AstraOne

3. Policy

3.1 Governance

3.1.1 Policy Dissemination & Enforcement
The management team of each astraone.io Entity must ensure that all astraone.io Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. In addition, each astraone.io Entity will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e. their Data Processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by hybrid.ai.
3.1.2 Data Protection by Design
To ensure that all Data Protection requirements are identified and addressed when designing new products or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing. Each astraone.io Entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, for all new and/or revised products or processes for which it has responsibility. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will assess the impact of any new technology uses on the security of Personal Data.
3.1.3 Compliance Monitoring
To confirm that an adequate level of compliance that is being achieved by all astraone.io Entities in relation to this policy, the management of astraone.io will carry out an annual Data Protection compliance audit for all such Entities. Each audit will, as a minimum, assess:
- Compliance with Policy in relation to the protection of Personal Data, including:
  - Compliance with Policy in relation to the protection of Personal Data, including:
    - The assignment of responsibilities
    - Raising awareness
    - Training of Employees
  - The effectiveness of Data Protection related operational practices, including:
    - Data Subject rights
    - Personal Data transfers
    - Personal Data incident management
    - Personal Data complaints handling
    - The level of understanding of Data Protection policies and Privacy Notices
    - The currency of Data Protection policies and Privacy Notices
    - The accuracy of Personal Data being stored
    - The conformity of Data Processor activities
    - The adequacy of procedures for redressing poor compliance and Personal Data Breaches
    Key business stakeholders from each astraone.io Entity, will devise a plan with a schedule for correcting any identified deficiencies within a defined and reasonable time frame. Any major deficiencies identified will be reported to and monitored by the hybrid.ai Executive Management team.

3.2 Data Protection Principles

astraone.io has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data:

Principle 1: Lawfulness, Fairness and Transparency
Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, astraone.io must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).
Principle 2: Purpose Limitation
Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means astraone.io must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.
Principle 3: Data Minimisation
Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means astraone.io must not store any Personal Data beyond what is strictly required.
Principle 4: Accuracy
Personal Data shall be accurate and, kept up to date. This means astraone.io must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.
Principle 5: Storage Limitation
Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means hybrid.ai must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.
Principle 6: Integrity & Confidentiality
Personal Data shall be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. astraone.io must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data is maintained at all times.
Principle 7: Accountability
The Data Controller shall be responsible for, and be able to demonstrate compliance. This means astraone.io must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

3.3 Data Collection

3.3.1 Purposes of Data Collection
We may collect the following categories of information for the purposes explained below.

Advertiser website activity: This is data about your browsing activity on the Advertiser's website. For example, which pages you visited and when, and what items you placed into your online shopping cart.
Device and browser information: This is technical information about the device or browser you use to access the Advertiser's website. For example, your device's IP address, cookie string data and (in the case of mobile devices) your device type and mobile device's unique identifier such as the Apple IDFA or Android Advertising ID.
Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
Data from Advertising Partners: This is data that we receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us, such as your "Customer ID" with an Advertiser. We may work with these Advertising Partners to synchronize their unique, anonymous identifiers to our own to enhance data points about a particular unique browser or device.

We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device, or to target, optimize, cap, or synchronize advertising.

3.3.2 Data Sources

Personal Data should be collected only from the Data Subject unless one of the following apply:

The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.
The collection must be carried out under emergency circumstances in order to protect the vital interests of the Data Subject or to prevent serious loss or injury to another person.
If Personal Data is collected from someone other than the Data Subject, the Data Subject must be informed1 of the collection unless one of the following apply:
The Data Subject has received the required information by other means.
The information must remain confidential due to a professional secrecy obligation.
A national law expressly provides for the collection, Processing or transfer of the Personal Data.
Where it has been determined that notification to a Data Subject is required, notification should occur promptly, but in no case later than:
One calendar month from the first collection or recording of the Personal Data.
At the time of first communication if used for communication with the Data Subject.
At the time of disclosure if disclosed to another recipient.

3.3.3 Data Subject Consent

Each hybrid.ai Entity will obtain Personal Data only by lawful and fair means and, where appropriate with the knowledge and Consent of the individual concerned. Where a need exists to request and receive the Consent of an individual prior to the collection, use or disclosure of their Personal Data, astraone.io is committed to seeking such Consent. astraone.io business representatives, shall establish a system for obtaining and documenting Data Subject Consent for the collection, Processing, and/or transfer of their Personal Data.
Each astraone.io Entity will refer to OpenRTB Advisory – GDRP in order to receive a Consent from Third Parties. This advisory, therefore, focuses on how active versions of OpenRTB will signal GDPR applicability and convey the consent string, which is treated as a single unit of data to be conveyed throughout a real-time bidding transaction.

3.3.4 Data Subject Notification
Each astraone.io Entity will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide Data Subjects with information as to the purpose of the Processing of their Personal Data. When the Data Subject is asked to give Consent to the Processing of Personal Data and when any Personal Data is collected from the Data Subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:

The Data Subject already has the information
A legal exemption applies to the requirements for disclosure and/or Consent.

The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Office of Data Protection. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

3.4 Data Use

3.4.1 Data Processing

astraone.io provides targeted advertising services for our advertiser clients ("Advertisers"). When Identifiable Natural Person visits a website operated by an Advertiser or a third party site where we could serve an ad to you, we may collect some or all of the data described in 3.3.1. hybrid.ai uses that data as well as other data described below to help Advertisers provide ads to Identifiable Natural Persons that are more relevant to them.
astraone.io uses the Personal Data of its Contacts for the following broad purposes:
- The general running and business administration of hybrid.ai Entities.
- To provide advertising services to astraone.io customers.
The use of a Advertiser’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a Advertiser’s expectations that their details will be used by hybrid.ai to respond to a Advertiser request for information about the products and services on offer. However, it will not be within their reasonable expectations that astraone.io would then provide their details to Third Parties for marketing purposes. Each astraone.io Entity will Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, astraone.io will not Process Personal Data unless at least one of the following requirements are met:
- The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.
- Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
- Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
- Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
- Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).
There are some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected. When making a determination as to the compatibility of the new reason for Processing, guidance and approval must be obtained from the hybrid.ai representative before any such Processing may commence.
In any circumstance where Consent has not been gained for the specific Processing in question, astraone.io will address the following additional conditions to determine the fairness and transparency of any Processing beyond the original purpose for which the Personal Data was collected:
- Any link between the purpose for which the Personal Data was collected and the reasons for intended further Processing.
- The context in which the Personal Data has been collected, in particular regarding the relationship between Data Subject and the Data Controller.
- The nature of the Personal Data, in particular whether Special Categories of Data are being Processed, or whether Personal Data related to criminal convictions and offences are being Processed.
- The possible consequences of the intended further Processing for the Data Subject.
- The existence of appropriate safeguards pertaining to further Processing, which may include Encryption, Anonymisation or Pseudonymisation.

3.4.2 Special Categories of Data

astraone.io will only Process Special Categories of Data (also known as sensitive data) where the Data Subject expressly consents to such Processing or where one of the following conditions apply:
- The Processing relates to Personal Data which has already been made public by the Data Subject.
- The Processing is necessary for the establishment, exercise or defence of legal claims.
- The Processing is specifically authorised or required by law.
- The Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving consent.
- Further conditions, including limitations, based upon national law related to the Processing of genetic data, biometric data or data concerning health.
In any situation where Special Categories of Data are to be Processed, prior approval must be obtained from the Office of Data Protection and the basis for the Processing clearly recorded with the Personal Data in question. Where Special Categories of Data are being Processed, MetaPrivacy will adopt additional protection measures. Each MetaPrivacy Entity may also adopt additional measures to address local custom or social expectation over the Processing of Special Categories of Data.

3.4.3 Children’s Data
Children are unable to Consent to the Processing of Personal Data for information services. Consent must be sought from the person who holds parental responsibility over the child. However, it should be noted that where Processing is lawful under other grounds, Consent need not be obtained from the child or the holder of parental responsibility. Should any astraone.io Entity foresee a business need for obtaining parental consent for information society services offered directly to a child, guidance and approval must be obtained from the hybrid.ai representative before any Processing of a child’s Personal Data may commence.

3.4.4 Data Quality

Each astraone.io Entity will adopt all necessary measures to ensure that the Personal Data it collects and Processes is complete and accurate in the first instance, and is updated to reflect the current situation of the Data Subject.
The measures adopted by astraone.io to ensure data quality include:
- Correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the Data Subject does not request rectification.
- Keeping Personal Data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.
- The removal of Personal Data if in violation of any of the Data Protection principles or if the Personal Data is no longer required.
- Restriction, rather than deletion of Personal Data, insofar as:
  - a law prohibits erasure.
  - erasure would impair legitimate interests of the Data Subject.
  - the Data Subject disputes that their Personal Data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.

3.4.6 Digital Marketing
As a general rule hybrid.ai will not send promotional or direct marketing material to an astraone.io website visitors or platform users through digital channels such as mobile phones, email and the Internet, without first obtaining their Consent. Any astraone.io Entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the Data Subject must first have it approved by astraone.io representative. Where Personal Data Processing is approved for digital marketing purposes, the Data Subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data Processed for such purposes. If the Data Subject puts forward an objection, digital marketing related Processing of their Personal Data must cease immediately and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted. It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.

3.5 Data Retention
We retain the identifiable data we collect directly for targeting purposes for 12 months, after which time we employ measures to delete it. However for identifiable data that we hold on behalf of an Advertiser such as their email address list, we may retain it for a longer period and not delete it until we no longer require it to provide services to the Advertiser or the Advertiser asks us to delete it.
Identifiable data collected for other purposes is held no longer than necessary for our business purposes or to meet legal requirements.

3.6 Data Subject Requests
Each astraone.io Entity will establish a system to enable and facilitate the exercise of Data Subject rights related to:
- Information access.
- Objection to Processing.
- Objection to automated decision-making and profiling.
- Restriction of Processing.
- Data portability.
- Data rectification.
- Data erasure.
If an individual makes a request relating to any of the rights listed above, astraone.io will consider each such request in accordance with all applicable Data Protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. Data Subjects are entitled to obtain, based upon a request made in writing to a astraone.io representative and upon successful verification of their identity, the following information about their own Personal Data:
- The purposes of the collection, Processing, use and storage of their Personal Data.
- The source(s) of the Personal Data, if it was not obtained from the Data Subject;
- The categories of Personal Data stored for the Data Subject.
- The recipients or categories of recipients to whom the Personal Data has been or may be transmitted, along with the location of those recipients.
- The envisaged period of storage for the Personal Data or the rationale for determining the storage period.
- The right of the Data subject to:
  - object to Processing of their Personal Data.
  - lodge a complaint with the Data Protection Authority
  - request rectification or erasure of their Personal Data.
  - request restriction of Processing of their Personal Data.
  All requests received for access to or rectification of Personal Data must be directed to the astraone.io representative, who will log each request as it is received. A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require astraone.io to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

3.7 Law Enforcement Requests & Disclosures
In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:
- The prevention or detection of crime.
- The apprehension or prosecution of offenders.
- The assessment or collection of a tax or duty.
- By the order of a court or by any rule of law.
If a astraone.io Entity Processes Personal Data for one of these purposes, then it may apply an exception to the Processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question. If any astraone.io Entity receives a request from a court or any regulatory or law enforcement authority for information relating to a astraone.io Advertiser, you must immediately notify the hybrid.ai representative who will provide comprehensive guidance and assistance.

3.8 Data Protection Training
All astraone.io Employees that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each astraone.io Entity will provide regular Data Protection training and procedural guidance for their staff.
The training and procedural guidance set forth will consist of, at a minimum, the following elements:
- The Data Protection Principles set forth in Section 4.2 above.
- Each Employee’s duty to use and permit the use of Personal Data only by authorised persons and for authorised purposes.
- The need for, and proper use of, the forms and procedures adopted to implement this policy.
- The correct use of passwords, security tokens and other access mechanisms.
- The importance of limiting access to Personal Data, such as by using password protected screen savers and logging out when systems are not being attended by an authorised person.
- Securely storing manual files, print outs and electronic storage media.
- The need to obtain appropriate authorisation and utilise appropriate safeguards for all transfers of Personal Data outside of the internal network and physical office premises.
- Proper disposal of Personal Data by using secure shredding facilities.
- Any special risks associated with particular departmental activities or duties.

3.9 Data Transfers
We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.
astraone.io Entities may transfer Personal Data to internal or Third Party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant Data Subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. Third Countries), they must be made in compliance with an approved transfer mechanism astraone.io Entities may only transfer Personal Data where one of the transfer scenarios list below applies:
- The Data Subject has given Consent to the proposed transfer.
- The transfer is necessary for the performance of a contract with the Data Subject.
- The transfer is necessary for the implementation of pre-contractual measures taken in response to the Data Subject’s request.
- The transfer is necessary for the conclusion or performance of a contract concluded with a Third Party in the interest of the Data Subject.
- The transfer is legally required on important public interest grounds.
- The transfer is necessary for the establishment, exercise or defence of legal claims.
- The transfer is necessary in order to protect the vital interests of the Data Subject.

3.9.1 Transfers between hybrid.ai Entities
In order for astraone.io to carry out its operations effectively across it’s various hybrid.ai Entities, there may be occasions when it is necessary to transfer Personal Data from one astraone.io Entity to another, or to allow access to the Personal Data from an overseas location. Should this occur, the astraone.io Entity sending the Personal Data remains responsible for ensuring protection for that Personal Data.
astraone.io handles the transfer of Personal Data between astraone.io Entities, where the location of the recipient Entity is a Third Country, using the Binding Corporate Rules transfer mechanism. Binding Corporate Rules provide legally binding, enforceable rights on Data Subjects with regard to the Processing of their Personal Data and must be enforced by each approved hybrid.ai Entity, including their Employees. When transferring Personal Data to another astraone.io Entity located in a Third Country, you must:
- Only transfer the minimum amount of Personal Data necessary for the particular purpose of the transfer (for example, to fulfil a transaction or carry out a particular service).
- Ensure adequate security measures are used to protect the Personal Data during the transfer (including password-protection and Encryption, where necessary).

3.9.2 Transfers to Third Parties
Each astraone.io Entity will only transfer Personal Data to, or allow access by, Third Parties when it is assured that the information will be Processed legitimately and protected appropriately by the recipient. Where Third Party Processing takes place, each hybrid.ai Entity will first identify if, under applicable law, the Third Party is considered a Data Controller or a Data Processor of the Personal Data being transferred.
Where the Third Party is deemed to be a Data Controller, the astraone.io Entity will enter into, in cooperation with the Office of Data Protection, an appropriate agreement with the Controller to clarify each party’s responsibilities in respect to the Personal Data transferred.
Where the Third Party is deemed to be a Data Processor, the astraone.io Entity will enter into, in cooperation with the Office of Data Protection, an adequate Processing agreement with the Data Processor. The agreement must require the Data Processor to protect the Personal Data from further disclosure and to only Process Personal Data in compliance with astraone.io instructions. In addition, the agreement will require the Data Processor to implement appropriate technical and organisational measures to protect the Personal Data as well as procedures for providing notification of Personal Data Breaches.
When a hybrid.ai Entity is outsourcing services to a Third Party (including Cloud Computing services), they will identify whether the Third Party will Process Personal Data on its behalf and whether the outsourcing will entail any Third Country transfers of Personal Data. In either case, it will make sure to include, in cooperation with the Office of Data Protection, adequate provisions in the outsourcing agreement for such Processing and Third Country transfers. MetaPrivacy has a ‘Standard Provisions for Outsourcing Agreement’ document that should be used for guidance.

3.10 Complaints Handling
Data Subjects with a complaint about the Processing of their Personal Data, should put forward the matter in writing to the Office of Data Protection. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The hybrid.ai representative will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the Data Subject and the hybrid.ai representative, then the Data Subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

3.11 Breach Reporting
Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify astraone.io representative providing a description of what occurred. Notification of the incident can me made via e-mail , by calling , or by using the anonymous incident reporting form at . astraone.io representative will investigate all reported incidents to confirm whether or not a Personal Data Breach has occurred. If a Personal Data Breach is confirmed, the astraone.io representative will follow the relevant authorised procedure based on the criticality and quantity of the Personal Data involved. For severe Personal Data Breaches, the astraone.io management will initiate and chair an emergency response team to coordinate and manage the Personal Data Breach response.

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