Privacy Policy

Last Updated: June 7, 2023

This Privacy Policy (“Privacy Policy” or “Policy”) explains how aShareX, Inc. aShareX Fine Art, LLC, aShareX Management, LLC, aShareX Holdings, LLC and their subsidiaries and affiliated companies (collectively, the “Company, “we,” “us” or “our”) may gather, collect, record, hold, distribute, share, disclose or otherwise use your personal information and the rights and choices you have in relation to your personal information.

This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline (collectively, the “Services,” including through our website at www.aShareX.com all corresponding webpages, software applications or mobile applications that link to this Privacy Policy (collectively, the “Site”), and when you interact with our advertising and applications on third-party websites and services, if the advertising and applications include links to this Privacy Policy.

By using our Site or Services, you agree to the collection and use of your personal information in accordance with this Privacy Policy and our Terms of Use. If you do not agree to all of the terms of this Privacy Policy or the Terms of Use, then you should not use or access our Site or Services.

We may update this Privacy Policy from time to time and make changes to information previously collected, as permitted by law. If we make material changes, we will post the updated Privacy Policy on this page with an “Updated” effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our Services.

Please note that our Site may contain links to third-party websites, such as social media pages and auction house sites. These links are intended for your convenience only. These third-party websites and services are not related to the Company and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage users to read the privacy policies of all websites they visit.

1. INFORMATION WE COLLECT

When you access or use our Services, we may, either directly or by using our service providers, gather, collect, record, hold, distribute, share, disclose or otherwise use personal information about you which you provide to us. Personal information is any information that relates to you, identifies you personally, or could be used to identify you including your name, mailing address, email address and telephone number. Personal information does not include anonymized or aggregated information. The types of personal information that we may collect about you are described below.

1.1. INFORMATION YOU VOLUNTARILY PROVIDE TO US. We collect personal information that you voluntarily provide to us when you:

complete forms on the Site, or in relation to our Services, or you contact us via telephone;
create an account with us;
purchase or otherwise request any of the Company’s offerings or services;
request any customer support;
request any information from or about the Company, such as a newsletter, e-alert, or any other information about our offerings, services, events or business partners;
communicate with any representative of our Company;
communicate with us via third-party social media sites;
participate in any event bby us;
maintain employment with the Company;
apply for a job with the Company; or
otherwise communicate with us in any other way, whether in writing or orally.

In these instances, the types of personal information that we may collect from you may include:

Your name;
Mailing address and/or billing address;
E-mail address;
Phone (or mobile) number;
Date of birth or age;
Credit or debit card number and other information about the same (if you make a payment either directly to us or by using a third-party payment provider that handles payments and will receive your payment card information);
Information about your bank or checking account (if you make a payment through your bank transfer);
Information, including “know your customer,” financial and credit information, you provide to us, including when registering on our Site or when purchasing any of our offerings or services, including product or service parameters or preferences you provided when making a purchase;
Your social security number;
Information you provide when you report a problem with our Site or a purchase or other transaction with us by email, our Site, telephone, in writing or through other means;
Records and copies of your correspondence if you contact us; or
Transaction history with us.
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1.2. INFORMATION WE COLLECT BY OTHER MEANS

1.2.1. INFORMATION AUTOMATICALLY COLLECTED

When you access or otherwise use our Site or Services, we automatically collect certain personal information about you, including:

Device Information. We (or our service providers) may collect information about the computer, tablet, phone or other device you use to access any of the Services, including the Internet Protocol address, hardware models, operating system and version, mobile network information and other unique device identifiers.
Interaction with Website. We (or our service providers) may collect information about your browsing history and interaction with our Site.
Cookies and other Web-based Tracking Technologies: We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by your web browser on your computer or mobile device (hard drive) that helps us to improve the way we deliver our Services to you, helps us improve your overall experience using our Services, and/or helps us analyze the areas and features of our Services that are most popular or to detect fraud. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by us (or our service providers) during your visit to the Sites or other Services in order to improve your individual experience as a user of our Site and Services, or to generally improve or enhance the overall functionality of the Services.
Social Media Information. If any of our Services offer any social media features, such as the Facebook Like buttons or similar social media interactive mini-programs, these features may collect your Internet Protocol address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third-party or hosted directly on our Services. Your interactions with these features may be governed by the privacy policies of the company providing it.
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1.2.2. INFORMATION WE RECEIVE FROM THIRD PARTIES IF APPLICABLE TO FURTHER INFORMATION

We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our Services to you, and prevent or detect fraud.

We may also collect personal information about you that we receive from our partners, group members or other third parties. For example, if you intend to, or make, a purchase from us, we may receive information about your creditworthiness from our financial service providers; or if you visit one of our social media accounts, the respective provider may provide us with statistical information regarding your use of our account. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you recommendations and special offers that are more likely to interest you.

1.2.3 THIRD PARTY COLLECTION VIA WEBSITE

A number of third-party companies may collect personal information about you during your use of our Site, through the use of pixels. These third parties are generally advertising / marketing partners, social media partners, auction partners, broker-dealers and analytics providers. The following is a non-exhaustive list of these third parties, along with links to their specific privacy policies:

The type of personal information gathered directly by these third parties includes IP address, unique personal identifier, online ID, consumer history / tendency, interaction with the website and preferences, characteristics, and behavioral information.

2. HOW WE USE YOUR INFORMATION

‍We will only use your personal information as described in this Privacy Policy or our Terms of Use or as disclosed to you prior to such processing taking place. The purposes for which we may use or share your personal information include to:

Process your purchase transactions, fulfill your orders, process bidding orders and share purchases;
Analyze your credit worthiness;
Send support and administrative messages, and respond to your comments, questions, and customer service requests;
Communicate with you about offerings, services and events offered by us and others, and provide news and information we think will be of interest to you, subject to the applicable law;
Monitor and analyze trends, usage, and activities in connection with our Services;
Conduct screenings or to otherwise protect against fraud or unauthorized transactions, including by identifying potential unauthorized users or hackers;
Personalize your experience and the advertisements and content you see when you use any Services based on your preferences, interests, and browsing and purchasing behavior;
Comply with applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting), or as may be requested under any subpoena;
Keep you secure and safe while using our Services, which requires us to process your personal information to combat spam, malware, malicious activities or security risks;
Improve and enforce our security measures;
Facilitate your use of various social media sharing features or other integrated tools (such as the Facebook “Like” button) which you may use as part of social media pages;
Facilitate any contests, events or promotions and process and deliver entries and rewards;
Process your information to evaluate your application if you apply for a job or to provide services to the Company;
Carry out any other purpose described to you at the time your personal information is collected; or
Use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law or regulation (including without limitation tax reporting).
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3. SHARING AND DISCLOSURE OF INFORMATION

We may share or disclose your personal information in the following circumstances, and in all countries mentioned within this Privacy Policy:

Affiliates and Subsidiaries. We may disclose your information with our affiliates or subsidiaries for any of the purposes described herein.
Service Providers and Contractors. We may share or disclose your personal information with our service providers, contractors or other third-party vendors that we retain in connection with the provision of the Services, including without limitation the following types of persons that we may engage:

Email, internet or other telecommunication service providers;
Cloud or other data storage and hosting service providers;
Third-party payment service providers, including without limitation third-party credit card processors (see “Third-Party Application Providers” below);
Analytics companies who assist us with various types of data analytics (see “Analytics Partners” below);
Auction partners;
Third party shippers; or
Other third-party contractors we engage to assist us in providing our Services.

Auction Partners. Our auction partners may receive personal information, such as your name and contact information from us. In turn, our auction partners may choose to market directly to you.
Third Party Application Providers. If a third-party application is used to support our Services, we may share or disclose your information to such third-party application providers, including without limitation third-party credit card processors or other third-party payment service providers.
Analytics Partners. We may use services provided by third-party analytics service providers or by using one of their tools, such as Google Analytics, to collect and process certain analytics data. These services may also collect data about your use of other websites, apps and online resources. Google Analytics is a web analytics service offered by Google LLC, a corporation domiciled in the USA (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com/privacy. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: tools.google.com/dlpage/gaoptout.
Advertising Partners. We may work with third-party advertising companies (collectively, “Advertising Partners”) to provide you with advertisements or other information that we think may interest you. These Advertising Partners may set or access their own cookies, pixel tags or similar technologies on our Site and Services or they may otherwise collect or have access to data about you which they may collect over time and across different online services. These Advertising Partners may also provide us with their own independent data about potential customers and such data could include data about you previously collected by the Advertising Partner.
Social Media Features. Our Services may offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let you share actions that you take on our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings you establish with the entity that provides the social sharing feature.
Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer your personal information to the Company’s professional advisors such as attorneys or accountants or other advisors (collectively, “Outside Professionals”), potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your personal information following any of these events will be governed by this Privacy Policy.
As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose your personal information if we believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any securities or tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety. We may be required to disclose your information to (a) taxing authorities as part of our tax reporting requirements, or (b) law enforcement authorities or other governmental agencies or via subpoena.
Company’s Outside Professional Advisors. We may share or disclose your personal information with any of the Company’s Outside Professionals to facilitate their advice.
Consent. We may share or disclose your personal information with your permission.

4. YOUR CHOICES

4.1. COMMUNICATION PREFERENCES

We may send you communications, messages or updates related to your transactions, security, the Company, our Services and Site, and promotions, events or other activities. If you do not wish to receive non-transaction/non-security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication you received from us, or send an email message to privacy@asharex.com stating that you no longer want to receive these communications directly from us (an “Opt-Out”). Users from the EEA, the United Kingdom, Switzerland, Singapore, South Africa, Saudi Arabia, the United Arab Emirates, or Canada will, if required by applicable law, receive such communications only after having consented hereto. Please note that Opt-Out and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to Opt-Out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

4.2. CORRECTION

You have the right to correct your personal information that you shared with us on our Site or Services. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is your responsibility to correct, update, or modify any and all of your personal information as it appears in, or otherwise stored by, our Site, or as used in connection with our Services.

4.3. DO NOT TRACK: SPECIAL ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

Some Internet browsers, such as Internet Explorer, Firefox, and Safari include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

5. CHILDREN

This Site and our Services are not directed to children under the age of 16, and we do not knowingly collect any personal information from them. We ask that minors under the age of 16 not submit any personal information to us, and if you have reason to believe any such minor has provided us with personal information, please contact us at privacy@asharex.com and request that such information be deleted from our records.

6. DATA SECURITY

We have implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to us is stored on our secure servers behind firewalls, or on secure systems of our vendors and service providers. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors, who will use appropriate security procedures.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential and you should not share it with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other jurisdictions where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States, the UK and/or the EEA and process it there.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws and ensuring the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Site or Services.

8. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and all pertinent amendments and regulations, below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your personal information, where we obtain the personal information, and the third-parties with whom we may share your personal information.

8.1 NOTICE AT COLLECTION

We generally collect the following categories of personal information about you when you use our Site or Services:

Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.
Customer records such as name, social security number, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Characteristics of protected classifications under California or federal law such as age.
Commercial information such as records of offerings or services purchased, obtained, or considered by you.
Internet or other electronic information regarding your browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
Sensitive personal information to the extent you have configured your device to permit us to collect such information.

For more information about the personal information we collect and how we collect it, please refer to Section 1, above.

We collect your personal information for the business purposes described in Section 2, above. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the purpose for which the personal information was collected or another purpose that is compatible with the context in which the personal information was collected.

The categories of third-parties with whom we may share your personal information are listed in Section 2, above.

8.2 LENGTH OF RETENTION

The length of time we retain customer personal information collected from you depends on a variety of factors, including the following:

Whether you have consented to us maintaining and using it;
Whether and to what extent you have restricted or limited the use in some fashion pursuant to your particular consumer rights;
Whether and to what extent the information is still relevant to our legitimate business purposes within the use categories of the privacy policy; and
Whether we are actually executing that practice in the moment to accomplish the legitimate business purpose.

We do not keep or use personal information that does not serve our legitimate business purpose and comply with this privacy policy.

8.3. PRIVACY RIGHTS

Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, correct, delete opt-out of sales or sharing, or limiting the use of sensitive personal information. This means we cannot, among other things:

Deny offerings or services to you;
Charge different prices or rates for offerings or services, including through the use of discounts or other benefits or imposing penalties;
Provide a different level or quality of offerings or services to you; or
Suggest that you receive a different price or rate for offerings or services or a different level or quality of offerings or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Right to Access. You have the right to request that we disclose certain information to you about the Company’s collection and use of your personal information (and sensitive personal information) over the past 12 months. Specifically, you can request the following information:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose is for collecting or selling that personal information.
The categories of third-parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
If we sold or disclosed your personal information for a business purpose:

In the case of sales, a list identifying the personal information categories that each category of recipient purchased; and
In the case of disclosures, a list identifying the personal information categories that each category of recipient obtained.

A copy of the specific personal information we collected about you during the 12 months before your request.
The right to access your information is not absolute and subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our system of networks.
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Right to Deletion. You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for the Company or its service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise exercise our rights or perform our obligations to you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug offerings to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
Comply with a legal obligation.
Make other internal or lawful uses of that information that are compatible with the context in which you provided it.
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Right to Correction. You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right to Opt-Out of Selling or Sharing of Personal Information. As described in this Privacy Policy, in certain situations we may share or sell your personal information with our partners, third-parties or affiliates for marketing or other purposes and could receive a benefit for such sharing. As a California resident you have the right to opt-out of such sharing or selling. Email privacy@asharex.com for the Company’s notification to California residents about their right to opt-out of any such sharing or sale, and to exercise this right.

Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested offerings or services. You also have the right to direct to limit the use and disclosure of your sensitive personal information at any time (the "right to opt-out"). To exercise this right, you (or your authorized representative) may submit a request to us by emailing privacy@asharex.com.

Please note that we can use sensitive personal information for the following purposes, and you do not have the right to limit the use and disclosure of sensitive personal information being used in the following ways:

To perform the services or provide the offerings reasonably expected by an average consumer who requests those offerings or services.
To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
To perform services on behalf of the business, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
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8.4. EXERCISING YOUR RIGHTS

To exercise your right to access, data portability, correction, deletion, opt-out and or limit use / disclosure rights, you must submit a verifiable consumer request to us by:

Emailing the Company at: Privacy@aShareX.com

You do not need to create an account with us to exercise your consumer rights. We will only use personal information provided in consumer requests to review and comply with the specific request.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request to the Company related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
Provide sufficient information that allows the Company to reasonably verify that you are the person about whom we collected personal information or an authorized representative, and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

9. ADDITIONAL NOTICE TO COLORADO RESIDENTS

‍Under the Colorado Privacy Act (the “CPA”), if you are a resident of Colorado, acting only in an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

9.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal data as defined in the CPA means any information that is linked or reasonably linkable to you. This Privacy Policy, including this Section 9, describes our practices concerning the collection and processing of personal data (therein also referred to as “personal information”), including:

the categories of personal data that we collect or process (Section 1);
the purposes for processing the personal data (Section 2);
the categories of personal data shared with third parties (Section 3);
the categories of third parties with whom we share personal data (Section 3); and
our sale of personal data to third parties or targeted advertising (Section 3, therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)
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‍9.2 Right of Access.

You have the right to confirm whether or not we are processing personal data concerning you and to access your personal data.

9.3 Right to Correction.

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

9.4 Right to Deletion

You have the right to delete personal data concerning you.

9.5 Right to Data Portability.

When exercising the right to access personal data, you have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

9.6 Right to Opt Out.

You have the right to opt out of the processing of your personal data for (a) targeted advertising, (b) sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We may disclose your personal data to third parties for targeted advertising purposes. This means the targeting of advertising to you based on your personal data that we obtain from your activity across businesses, distinctly-branded websites, applications, or services, other than our business, distinctly-branded website, application, or service. We may share personal data with advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or your activity on other websites or apps.

You have the right to opt-out of the processing of your personal data for targeted advertising or profiling and you may exercise your right by emailing privacy@asharex.com. If you exercise your right to opt-out of the processing of your personal data for targeted advertising or profiling, we will refrain from processing your personal data for targeted advertising or profiling, unless you subsequently provide express authorization for the sharing of your personal data.

We may disclose your personal data to third parties in exchange for monetary or other consideration. We may sell your personal data to advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or to recommend our services and offerings to you based on your activity on other websites or apps. We may sell your personal data to data analytics providers who may use your personal data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of your personal data and you may exercise your right by emailing privacy@asharex.com. If you exercise your right to opt-out of the sale of your personal data, we will refrain from selling your personal data, unless you subsequently provide express authorization for such sale.

We will process any opt-out preference signal that is (a) in a format commonly used and recognized by businesses (for example, in an HTTP header field), and (b) sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of personal data for your browser or device, and, if known, for you.

9.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) personal data revealing your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; (b) the processing of genetic or biometric data for identification purposes and (c) personal data from a known child. We will not process your “Sensitive Data” without your consent or in the case of a known child, the consent or a parent or lawful guardian.

9.8 How to Exercise your CPA Rights

Unless otherwise specified, to exercise any of your rights described in this Section 9, please submit your request to us at privacy@asharex.com with the subject “CPA Consumer Request.” We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 day response period, together with the reason for the extension.

If we decline to take action on your request, we shall inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal.

Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decisions. If we deny the appeal, you may contact the Colorado Attorney General at https://complaints.coag.gov/s/?varCFT=2 or (720) 508-6000.

We shall provide information in response to your request free of charge, except that, for a second or subsequent request within a 12-month period, we may charge an amount as provided in the CPA. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

You may designate another person to serve as your authorized agent and act on your behalf. We will comply with an opt-out request received from an authorized agent if we are able to verify, with commercially reasonable effort, your identity and the authorized agent’s authority to act on your behalf.

10. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your personal data.

10.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal data as defined in the VCDPA means any information that is linked or reasonably linkable to you. Our Privacy Policy, including this Section 10, describes our collection and processing of personal data (therein also referred to as “personal information”) practices, including:

the categories of personal data that we collect or process (Section 1);
the purposes for processing the personal data (Section 2);
the categories of personal data shared with third parties (Section 3);
the categories of third parties with whom we share personal data (Section 3); and
our sale of personal data to third parties or targeted advertising (Section 3, therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)
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‍10.2 Right of Access.

You have the right to confirm whether or not we are processing personal data concerning you and to access your personal data.

10.3 Right to Correction.

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

10.4 Right to Deletion

You have the right to delete personal data concerning you.

10.5 Right to Data Portability.

10.6 Right to Opt Out.

You have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We may disclose your personal data to third parties in exchange for monetary consideration. We may share personal data with advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or to recommend our services and offerings to you based on your activity on other websites or apps. We may share your personal data with data analytics providers who may use your personal data for their own behavioral advertising analysis purposes.

10.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (b) the processing genetic or biometric data for the purpose of uniquely identifying you; (c) the personal data from a known child; or (d) precise geolocation. We do not process “Sensitive Data.” If we intend to do so, we will obtain your consent or in the case of a known child, the consent as required by the federal Children’s Online Privacy Protection Act.

10.8 How to Exercise your VCDPA Rights

Unless otherwise specified, to exercise any of your rights described in this Section 10, please submit your request to us at privacy@asharex.com with the subject “VCPDA Consumer Request.” We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 day response period, together with the reason for the extension.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

Within a reasonable time, not to exceed 60 days, after you have received a notice that we have declined to take action your request, you may appeal by sending your appeal to privacy@asharex.com with the subject “VCPDA Appeal.” We shall respond to you within 60 days of receipt of the appeal in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If we deny your appeal, you may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint or call (804) 786-2042.

11. ADDITIONAL NOTICE TO UTAH RESIDENTS

Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below.

11.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal data as defined in the UCPA means any information that is linked or reasonably linkable to you. Our Privacy Policy, including this Section 11, describes our collection and processing of personal data (therein also referred to as “personal information”) practices in general, including:

the categories of personal data that we collect or process (Section 1);
the purposes for processing the personal data (Section 2);
the categories of personal data shared with third parties (Section 3);
the categories of third parties with whom we share personal data (Section 3); and
our sale of personal data to third parties or targeted advertising (Section 3, therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)
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‍11.2 Right of Access.

You have the right to confirm whether or not we are processing personal data concerning you and to access your personal data.

11.3 Right to Correction.

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

11.4 Right to Deletion

You have the right to delete personal data concerning you.

11.5 Right to Data Portability.

11.6 Right to Opt Out.

You have the right to opt out of the processing of your personal data for (a) targeted advertising or (b) sale of personal data.

You have the right to opt-out of the processing of your personal data for targeted advertising and you may exercise your right by emailing privacy@asharex.com. If you exercise your right to opt-out of the processing of your personal data for targeted advertising, we will refrain from processing your personal data for targeted advertising, unless you subsequently provide express authorization for the sharing of your personal data.

We may disclose your personal data to third parties in exchange for monetary consideration. We may sell your personal data to advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or to recommend our services and offerings to you based on your activity on other websites or apps. We may sell your personal data to data analytics providers who may use your personal data for their own behavioral advertising analysis purposes.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of personal data for your browser or device, and, if known, for you.

11.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) personal data revealing your racial or ethnic origin; religious beliefs; sexual orientation; citizenship or immigration status; or medical history, mental or physical health condition, or medical treatment or diagnosis by a health care professional; (b) the processing of genetic or biometric data for identification purposes and (c) specific geolocation data. We will not process your “Sensitive Data” without your consent or in the case of a known child, the consent or a parent or guardian.

11.8 How to Exercise your UCPA Rights

Unless otherwise specified, to exercise any of your rights described in this Section 11, please submit your request to us at privacy@asharex.com with the subject “UCPA Consumer Request.” We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 day response period, together with the reason for the extension.

If we decline to take action on your request, we shall inform you without undue delay, within 45 days of receipt of your request.

We shall provide information in response to your request free of charge, except that, for a second or subsequent request within a 12 month period, we may charge an amount as provided in the UCPA. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.

12. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

12.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal data as defined in the CDPA means any information that is linked or reasonably linkable to you. This Privacy Policy, including this Section 12, describes our collection and processing of personal data (therein also referred to as “personal information”) practices, including:

the categories of personal data that we collect or process (Section 1);
the purposes for processing the personal data (Sections 2);
the categories of personal data shared with third parties (Section 3);
the categories of third parties with whom we share personal data (Section 3); and
our sale of personal data to third parties and processing of personal data for targeted advertising (Section 3, therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”)
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‍12.2 Right of Access.

You have the right to confirm whether or not we are processing personal data concerning you and to access your personal data, except if doing so would require us to reveal a trade secret.

12.3 Right to Correction.

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

12.4 Right to Deletion

You have the right to delete personal data concerning you.

12.5 Right to Data Portability.

12.6 Right to Opt Out.

12.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) personal data revealing your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status; (b) the processing of genetic or biometric data for identification purposes; (c) personal data from a known child (individual under the age of 13); precise geolocation data. We will not process your “Sensitive Data” without your consent or in the case of a known child, the consent or a parent or lawful guardian.

12.8 How to Exercise your CDPA Rights

Unless otherwise specified, to exercise any of your rights described in this Section 12, please submit your request to us at privacy@asharex.com with the subject “CDPA Consumer Request.” We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45-day response period, together with the reason for the extension.

Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including an written explanation of the reason for the decisions. If we deny the appeal, you may contact the Connecticut Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page or (860) 808-5318.

We shall provide information in response to your request free of charge, except that, for a second or subsequent request within a 12-month period, we may charge an amount as provided in the CDPA. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

13. ADDITIONAL NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINGDOM AND SWITZERLAND

This Section provides additional information to individuals located in the EEA, the United Kingdom or Switzerland at the time their personal information is collected by us. All capitalized terms in this Section have the meaning as defined in the General Data Protection Regulation (GDPR) and/or, as applicable, the GDPR as it is saved and incorporated into United Kingdom law following Brexit (UK-GDPR) or the Swiss Data Protection Act (including, but not limited to “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Subject”, “Consent”).

13.1. Data Controller, Data Protection Officer and EU Representative

The Controller for the Processing described in this Privacy Policy is:

aShareX Inc., 10990 Wilshire Boulevard Suite 1150, Los Angeles, CA 90024

You can contact the Company’s Data Protection Officer using: privacy@asharex.com

For Data Subjects in the EU and the UK:

We value your data subject rights under the GDPR and UK-GDPR and therefore designated the Data Protection Officer as our representative according to Art 27 GDPR and Art. 27 UK-GDPR in order to provide you with an easy way to submit to us privacy related request like a request to access or erase your personal data. If you want to make use of your data subject rights, please email our Data Protection Officer at privacy@asharex.com

13.2. Legal Basis of Our Processing. The Legal basis of our Processing of your Personal Data within the scope of application of the GDPR, the UK-GDPR or the Swiss Data Protection Act is as follows:

Contract (Art. 6 (1) b GDPR), where we Process your purchase transactions (e.g. orders, exchanges and returns, shipping notifications) and answer your support and customer service requests as this is necessary for the performance of our contract with you;
Legitimate Interests (Art. 6 (1) f GDPR):

In our legitimate interest in providing a secure Website user experience, we Process Your Personal Data to administer our Programs and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
For an appealing surfing experience, we Process your Personal Data to allow you to participate in interactive features of our Website or our social media accounts, when you choose to do so;
Responding to your comments and questions is part of our legitimate business interests in providing you with first class services;
In our legitimate interest in expanding marketing offers to potential customers, we Process your Personal Data to share it with other marketing companies;
To protect our financial interests or to otherwise protect ourselves against fraud or unauthorized transactions, we Process your Personal Data by, for example, conducting credit card screenings, and performing monitoring to identify potential unauthorized users or hackers;
Our legitimate interest in promoting our business is the purpose for Processing your Personal Data to facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards;
If you want to work with us and apply for a job, we Process your Personal Data to evaluate your application;
To protect our rights and interests (e.g., to protect the Company against legal claims) we can use your data with, or otherwise distribute, share or disclose your Personal Data to any of the Company’s professional advisors such as attorneys or accountants in order to facilitate their professional advice.

Consent (Art. 6 (1) a GDPR):

Unless consent is not required under applicable law, we send you promotional communications about our offerings, services, and events offered by us and others, and provide news and information we think will be of interest to you only after you have consented to such communication. You can withdraw your consent at any time with future effect, e.g. by clicking the unsubscribe-link in each promotional email;
We request your explicit consent to monitor and analyze your usage of Company Programs and advertising to understand their effectiveness, and to personalize your experience when you use a Company Program.
We also request your consent to facilitate your use of various social media sharing features or other integrated tools (such as the Facebook “Like” button) which you may use as part of social media pages.

Compliance with Legal Obligations (Art. 6 (1) c GDPR):

We Process your Personal Data for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested e.g. under any subpoena or court order.

13.3. Social Media Accounts We maintain accounts with various social media networks. When you visit these social media networks, a variety of Data Processing operations are triggered. We use your Personal Data when you visit our profiles on these social media networks, or when you click on the like-button on one of our social media advertisements. When you visit our profiles, your Personal Data is not only used by us but also by the social network provider, regardless of whether you have a profile in the social network or not. The individual Processing and its scope differ from provider to provider, and they are not completely transparent to us. Details about the Processing of the social network providers can be found in the relevant social media network’s Privacy Policy:

Facebook by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland:
Instagram by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2 Ireland
X (formerly Twitter), One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland
YouTube by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland:
Pinterest by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland
TikTok by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland:

The social network providers collect your usage information to provide us with usage statistics. To learn more about how such tracking takes place and to understand how we use social media plugins on our Site please read our Cookie Policy.

13.4. International Transfers We may share your Personal Data with recipients (including our group members, service providers or business partners, as described in this Privacy Policy), located in the EEA, the UK and Switzerland; or in the United States and/or otherwise in countries outside the EEA, the UK and Switzerland which do not provide for an adequate level of data protection from an EU or Swiss law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g. by entering into appropriate data transfer agreements on the basis of updated EU standard contractual clauses issued by the Commission, on the basis of the UK’s International Data Transfer Agreement (IDTA) or by reliance upon the Article 49 GDPR derogations or corresponding derogations under the UK-GDPR or Swiss Data Protection Act, as applicable.

13.5. Duration of Our Data Processing We retain Personal Data you provide to us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g., in order to meet our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with us. If required under applicable law, we will store your Personal Data for a period of up to ten more years (e.g., under tax law). Apart from that, we can further store your Personal Data for the establishment, exercise or defense of legal claims.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services.

13.6. Your Data Protection Rights under the GDPR You have the following rights pursuant to the GDPR, where applicable, which can be exercised using the contact details of the Controller listed above:

Right of Access, pursuant to GDPR Article 15, to obtain from us confirmation as to whether or not Personal Data has been Processed and, if so, access to that Personal Data and additional information about the categories of Personal Data and its source, and how it has been Processed, e.g., the purpose, the categories of recipients, the planned retention period, the existence of the Data Subject’s rights;
Right to Rectification, pursuant to GDPR Article 16, to request the correction of incorrect Personal Data or any completed Personal Data stored by us;
Right to Erasure, pursuant to GDPR Article 17, to request the deletion of the Personal Data stored by us, except for the allowed continued uses permitted by the GDPR;
Right to Restriction, pursuant to GDPR Article 18, to demand the restriction of the Processing of the Personal Data where one of the following applies: (i) as far as the accuracy of the Personal Data is disputed by you; (ii) the Processing of the Personal Data is unlawful, but you reject its deletion; (iii) we no longer need the Personal Data, but you require it to exercise or defend legal claims; or (iv) you have objected to the Processing in accordance with GDPR Article 21;
Right to Data Portability, pursuant to GDPR Article 20, to receive your Personal Data as provided to us, in a structured, common and machine-readable format or to request the transfer to another Controller;
Right to Withdrawal, pursuant to GDPR Article 7(3), you have the right to withdraw, at any time, your once granted consent. As a result, we are no longer allowed to continue the Processing based on that consent for the future, but such withdrawal does not affect the lawfulness of the Processing based on such consent before such withdrawal; and
Right to Lodge a Complaint with a Supervisory Authority, pursuant to GDPR Article 77, to complain to a Supervisory Authority (e.g., that of your usual place of residence or work or place of the alleged infringement). You can find details of EEA Supervisory Authorities here The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO) or 0303 123 1113 / +44 1625 545 700
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14. ADDITIONAL NOTICE TO INDIVIDUALS IN CANADA

This Section provides additional information to individuals located in Canada at the time their personal information is collected by us.

You may request details about our privacy practices, access or correct your personal information, or make a complaint by contacting our privacy officer in writing:

aShareX Inc., 10990 Wilshire Boulevard, Los Angeles, CA 90024, privacy@asharex.com

If you are not satisfied with our response to your inquiry, you may contact the Office of the Privacy Commissioner of Canada: 1-800-282-1376 (toll-free) or priv.gc.ca

15. ADDITIONAL NOTICE TO INDIVIDUALS IN AUSTRALIA

This Section provides additional information to individuals located in Australia at the time their personal information is collected by us.

You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via our Services or by contacting us via privacy@asharex.com. If you request that your information be corrected, and we do not agree that it is incorrect, we may refuse to update that information. In such a scenario, we will provide written notice of our refusal to do so within 30 days and upon your request, will place a statement of what you allege is correct where your personal information is kept and accessed.

16. ADDITIONAL NOTICE TO INDIVIDUALS IN NEW ZEALAND

This Section provides additional information to individuals located in New Zealand at the time their personal information is collected by us.

You have the right to request access to any personal information we hold about you, by emailing us at privacy@asharex.com.

We retain Personal Data you provide to us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g., in order to meet our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with us. If required under applicable law, we will store your Personal Data for a period of up to ten more years (e.g., under tax law). Apart from that we can further store your Personal Data for the establishment, exercise or defense of legal claims. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services.

17. ADDITIONAL NOTICE TO INDIVIDUALS IN SINGAPORE

This Section provides additional information to individuals located in Singapore at the time their personal information is collected by Us.

You have the right to request access to and/or correction of any personal information we hold about you by emailing us at privacy@asharex.com.

You can also contact the Company’s Data Protection Officer at: privacy@asharex.com.

18. ADDITIONAL NOTICE TO INDIVIDUALS IN SOUTH AFRICA

18.1. Data Retention This paragraph sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Your personal information, account, transaction, usage, data are held in our website database or will be stored on the servers of our hosting services providers. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal information as follows for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 6 years following that date.

Notwithstanding the other provisions of this paragraph and any other provisions of this Privacy Policy, we may keep some or all of your personal data if and for as long as (i) we are required or permitted by law, a code of conduct, or a contract with you to keep it; (ii) we reasonably need it for lawful purposes related to our functions and activities; (iii) we reasonably need it for evidentiary purposes; or (iv) you agree to us keeping it for a specified further period.

18.2. International Transfers We may share your information with recipients (including our group members, service providers or business partners, as described in this Privacy Policy), located in the EEA, the UK and Switzerland; or in the United States and/or otherwise in countries outside South Africa which do not provide for an adequate level of data protection from a South African law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g., by entering into appropriate data transfer agreements that contain the safeguards prescribed by applicable data protection legislation.

18.3. Your Rights in this Paragraph, we have listed the rights that you have under data protection law. Your principal rights under data protection law are:

the right to access - you can ask for copies of your personal data;
the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure - you can ask us to erase your personal data;
the right to restrict processing - you can ask us to restrict the processing of your personal data;
the right to object to processing - you can object to the processing of your personal data;
the right to data portability - you can ask that we transfer your personal data to another organization or to you;
the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
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As far as the law allows, we may charge a fee for attending to any of your requests above and may also refuse to carry out any of your requests in whole or in part. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below. You must let us know if any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details below. Where required by law we will take reasonable steps to correct or update the relevant information, accordingly, having regard to the purpose for which the information was collected or used.

18.4. Most Pertinent Terms We have a duty under the Consumer Protection Act 68 of 2008, to bring certain important terms to your attention. In accordance with this obligation, We hereby notify you that Sections 3, 4.1 and 6 as well as this Section 14 are important terms that should be carefully reviewed by you, as these terms may (i) limit our liability to you or another person; or (ii) constitute an assumption of risk or liability by you; or (iii) be an acknowledgement of fact by you.

19. ADDITIONAL NOTICE TO INDIVIDUALS IN SAUDI ARABIA AND THE UNITED ARAB EMIRATES

We only process your personal information after obtaining your consent. You may have certain rights in relation to such processing under applicable law. To know more about any such rights and how to exercise them, please contact us at privacy@asharex.com.

We retain your personal information for as long as necessary as described in this Privacy Policy.

20. COMMUNICATING WITH THE COMPANY

We welcome your questions and comments about this Privacy Policy. You can contact aShareX by emailing us at: privacy@asharex.com

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