1.Introduction and Overview

This Privacy Policy describes how Anterdit (“Anterdit”, “we”, “us”, “our”) collects, uses, stores, and shares your information when (1) you access and/or use the Anterdit website available at www.anterdit.com or any other online location where this Privacy Policy is posted or linked (collectively, “Sites”); (2) you communicate with us in any way (“Communications”); (3) your information is provided to us by an Anterdit customer; and/or (4) we obtain your information from third-party sources (“Third Parties”).

2.Acknowledgment

Please read this Privacy Policy carefully. The practices described herein are subject to the laws in the places in which we operate.

BY ACCESSING AND/OR USING THE SITES, OR BY COMMUNICATING WITH US, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.

3.Specific Locations

If you are a California resident please see the “Additional Disclosures for California Residents” section.

If you are an individual located in the United Kingdom or any part of the European Economic Area, please see the “Additional Disclosures for People in Europe” section.

4.What Type Of Information Do We Collect About You?

A.Information You Provide

Depending on how you use and interact with the Sites and the nature of our Communications, we may collect the following information directly from you:

• Contact Data, including your first and last name, email address, postal address, and phone number.
• Account Credentials, including your username, password, password hints, and information for authentication and account access.
• Demographic Data, including your age, gender, and country.
• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
• Profile Data, including your interests, inferences, preferences and favorites.
• Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Sites. We also collect content within any messages you exchange with other users through the Sites (such as if you use our chat functionality), if applicable.

B.Information Collected Automatically

We automatically collect information when you use our Sites and Communicate with us. The categories of information we automatically collect from you include:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

We may also use various current – and later – developed tracking technologies to automatically collect information when you use the Sites, including the following:

• Log Files, which are files that record events that occur in connection with your use of the Sites.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Sites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies may allow us to bring you advertising both on and off the Sites. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. To learn more about how we use cookies, please visit our Cookie Policy.
• Pixels (also known as web beacons), which are types of code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our communications, bring you advertising both on and off the Sites and provide you with additional functionality.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
• App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our communications, bring you advertising both on and off the Sites, and provide you with additional functionality.
• Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our Sites. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C.Information on Behalf of Our Customers.

In the course of providing our Sites to our customers, we collect and process certain information about individuals at the direction of our business customers (“Customer Data”). Customer Data includes contact data, purchase information, content, service use data, device connectivity and configuration data, and location data, among other information.

Our processing of Customer Data is governed by the terms of our service agreements with our business customers. To the extent we combine Customer Data with information we have collected through the Sites, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by our customers. We are not responsible for how our business customers treat the information we collect on their behalf, and we recommend you review their own privacy policies.

For further information on your rights and choices regarding Customer Data, see the “Your Rights and Choices” section below.

D.Information from Other Sources

We also collect information from other sources. The following are the categories of sources we collect information from:

• Consumer or users of the Sites.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly-available sources, including data in the public domain.

5.Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. The legal basis for these uses include obtaining your consent, to complete a transaction with you, and to further our legitimate interests of improving our Sites, maintaining a secure experience, and maintaining adequate business administration:

• Operate and manage our Sites, including your registration and account.
• Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Preventing and addressing fraud, breach of policies or terms, and threats or harm.
• Monitoring and analyzing trends, usage, and activities.
• Conducting research, including focus groups and surveys.
• Improving the Sites or other websites, apps, marketing efforts, products and services.
• Developing and sending you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
• Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
• Sending you advertising.
• Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

6.Sharing of Information

We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities we may have shared information with or may share information with in the future include the following:

• Service Providers. We may share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as payment processing, data analytics, marketing, ad measurement services, advertising, website hosting, and technical support.
• Vendors and Other Parties. We may share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Affiliates. We may share information with our related entities including our parent and sister companies for business purposes such as customer support, marketing, product development, and technical operations. We also may share information with affiliates for commercial purposes.
• Customers. We may share information with our customers in connection with us processing information on their behalf. For example, we share information with our customers in order to facilitate your orders, maintain and administer your online accounts, respond to your questions and comments, comply with your requests, market and advertise to you, and otherwise comply with applicable law.
• Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we may share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list).
• Merger or Acquisition. We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition, business combination of all or any portion of our business or assets, change of control, or a transfer of all or a portion of our business or assets to another third party (including in the case of any bankruptcy proceeding).
• Security and Compelled Disclosure. We may share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
• Consent. We may share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

7.Social Media and Technology Integrations

We may, from time to time, offer parts of our Sites through websites, platforms, and services operated or controlled by separate entities. In addition, we may integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:

• Links. Our Sits may include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
• Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Sites on social media (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Sites.

Please note that when you interact with other entities, including when you leave our Sites, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

8.Analytics and Advertising

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we may, from time to time, work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services.

9.Your Rights and Choices

A.Account Information

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B.Tracking Technology Choices

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track.Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. We do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com
.
• App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Sites may not function correctly.

C.Analytics and Interest-Based Advertising

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .

D.Communications

• E-mails.You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
• Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
• Text Messages and Calls. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

10.Children

Our Service is not directed towards, nor was it designed to attract the attention of any children, and we do not knowingly collect or maintain personal information from any person under the age of thirteen.

11.Security

We implement commercially reasonable safeguards as appropriate to the sensitivity of the information collected to mitigate the risk of unauthorized access and acquisition of your information.

12.International Transfer

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Sites from outside of the U.S., please be aware that information collected through the Sites may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence.

13.Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy.

14.Contact Us.

By email:
support@anterdit.com

By mail:
925 Mariner Dr, Key Biscayne 33149 Miami, FL

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at support@anterdit.com.

15.Additional Disclosures for California Residents.

These additional disclosures for California residents apply only to individuals who reside in California. All phrases used under this section carry the same meaning as those phrases are used under the California Consumer Privacy Act of 2018 (“CCPA”).

A.Notice of Collection.

In the past 12 months, we have collected the following categories of personal information from California residents:

• Identifiers, including name, email address, national ID, passport, phone number account name, IP address, and an ID or number assigned to your account.
• Customer records, billing and shipping address, biometric piece of information (e.g. facial scan data) and credit or debit card information.
• Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information, including purchases and engagement with the Services.
• Internet activity, including your interactions with our Service.
• Audio or visual data, including pictures or vides you post on our Service.
• Geolocation data, including location enabled services such as WiFi and GPS.
• Inferences, including information about your interests, preferences and favorites.

For more information on information we collect, and the information we have shared with third parties, review the Information Collection section. We collect and use these categories of personal information for the business purposes described in the Use of Information section, including to provide and manage our Services. We share the information as described in the Sharing of Information section.

Anterdit does not sell the personal information of California residents, nor does Anterdit have actual knowledge of selling the personal information of California residents who are 16 years or younger.

B.Right to Know and Delete.

If you are a California resident, you have the right to delete the personal information we have collected from you (subject to certain exceptions) and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please email us at support@anterdit.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

C.Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

D.Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

16.Additional Disclosures for Data Subjects in Europe.

A.Roles.

Anterdit acts as a controller with respect to personal data collected as you interact with our Sites and through our Communications. However, in most instances, Anterdit acts a processor on behalf of a customer, a separate legal entity, which is the controller. Any questions that you may have relating to the processing of personal data by Anterdit on behalf of the customer and your rights under data protection law should be directed to the customer as the controller, not to Company.

B.Lawful Basis for Processing.

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

C.Your Data Subject Rights.

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If your personal data has been processed by us on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

D.Complaints.

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. In addition to the contact information above, please contact our:

European Representative support@anterdit.com