MAD CURVE PRIVACY POLICY

Last Update: 14.09.2022

This privacy policy will explain how Horizon Labs Ltd. (“we”, “us”, “our”, “Horizon Labs”) collects and uses the information and data.

This privacy policy applies to:

Information and data that our customers (“Customer(s)”) provide to us when when they register an account and use the services under the Terms of Service available at https://madcurve.com/legal/terms-of-service (the ”Services”);
About the end users of the Customers’ products including websites and mobile applications that the Customers provide to us in for using the Services (“End Users’ Data”);
Data that we collect when you visit our website https://madcurve.com/, https://app.madcurve.com/

DATA COLLECTION, PURPOSES AND LEGAL BASIS FOR PROCESSING

Data collected	Purpose	Legal Basis
About Customer of the Services (“Customer’s Data”)
Information that you provide when you register an Account with us (or update this information) including your professional or employment related information such as full name, email, address, postal code, tax ID, VAT ID, telephone number, company name and position, brand name, country, city	We use this data to manage and administer the Services provided to you We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account). We may use this information to inform you of any updates to the Services, including new features and functionalities.	Legitimate Interest Performance of a contract with you
Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and other additional data, with that you may provide us, including through our support service. We may take additional verification steps that we consider reasonable in order to verify your account.	We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights For example, we use this information to verify your identity if you lose your credentials and wish to regain access to your account	Legitimate Interests Performance of a contract with you
Your email and the contents of your message you submit via our support email support@madcurve.com	We use this information to communicate with you including the response to your inquiries or complaints.	Legitimate interests Performance of our contract with you
About the end users of the Customer’s products including websites and mobile applications that the Customer provides to us for using the Services(“End Users’ Data”) In order to provide the Services to the Customer, we process the personal data (or personal information) of the Customer products’ end users which the Customer provides to us or makes available to us under the Terms of Service acting as a data processor (or a service provider) on behalf of the Customer and under Customer’s instructions. If you are a data subject of the End Users’ Data (i.e., you are an end user of the Customer’s product), and would like to obtain more information on the collection and processing of your personal data, please contact the Customer which is the data controller of your personal data.
Device related data: browser type, device type and model, CPU, system language, memory, OS version, screen resolution, time stamp and zone, carrier, location, app version data, installed apps, the Internet provider, the dates and times an end user accesses an application and other similar information. This also refers to various technical identifiers that generally only identify a computer, device, browser or application. For example, IP address (which may also provide general location information), end user agent, network data (MAC address, Wi-Fi and other networks devices have connected to), IDFA (identifier for advertisers), IDFV, Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique technical identifiers.	We use this data to enable us to fulfil our obligations to you as part of the Services	Legitimate interests Performance of our contract with you
End user’s engagement information that is related to the ad campaigns and end user actions, such as: clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, installations of applications, and other interactions, events and actions Licensee choose to measure and analyse within their Application (e.g. app installs, launches, in-app purchases made, clicks, screens transitions, engagement time etc.). Some of this information may be collected from various advertising networks and third parties that are used in connection with the measurement and analysis of marketing campaigns.	We use this data to enable us to fulfil our obligations to you as part of the Services	Legitimate interests Performance of our contract with you
About visitors of our website madcurve.com and *all subdomains in .madcurve.com (“Visitor’s Data”)**
Technical Information such as browser type, operating system, device type, IP address, country and language settings and other similar information typically received when you visit our website. This may include the referring URL that led you to our website.	We use this information to operate our website, diagnose any problems and to improve the website and your navigating experience. We also use this information to tailor the content that we may send or display to you on our website, and to otherwise personalise your experiences while using our website. We also use this information to better understand how individuals access and use our Services, both on an aggregated and individualised basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.	Legitimate interests
Usage information collected through your use of the website, such as webpages you access, where you clicked and other similar information related to how you have used our website. This also include web log data, such as dates and times you access our website, IP addresses, event information (e.g., web server responses, system crashes etc.)	We use this information to tailor the content that we may send or display to you on our website, and to otherwise personalise your experiences while using our website. We also use this information to better understand how individuals access and use our website, both on an aggregated and individualised basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.	Legitimate interests
Information that is automatically received at the time of access to the website through use of cookies, pixels, redirect links, JavaScript tags and other similar technologies.	We use this information to analyse how our website is used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third party websites.	Consent on use cookies
Information you share voluntarily with us, such as your name and email address when you send us an email asking a question, or submit a form on our website. We will also collect any other Information that you choose to provide to us, such as the contents of a message that you submit through our website.	We use this information to communicate with you, including via email, about our Services; to respond to your inquiries or complaints.	Legitimate interests

The Customer’s Data, the End Users’ Data and the Visitors’ Data is collectively referred to as “data”.

Our legitimate interests are: maintaining and managing the Services, providing the Services to you, improving the Services, processing of the information that you choose to provide to us via email or submitting on our website or by using the Services, preventing fraud or harm to us or to any third party, ensuring your account is adequately protected, ensuring the overall security of our network and services, compliance with any contractual, legal or regulatory obligations under any applicable law.

DATA SHARING

We will share your data with third parties only as listed below:

We will process your data with the assistance of our service providers who assist us with the internal operations of our website and the Services. For example, we engage service providers for data storage, development of the software underlying the Services, and marketing. These service providers are authorised to use your data in this context only as necessary to provide these services to us and not for their own promotional or other purposes
We will share your data with competent authorities if you violate the Terms and Conditions https://madcurve.com/legal/terms-of-service or applicable law.
We will share your data with legal parties and advisors helping us handle your violation of the Terms and Conditions https://madcurve.com/legal/terms-of-service or applicable law.
We will share your data if we are legally required to do so.
We will share information if we are required to do so by a judicial, governmental or regulatory authority.
We will share your data with remarketing services to advertise on third party websites to you after you visited our Services. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Services.

SECURITY AND DATA RETENTION

We will implement measures to secure the data in accordance with applicable lawand reduce the risks of damage, loss of data and unauthorised access or use of data.

We will retain your data for as long as we need it for our legitimate interests, in particular, for the performance of the Services or for the compliance with our legal obligations, resolving disputes, establishing and defending legal claims and enforcing our agreements.

When we have no ongoing legitimate interests to process the data, we securely delete the data or anonymize it or, if this is not possible, securely store the data and isolate it from any further processing until deletion is possible.

INTERNATIONAL TRANSFER

We will internationally transfer your data in accordance with applicable data protection laws.

If we transfer your data for processing at locations outside your jurisdiction, we will abide by data protection applicable laws.

DATA CONTROLLER AND DATA PROCESSOR

The Customer is the data controller of the End Users’ Data, and we are its data processor. The Customer determines the purposes and means of processing of the End Users’ Data. We only process the End Users’ Data on the Customer’s instructions for the purposes of providing the Services to the Customer.

We are the data controller of the Customer’s Data and the Visitor’s Data.

EU AND UK RESIDENTS’ DATA PROTECTION RIGHTS

If you are in the EU or UK, you have the following rights under the GDPR in relation to Horizon Labs processing of the Customer’s Data and the Visitor’s Data:

The right to access - you have the right to request us for copies of your personal data. We may charge you a small fee for this service.

The right to rectifictification - you have the right to request that Horizon Labs correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.

The right to erasure - you have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing - you have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to data portability - you have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

In addition, you have a right to submit a complaint to the relevant supervisory data protection authority.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@madcurve.com .

We may ask for reasonable evidence to verify your identity.

If you are an individual acting on behalf of a legal entity and wish to exercise any of your EU or UK rights, please contact that legal entity.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The CCPA requires companies, such as Horizon Labs, to make certain additional disclosures and provides California residents with the ability to request certain additional information about their personal information and data collected.

Rights of California Residents

CCPA grants California residents certain rights around the personal information and data that collected about them, as below:

(1) Right to Know About Personal Information Collected and/or Disclosed:

California residents have the right to request information about their personal information that we have collected in the preceding 12 months. Upon our receipt of a verifiable request from you, we will disclose the following information:
- the categories of personal information we have collected about you
- the categories of sources from which the personal information was collected
- the business or commercial purpose for collecting your personal information
- the categories of third parties with whom we share your personal information
- the specific pieces of personal information we have collected about you
- the CCPA allows California residents to submit a maximum of two (2) requests in any 12-month period.

(2) Right to Request Deletion of Personal Information:

California residents have the right to request that we delete any personal information about you which we have collected from you.
This right to request deletion does not apply to any of your personal information that is subject to an exception in the CCPA, for example, where we need to retain the personal information to complete a transaction for which the personal information was collected, to prevent fraud or to comply with a legal obligation.

(3) Right to Opt-Out of the Sale of Personal Information:

We do not sell any data and will not sell any data without providing you with prior notice and an opportunity to opt-out, as required by law.

(4) Right to Non-Discrimination:

We do not discriminate against any California resident who exercises any of the rights described above. This includes denying goods or services; charging different prices or rates; or providing a different level of service or quality of goods or services.

Categories of personal information

We collected the following categories of personal information in the last 12 months:

Individual’s information: full name, email, country, city, address, postal code, tel.number.

Business information: company name, brand name, country, city, address, postal code, tax id, vat id, tel.number., number of employees, business area, site.

Sources of personal information: you, directly, third party sites or platforms that you link with your Account, your device.

Business and commercial purposes: are described in “Data collection, purposes and legal basis for processing” section of this Privacy Policy

We disclosed the following categories of personal information for a business purpose in the last 12 months: as described in the “DATA SHARING” section of this Privacy Policy.

CCPA Information Requests

California residents can submit a request by sending us an email to privacy@madcurve.com or submit your request in writing to Aigaiou 83, Flat/Office 104, Lakatamia, 2302, Nicosia, Republic of Cyprus.

We are required to verify the identity of the requester before answering to any request for information or deletion of data.

California residents have the option to designate an authorised agent to submit a request on their behalf. To do this, the authorised agent must inform that an “authorised agent” is submitting the request on a consumer’s behalf and provide all the required information for identity verification along proof of authorisation in the form a notarized authorization form, signed by the California resident who is the subject of the request. We will also contact the California resident directly to verify the request.

We will respond to requests within 45 days and will notify the requester if we need additional time.

If you are an individual acting on behalf of a legal entity and wish to exercise any of your CCPA rights, please contact that legal entity.

COOKIES AND HOW TO MANAGE THEM

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

We use cookies in a range of ways, including:

To keep you signed in
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
To keep our site safe and secure.
For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of our site and service, when you choose to do so.
To deliver and improve our products and services and your overall user experience.

There are a number of different types of cookies, however, our website uses:

Preference Cookies - we use these cookies so that we recognise you on your website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Session Cookies - we use these cookies to operate our Service.
Security Cookies - we use these cookies for security purposes for your account and our service.

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

PRIVACY POLICIES OF OTHER WEBSITES

Our website and application may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Policy under regular review and place any updates on https://madcurve.com/legal/privacy-policy . This Privacy Policy was last updated on the date set forth at the beginning.

HOW TO CONTACT US

If you have any questions about our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to email us: privacy@madcurve.com.