details. We process your personal data to evaluate your job application and To contact you in this regard.

Processing of this data is necessary in preparation of the performance of a contract between you and us in connection with a possible employment. If your application is successful, we retain the personal data for the duration of your employment with us, and beyond based on statutory retention periods. If we do not employ you we will delete your personal data when accordant time limits for legal actions have lapsed.

‍Marketing

Purpose Legal Basis For Processing Retention period

‍To send you information on our new products as well as the latest industry news & information that is relevant for your area.If you subscribe to receive news via email from us, the processing is based on your consent.

If you are already a customer who has purchased from us, we also process your email address to offer similar products or services to you that may be of interest to you. Such processing is based on our legitimate interest to conduct direct marketing. You may always object to such processing.

You have the right to opt-out from marketing at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our marketing emails.

We will process this personal data for as long as you show interest in our services and newsletters or until you opt out/withdraw your consent.To contact you to provide you with information regarding our technologies that you would like to learn about.Processing of this personal data is necessary for the performance of a (quasi-) contract between you and us in connection with your inquiry. We process your personal data to handle your inquiry and to provide you with the required information.We retain this personal data for the time required to respond to your request and, where applicable, as required or permitted by statutory law.To contact you to respond to your inquiry (e.g. regarding technical or business related matters)Processing of this data is necessary for the performance of a (quasi-) contract between you and us in connection with your inquiry, comment or complaint.We retain this personal data for the time required to respond to your request and, where applicable, as required or permitted by statutory law, e.g. for financial statements or legal claims.

‍Altpay product

Purpose Legal Basis For Processing (for EU users) Retention period To enable us to provide you with access to the Services and invoice you. To contact you regarding your access to the Services or to notify you of important changes to the Services. To provide you with a list of access codes and your payment history for your AltPay purchases.

Processing of your email address is necessary for the performance of the contract between you and us in connection with the Services. If you do not provide us with your email address, we will not be able to provide you with access to the Services and to contact you regarding your access or changes to the Services.

We retain this personal data as long as you use our Services and, where applicable, as required or permitted by statutory law, e.g. for financial statements or legal claims.To assess the suggested website and contact you in this regard.It is in our legitimate interests to learn about websites that could benefit from our Altpay technology as this helps us expanding our business.We retain this personal data for as long as required to evaluate your suggestion and, where applicable, as required or permitted by statutory law.To send you marketing emails about products or services of Sourcepoint similar to the Services you subscribed to (see marketing section above).To offer similar products or services to you that may be of interest to you. Such processing is based on our legitimate interest to conduct direct marketing. You may always object to such processing.

‍You have the right to opt-out from marketing at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our marketing emails.

‍We will process this personal data for as long as you show interest in our services and newsletters or until you opt out.

‍Retention Policy

‍We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Policy, or for the duration required by law, whichever is the longer. Please see section 7.2 above for more details.

Recipients outside the EU/EEA

‍Some of the above (sec. 5) listed recipients may be located outside the European Union/the European Economic Area. In such cases, we use EU standard contractual clauses, or recipients that are Privacy Shield or Binding Corporate Rules certified as a safeguard to establish an adequate data protection level in the third country. You may ask to receive a copy of the safeguard by contacting us as described in the “Questions And Contact Details” section below.

‍Your Rights

‍You have the following rights in relation to the personal data we hold about you, given that the accordant preconditions are fulfilled:

‍Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your personal data with others, we will let them know about the rectification where possible.

‍Right to erasure: You may ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we have shared your data information with others, we will let them know about the erasure where possible.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or object to us processing it (but not continuing to store it). We will tell you before we lift any restriction on processing. If we have shared your personal data with others, we will let them know about the restriction where possible.

Right to data portability: You have the right to obtain personal data you have provided to us, that we are processing based on your consent or because necessary to perform a contract with you, in a structured, commonly used and machine-readable format, and to reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your personal data, and we will do so, if we are: relying on our own or someone else’s legitimate interests to process your personal data except if we can demonstrate compelling legal grounds for the processing (for more information about what we mean by legitimate interests, and when we may process your data for our legitimate interests, please see “Legitimate Interests” section above); or processing your personal data for direct marketing.

Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and us.

Right to withdraw consent: If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.

Right to lodge a complaint with the data protection authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Questions And Contact Details” section below. EU representative Data subjects in the EU may also contact our office in Germany in Friedrichstraße 68, 10117 Berlin, Germany.

Questions And Contact Details If you have any questions about this Policy or our data processing practices, you can contact us using the contact details available at https://www.sourcepoint.com/contact, by writing to Sourcepoint Technologies, Inc.  228 Park Avenue South, #87903, New York, NY 10003 -1502, USA,or to our German office named in section 7.6

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