ISINA: PRIVACY POLICY

ISINA is committed to making your experience online satisfying and safe. Your privacy on the Internet is of the utmost importance to us. Please read this Privacy Policy carefully before using our Site(s) (e.g., isina.com). Your use of the Site(s) serves as your acceptance of this Privacy Policy and consent to ISINA’s collection and use of the information you provide as set forth in the Privacy Policy. Please note the Privacy Policy applies only to the Sites operated by ISINA, and not to other websites operated by other third parties to which they may hyperlink to. When you hyperlink to any other website from the Site(s), this Privacy Policy no longer applies and ISINA has no control of the activities of those third party websites. Also, this Privacy Policy does not apply to any information that ISINA may collect from you in any manner other than online. ISINA may revise the Privacy Policy at any time. You should therefore, review it periodically. If you do not want to submit personal information when requested, you will not be able to access certain areas of our Site(s).

INFORMATION COLLECTED:

When you use the Site(s), ISINA may ask you to provide us with Personally Identifiable Information. As used in the Privacy Policy, “Personally Identifiable Information” means any information that can be used to contact or identify you such as your name, your age, gender, home address, zip code, email address, telephone number or payment card number, or government issued identification information. ISINA only generally collect Personally Identifiable Information from you when you voluntarily submit it to us when you register with us; participate in contests, events, or promotions; and/or send us questions or comments via email. ISINA never collects more information than what is reasonably necessary to fulfill your requests and ISINA’s business objectives. We will take appropriate steps to ensure the security and integrity of any information you provide to us. We use the information you provide for such purposes as responding to your requests, improving our Site(s), and communicating with you.

IF YOU ARE UNDER THE AGE OF 13, YOUR PARENT OR GUARDIAN’S CONSENT IS REQUIRED BEFORE YOU CAN PROVIDE ANY PERSONAL INFORMATION TO US FOR PURPOSES OF REGISTRATION AND/OR OTHER ONLINE ACTIVITIES.

Like other websites, ISINA uses “COOKIES” on the Site(s). Cookies are small pieces of information that we place on your computer to help us accurately understand how many times you visit our Site(s) and what content you are most interested in. For example, a cookie will allow us to remember certain things based on your Internet Protocol (i.e., “IP address”), such as the time and duration of your visits, how you navigated through our content and where you exited a particular site. If you do not want us to use cookies, you can easily disable them by going to the toolbar of your web browser, and clicking on the “help” button. Follow the instructions that will prevent the browser from accepting cookies, or set the browser to inform you when you receive a new cookie.

HOW INFORMATION IS USED:

ISINA engages other companies and individuals to perform functions on our behalf, such as, sending postal mail and email, as well as processing credit card payments. These companies and individuals have access to personal information needed to perform their business functions, but may not use your information for other purposes. In addition, from time to time, we may send you special offers, advertisements, or promotional materials, unless you choose to “opt out” from receiving such offers. We may offer promotions in conjunction with a sponsor, and may share your information with these sponsors. We will identify the sponsor to you, and provide you with the opportunity to “opt out”. We may also use your personal information for internal and/or marketing studies, so we can improve the products and services we provide you. We may sell, transfer or otherwise share some or all of ISINA’s assets, including your Personally Identifiable Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. If we receive a lawful court order to release account or other personal information then we will comply with the law (e.g., subpoenas).

HOW WE SHARE INFORMATION:

Since our goal is to help you make meaningful experience, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other ISINA related companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

• With other users
You share information with other users when you voluntarily disclose information on the site (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

• With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

• With other ISINA businesses, which are part of the EntEnt Group family of businesses which, as of the date of this Privacy Policy, includes websites and apps.
We share your information with other ISINA companies to benefit you in two respects: for other companies to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.

We may also share information with other companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other companies to remove users who violate our terms of service, or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms.

• For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

• When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

• To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

• With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our COOKIE POLICY.

CROSS BORDER DATA TRANSFER:

Sharing of information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as where you live. If you are located outside the United States and choose to provide information to us, we may transfer your Personally Identifiable Information to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

HOW WE PROTECT YOUR INFORMATION:

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

HOW LONG WE RETAIN YOUR INFORMATION:

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after three years of continuous inactivity, unless:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

OPT-OUT; AND UNSUBSCRIBE:

If you do not want ISINA to send you emails or special offers from us. When signing up for any of our services it is your choice whether to receive news and offers from us. You may “opt-out” from receiving information from us at any time.

You may “opt out” of email communications from ISINA at any time by clicking on the “unsubscribe” link found tat the bottom of every email. Requests are processed as they are received; however, some email communications are planned in advance and may continue to be sent for a few days following your unsubscribe request.

CHILDREN UNDER 13:

Consistent with the Children’s Online Privacy Protection Act (“COPPA”), ISINA does not knowingly collect or solicit personal information from children. The Site(s) are not directed to children under 13 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personally Identifiable Information without their consent, he or she should contact us at legal@isina.com. If we become aware that a child under 13 years of age has provided us with Personally Identifiable Information without verifiable parental or guardian consent, we will delete such information from our files.

CHANGES TO PRIVACY POLICY:

We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the "EFFECTIVE DATE" date at the bottom of this Privacy Policy. We recommend that you check our Service from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

In case of making significant changes we will notify you before any material changes take effect, through our applications or by other means of communication, for example, by email. To the extent permitted by applicable law so that you have time to review the changes. Your use of the services after receiving such notifications means your acceptance of the amended Policy.

We recommend that you check our Service from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

REVIEWING AND UPDATING PRIVACY PREFERENCES AND PERSONAL INFORMATION:

To update or correct your information and privacy preference, you may write to ISINA at:

ISINA, Inc.
8383 Wilshire Blvd., Suite 339
Beverly Hills, CA 90211
legal@isina.com

YOU CAN USE THE SAME CONTACT INFORMATION ABOVE TO REQUEST INFORMATION UNDER CALIFORNIA CIVIL CODE SECTION 1798.83.

EFFECTIVE DATE:

The effective date of this Privacy Policy is May 24, 2018.

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