Privacy Policy

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Effective as of November 21, 2019

This privacy policy discloses the privacy practices for www.MaltawellHoldings.com. This policy applies solely to information collected by this website. It will notify you of the following:

· What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.

· What choices are available to you regarding the use of your data.

· The security procedures in place to protect the misuse of your information.

· How you can correct any inaccuracies in the information.

Information Collection, Use, and Sharing
We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contacts from you. We will not sell or rent this information to anyone.

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. to ship a product order.

Unless you ask us not to, we may contact you via email in the future to tell you about special events and announcements, new products/services, or changes to this privacy policy.

Log Data 

Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this data to help us better market our business.

Your Access to and Control Over Information
You may opt-out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

· See what data we have about you if any.

· Change/correct any data we have about you.

· Have us delete any data we have about you.

· Express any concern you have about our use of your data.

Security
We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the Web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment by our providers.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at (919) 578-6343 or via email (info@maltawellholdings.com).

Registration
In order to use “Member” portions of this website, a user must first complete the registration form and be accepted for membership. During registration, a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest and paid an access fee. At your option, you may also provide demographic information (such as gender or age) about yourself which can be used to personalize your “Member” experience, but it is not required.

Cookies
We use "cookies" on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site. For further information regarding cookies, see our Terms and Conditions.

Partner Data Sharing

We partner with another party to provide specific services. When the user signs up for these services, we will share names or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Links
This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites that are not the property of the Maltawell Holdings, Inc. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Polls, Surveys & Contests
From time-to-time, our site requests information via polls, surveys or contests. Participation in these polls, surveys or contests is completely voluntary and you may choose whether to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to analyze poll and survey data. Survey information will also be used for purposes of monitoring or improving the use and satisfaction of this site.

Our Legal Basis (EU and GDPR)

If you interact with our services while from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. For these purposes, "European Territories" means the European Economic Area and Switzerland, and shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.

Specifically:

· We will normally process personal data about you where the processing is in our legitimate interests (or the legitimate interests of our Customers) to do so and not overridden by your interests or fundamental rights and freedoms. We rely on legitimate interests, for example, when we process personal data as a data controller in order to administer our platforms and provide our services so that we can fulfill our contractual obligations to our customers and support them to provide you with interest-based advertising.

· In some cases, we may collect, and process personal data based on your consent. For example, when you visit an Advertiser’s Digital Property, you will be asked to consent to Maltawell Holdings, Inc. dropping a cookie. 

· If you have questions about or need further information concerning, the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “Contact Us” section of the website.

European Residents’ Privacy Rights

In addition, if you are a resident of a European Territory, you have the following data subject access rights under EU data protection law:

· If you wish to access, correct, update or request deletion of your personal data, please complete the information on the “Contact Us” to obtain the request form.

· If you wish to object to us processing your personal data or would like to otherwise restrict the processing of your personal data, we will honor that request.

· Similarly, if we process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. It will, however, potentially affect your continued access to the “Member” sections of the Maltawell Holdings, Inc. website.

· You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Territories are available here. 

However, if you have any questions about our collection and use of your personal data, we encourage you to contact us first at info@maltawellholdings.com . If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer also at info@maltawellholdings.com.

In some cases, we act as a processor for our Customers (for example, when we handle our Customers’ CRM data solely to provide them services) and, in those cases, you should direct any requests to exercise your data protection rights to the relevant Customer. If you are uncertain whether we process your personal data as a controller or a processor in any specific context, you can contact us at info@maltawellholdings.com and we will advise you accordingly.

We may transfer the data we collect about you to countries other than the country where we originally collected it for the purposes of operating our services. In general, the transferring countries will be the countries in which we, our Customers, our Advertising Partners, or our or their service providers operate.Those countries may not have the same data protection laws as your country. However, when we transfer your data to other countries, we will protect that data as described in this Service Privacy Policy and take steps, where necessary, to ensure that international transfers comply with applicable laws.

For example, when we transfer your data from a European Territory (as defined below) to our parent company in the United States, we do so under the European Commission's Standard Contractual Clauses. These Standard Contractual Clauses are incorporated in writing between Maltawell Holdings, Inc. and each of our Customers where applicable. When we transfer your data outside to a European Territory to Advertising Partners (or vice versa), we do so under lawful data export mechanisms which may include Standard Contractual Clauses, EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and Binding Corporate Rules.

This section supplements the information contained in this Service Privacy Policy and applies solely to visitors, users, and others who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section is effective as of January 1, 2020, to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this section.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“personal information”). This collection of information is listed in What Data We Collect.

We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months in respect of our services. Please note that personal information in certain categories may overlap with other categories.

A. Category: Identifiers    

Data Collected: Yes

Details: Device IP address, email address, cookie string data, pseudonymous data (e.g. hashed emails), operating system, and (in the case of mobile devices) your device type, and mobile device's identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to any device by third parties and cross-referenced to recognize a device.

Source: Directly and indirectly from consumers, third party data providers and Advertising Partners. In the case of business email addresses, Maltawell Holdings B2B services may infer a business email address.

B. Category:  Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Data Collected: Yes

Details:

In respect of Maltawell Holdings, B2B Services:
Name, business address, business telephone number, education, employment and employment history.
In respect of Maltawell Holdings, D2C Services:
The perceived general education level of consumers may be collected for D2C marketing, advertising and analytics to the extent relevant for providing marketing or advertising.

Source: Directly from third party data providers.

C. Category: Protected classification characteristics under California or federal law

Data Collected: Yes

Details: Limited to age ranges such as 35-44, 45-54, 55-64 and 65+ and male/female gender categories are sometimes collected for use of Maltawell Holding’s D2C services that do not carry a risk of unintended discrimination.

Source:From third party data providers.

D. Category:  Commercial information   

Data Collected: Yes

Records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

Details: Directly from consumers and Advertiser.

E. Category: Biometric information   

Data Collected:  No

F. Category: Internet or another similar network activity 

Data Collected: Yes

Details: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a B2B website, what items you placed into your online shopping cart, what products were   purchased and the price of the products purchased.

Source: Directly from cookie browsing history on Advertisers’ Digital Properties. Non-personal information about one of our ads e.g. the third party who served the ad, and the name of the ad) may be connected with browsing history or activity on our websites for the purposes of determining attribution information (e.g. whether particular ad led to a consumer visiting our website, and, if so, which particular ad campaign).

G. Category: Geo-location data

Data Collected: Yes

Details: Non-precise geo-location derived from IP address.

Source: Directly from consumers and Advertising Partners.

H. Category: Sensory data

Data Collected: No

I. Category: Professional or employment-related information

Data Collected: Yes

Details:

In respect of Maltawell Holdings, Inc. B2B business only:
Current or past job history, including details about the employer (industry, name, company location, company domain or URL), and employee (positions held, duration of employment, and office location of the company where the employee worked).

Source:Third party data providers.

J. Category: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99))

Data Collected: No

K. Category: Inferences are drawn from other personal information

Data Collected: Yes

Details: Creating profiles that reflect consumer preferences and interests.

Source: Third-party data providers.

For clarity, under CCPA personal information does not include:

· Publicly available information from government records;

· De-identified or aggregated consumer information; and

· Information excluded from the CCPA's scope such as:

      o Health or medical information covered by the Health Insurance Portability and     Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

     o Personal information covered by certain sector-specific privacy laws, including the Fair   Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Maltawell Holdings, Inc is a research, consulting, and investment technology company. All data we collect is for the business purpose of providing services primarily for our research, consulting, or analytical services. However, as part of performing these services, we also use data collected (as identified above) for the following additional business purposes:

• Auditing Interactions with Consumers: count ad impressions and verify the quality of ad impressions served to unique visitors identified by cookie id or another unique identifier;
• Debugging and Repair: the identification and repair of impairments to intended and existing functionalities in our services and perform debugging and related activities to repair errors that impair the functionality of our services;
• Security: detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities;
• Internal Research and Development: conduct internal research for technological development of our services and demonstration of the performance of these services; and
• Quality and Safety Maintenance and Verification: verify the quality or safety of our services and improve, upgrade or enhance the services we provide.