ASTERI NETWORKS, INC.

PRIVACY POLICY

Effective as of: May 2, 2019

Asteri Networks, Inc. (referred to as “Asteri”, “we”, “us”, or “our”) respects your concerns about privacy and values the relationship we have with you. This Privacy Policy describes our privacy practices with respect to information collected through our websites, applications, the various social networking platforms we use, and any other online service that links to this Privacy Policy, including any webservices and online services we operate (collectively referred to as the “Services”). This Privacy Policy does not apply to information that you may provide to us other than through our Sites, such as over the phone, by mail, or in person unless expressly indicated by us (e.g., by including a link to this Privacy Policy).

By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Asteri Terms of Service on the site (our “Terms of Service”) and is subject to the provisions of the Terms of Service. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy, you should not use our Services. If you do not agree to the terms of this Privacy Policy, please do not use the Sites.

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our Services, this Privacy Policy may change over time. The effective date at the top indicates the last time this Privacy Policy was modified. If we modify the terms of this Privacy Policy, we will notify you via our Services. Your continued use of our Services after such changes are made shall constitute your acceptance of such changes and will be subject to the then-current Privacy Policy. If you cease to use our Services after such changes, your discontinued use shall not constitute acceptance of such changes and such changes shall not apply to you. Any revised Privacy Policy will supersede all previous privacy policies.

Table of Contents

  1. What Information We Collect
  2. Information That You Choose to Provide to Us
  3. Information We Collect Automatically When You Use Our Services
  4. How We Use Your Information
  5. What Kinds of Information We Share
  6. Ways You Might Share Your Information through Our Services
  7. Analytics, Advertising and Other Third Party Services
  8. How We Keep Your Information Safe
  9. Where We Store Your Information
  10. Our Policies Regarding Children (COPPA)
  11. Your Choices
  12. How We Respond to Do Not Track Signals
  13. Your Privacy Rights as California Residents
  14. Law, Assignment, Personal Information Rights
  15. Contact Us

 

  1. What Information We Collect

The information collected when you interact with our Sites and Services falls into two categories: (1) personal information you voluntarily provide such as your name, address, email address, and credit card number; and (2) non-personal information collected through technology, which includes tracking information collected by us as well as third parties.

  1. Information That You Choose to Provide to Us

We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of the Services, participate on our Sites’ social media accounts, provide information about your preferences or interests, request a newsletter or other marketing communications, participate in a promotion or survey, submit user generated content on any part of the Sites that permit it, request customer support, purchase products on our website, submit a job application or otherwise communicate with us. The type of information we may collect may include your name, email address, postal address, photograph, avatar, password, forum posts and comments and other contact or identifying information that you choose to provide

  1. Information We Collect Automatically When You Use Our Services

In addition to any information you provide directly to us, we and our third party service providers may use a variety of technologies that automatically collect certain tracking information when you interact with the Sites or emails sent to you. By using our Sites, you consent to our use of tracking technologies as described below. We automatically collect information about you including:

Device Information. We collect device-specific information when you access our Services from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country of access.

Usage Information. We collect information about your use of our Services, including the type of browser you use, access times, pages viewed, user activity, interactions with other users, and additional “traffic data” (e.g., time of access, date of access, software crash reports, session identification number, access times), your internet protocol address and the page you visited before navigating to our Services.

Information Collected by Cookies and Other Tracking Technologies. We and the third party service providers with whom we work may use various technologies to collect information, and these may include sending cookies, web beacons, Flash Cookies (as defined below), or other tracking technologies.

Cookies. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience.

These cookies may include information about the web pages you view, the links you click and other actions you take on our Sites and in response to our advertising or email newsletters. We and our third party service providers use the information collected for various reasons, including to remember you and your preferences, track your use of our Sites and Services, facilitate your payment transactions, manage access to and use of the Sites, and provide a personalized experience. For more information about cookies, and how to disable them, please see Section 11 Your Choices below.

Location Information. Some of our Sites may deliver content based on your current location if you choose to enable that feature of the Site (e.g., enabling location tracking settings on your mobile device or browser). If you enable the location-based feature, your current location will be stored locally on your device, which will then be used by the Site. If you elect to have a location-based search saved to your history, we will store that information on our servers. If you do not enable the location-based service, or if a Site does not have that feature, the Site will not transmit to us and we will not collect or store location information.

Web Beacons. We may also collect information using web beacons (also known as “tracking pixels,” “action tags,” “ad tags,” “tracer tags,” or “single-pixel GIFs”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage, advertising campaign effectiveness and determine whether an email has been opened and acted upon, and providing you with content customized to your interests.

Other Technologies. There are other local storage and internet technologies, such as local shared objects (also referred to as “Flash Cookies” – data files placed on your device via the Adobe Flash plug-in) and HTML5 local storage that operate similarly to cookies in the way they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions. Flash cookies may be used for various purposes, such as enabling a Flash feature and remembering your preferences. If you choose to adjust your Flash privacy settings in your device, some features of the Sites may not function properly. Please note that these technologies are distinct from cookies, and you may not be able to control them using the standard browser tools and settings. For more information about disabling or deleting information contained in Flash Cookies please visit:  https://helpx.adobe.com/support.html

We may also develop any software or use any software developed by any third party that can be used in our Services to help understand advertising campaign effectiveness.

Information We Collect From Other Sources. We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we might have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

Targeted Advertising. We may allow third parties to use cookies, web beacons and similar technologies to better understand your behavior and browsing activities, so that we can serve you targeted advertising while you are on our Sites and display our ads to you when you visit other third party sites. For example, we work with third party network advertisers who may set these technologies to better provide advertisements about goods and services that may be of interest to you.

We do not control these third party technologies, and they are not subject to this Privacy Policy. We do not authorize these third party network advertisers to use this technology to collect personal information about you and they do not have access to your personal information from us. They may, however, track your Internet usage anonymously (that is, without being able to identify you personally) over time and across other websites in their networks beyond our Sites. To learn more about the use of this information or to opt out of having this information used by our third party network advertisers, please visit the Network Advertising Initiative http://optout.networkadvertising.org/?c=1. (You have to opt-out of each of your web browsing applications and devices separately). However, if you opt-out, we may still suggest offerings to you on our Sites based on your history on our Sites.

  1. How We Use Your Information

We use the information we learn about you to help us personalize and continually improve your experience. We may use information about you for various purposes, including to:

Provide, maintain, optimize and improve our Sites and Services;

Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;

Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;

Send you technical notices, updates, security alerts, support and administrative messages;

Respond to your comments, questions and requests and provide customer service;

Monitor and analyze trends, usage and activities in connection with our Services, including link or combine with information we receive from others to help understand advertising campaign effectiveness;

Personalize and improve our Services and provide advertisements, content and suggest connections or features that match user profiles or activities;

Process and deliver contest entries and rewards;

Link or combine with information we receive from others to help understand your needs and provide you with better service;

Carry out any other purpose for which the information was collected;

Post your user generated content to our Sites as you request;

Serve you targeted advertising, both on our Sites and elsewhere online, based on information we previously collected from you, including your activity on the Sites or activity on third party sites and applications;

Administer our loyalty programs, contests, sweepstakes, promotions, and surveys;

Detect, investigate, and prevent activities that may violate our policies or be illegal;

Perform statistical, demographic, and marketing analyses of users of the Sites and perform statistical, demographic, and marketing analyses of users of the Sites and recipients of our emails, including browsing and purchasing patterns;

Send a friend in-game communications (in these cases, we only use the friend’s information to send the friend the notice, invitation, email or card – we do not store the friend’s information for any longer than reasonably necessary to send the communication to the friend).

Combination of Your Information  To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and non-personal information, and use such information along with information collected from other sources (including third parties), such as demographic information and updated contact information. We or our third party service providers may also use your information to assess the level of interest in, and use of the Sites, our emails, and our other campaigns both on an individual basis and in the aggregate. We may also use and/or combine information we collect off-line or from third party sources to check the accuracy of, enhance and supplement your user records, and to better customize your experience.

  1. What Kinds of Information We Share

Except as disclosed in this Privacy Policy, we do not use or disclose your personal information to any other companies. Although, as disclosed below, we may provide your personal information to our business partners.

in no event will we sell or rent your personal information as part of a customer list or similar transaction without your express permission.

We may share information about you as described below or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

With other users of our Services in connection with the social features of our Services (for example, your username, profile picture you have accumulated in our Services that may be visible to other users of our Services, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);

In response to a request for information if we believe disclosure is required by or otherwise in accordance with any applicable law, regulation or legal process;

To protect the rights, property and safety of Asteri Networks or others;

In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business; or

With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you.

Third Party Service Providers.  We have third party service providers that perform functions on our behalf, such as hosting, billing, marketing, analytics, customer service, fraud protection, etc. These entities have access to your personal information only as needed to perform their functions and they are obligated to maintain the confidentiality and security of that personal information. They are obligated not to use, sell, distribute or alter this information in any way other than to provide the requested services to the Sites.

Third Parties With Whom We Do Business.  We may share your personal information with certain third parties with whom we do business, so that they can provide you with special offers, promotional materials, and similar materials that may be of interest to you. Although our treatment of your personal information is governed by this Privacy Policy, the third party’s treatment of your personal information will be governed by its privacy policy. You may withdraw your consent to our sharing of your personal information with

Affiliated Entities.  We may share your personal information with our affiliated entities for a variety of purposes, including business, operational and marketing purposes.

Other Third Parties.  When Required By Law or In Emergency Situations. We may also use or disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Sites; (b) protect and defend our rights or property, the Sites or our users, and (c) act under emergency circumstances to protect our personal safety, or that of our affiliates, agents, or the users of the Sites or the public.

  1. Ways You Might Share Your Information through Our Services

Social Media.  Our Sites may provide you with the ability to register, log into, “like” or otherwise interact with third party social media services, including, but not limited to, Facebook, Instagram, Twitter, Pinterest, YouTube, and other social media services. These features may enable integration and/or access to your social media accounts. We do not control these social media services or your profiles on these services, and we do not establish privacy settings or rules for how your personal information on these services will be used. If you choose to log on to or submit information through any of these social media services, your personal information will be subject to the applicable social media service’s terms and conditions and your current privacy settings on such social media service. By accessing any social media service, you will be assuming the risk that the personal information you provide on that service may be viewed and/or used by third parties for any purpose. You agree that we are not responsible for any acts or omissions by these social media service providers.

In addition, by choosing to log in to our Sites using your credentials from a social media service, you are asking that service to send us certain information from your account with the service, and you authorize us to collect, store and use such information in accordance with this Privacy Policy.

  1. Analytics, Advertising and Other Third-Party Services

We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons, Flash Cookies, your account information (that you provide to such third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your internet protocol addresses, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked and conversion information. These third parties may also share this information with their customers and clients. This information may be used by us, and such other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interest and better understand your usage. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. Links to the opt-out mechanisms for the third parties that offer such a choice can be found in the following section. This Privacy Policy does not apply to and we are not responsible for, third party cookies, web beacons, Flash Cookies or other tracking technologies.

  1. How We Keep Your Information Safe

We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. These security measures may include practices such as transmitting sensitive information (such as a credit card number) entered while using our Services by using secure socket layer technology (“SSL”). Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.

  1. Where We Store Your Information

All information that Asteri Networks collects through the Services is transferred to, and accessed from, jurisdictions, including the United States where Asteri Networks has its headquarters.

Your Consent Declaration.  By accepting this Privacy Policy, you consent to having your information transferred to, and accessed from, any location worldwide, including the United States for the purpose of providing the Services of Asteri Networks. You also consent to having your information processed and maintained in any location worldwide, including the United States for these purposes. You acknowledge that other jurisdictions may have laws that are different than the laws of your home country.

For visitors to our Services who are based within the European Union, this will involve the processing of your information outside of the European Economic Area, (the “EEA”). If you do not wish your information to leave the EEA, or your home country, please do not provide your information via the Services. If you have already provided your information, and you require us to stop processing your information, please contact us at legal@asteri.io.

We take the privacy of our users seriously and therefore take steps to safeguard your information, including assuring an adequate level of data protection in accordance with E.U. standards. If you provide your information you are aware that certain governmental authorities may have access to your information stored in the United States in accordance with your consent. The legal protections and other rights available to those affected in the event of such access by governmental authorities may be different compared to the protection provided in the EEA countries and may not entirely reflect standards imposed under European law. This includes the fact that governmental authorities may request access to your information without allowing Asteri Networks to inform you of such access, and that such requests for (and grants of) access may not be subject to equal limitations with regard to necessity and purpose as would be in effect under European law. Furthermore, governmental authorities may subject your information to further processing and such further processing may not be subject to equal limitations with regard to necessity and purpose as would be in effect under European law. Finally, you are aware that governmental authorities in the United States may not be subject to the same types or degree of public control by other authorities or courts as present under European law.

  1. Our Policies Regarding Children (COPPA)

Asteri respects the privacy of children and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). This Children’s Privacy Policy describes our practices with respect to the collection of personal information from children under the age of 13. This Site does not knowingly collect, use, or disclose personal information from children under the age of 13 without prior parental consent, except as permitted by COPPA. We do not require children to share any personal information in order to participate on this Site.

As set out in our Terms of Service, you must be at least 18 years old or have the requisite power and authority to access and/or use our Services. If you are between the ages of 13 and 17, you must obtain the consent of your parent or legal guardian to use the Services. Our Services are not intended for children under the age of 13 and we do not knowingly collect any personal information from such children. Children under the age of 13 should not use or attempt to use our Services, and if you are under 13, please do not attempt to use our Services or send any information about yourself to Asteri Networks.

In the event that we learn that we have inadvertently gathered personal information from a child under the age of 13, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a child under the age of 13 may submit a request to delete such information to legal@asteri.io or write to our address listed below.

If you become aware that your child has provided us with Personal Information at one of our Services, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

Send a friend in-game communications (in these cases, we only use the friend’s email address to send the friend the notice, invitation, email or card – we do not store the friend’s email address for any longer than reasonably necessary to send the communication to the friend)

Email newsletters.  We may collect a child’s email address if the child wishes to sign up for our email newsletters. In such instance, the child will be asked to provide his or her email address and the email address of his or her parent/guardian. We will send the child’s parent/guardian a notification email informing them of the child’s request to receive the newsletter by email on an ongoing basis and give the parent/guardian the option to have his or her child’s information removed from our newsletter database. If the newsletter is declined, we will not send the newsletter and will delete any related personal information collected in the sign-up process from our files. If the newsletter is not declined, we will send the newsletter.

Contests or Sweepstakes.  We may collect a child’s email address to enter the child in a sweepstakes or contest or to notify the child that he or she has won or lost a contest or sweepstakes or contest. We will not keep the child’s email address after the promotion or use the child’s email address for any other purpose other than for the promotion. For certain promotions, we may ask that a child give us his/her parent’s email address so we can obtain more personalized information for prize fulfillment purposes if the child wins the promotion or to notify the parent if we need more than the child’s email address to enter the child in the promotion. In the latter event, parents will be sent a notice along with instructions on how they may provide their consent for their child to participate in such promotion.

We may also collect anonymous information automatically from your child’s computer or device, such as the frequency with which the child visits our Site and the pages visited, to support the internal operations of the Site. We collect this information so we can understand and monitor usage of the Site, customize content on the Site and improve the performance of the Site. This information is collected using technologies such as cookies, web beacons, flash cookies and similar technologies. This information is not used to behaviorally target children and we do not permit behavioral targeting on any of our Sites that are directed to children.

Special Circumstances for Information Sharing and Security.  We may share children’s personal information with “Third Party Service Providers” and “Other Third Parties When Required by Law” as disclosed above (see “Who We Share Your Information With”).

Parent’s Rights Under COPPA, you have the right to review and have any of your child’s information deleted from our records. You also have the right to tell us to stop collecting or using your child’s personal information. If you have questions concerning our information practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s personal information in connection with the transaction for which it was originally collected, you may email us at legal@asteri.io For tips on protecting your child’s privacy online, please see the U.S. Federal Trade Commission’s brochure on this topic:  www.onguardonline.gov

  1. Your Choices

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Push Notifications. We may send push notifications or “alerts” to your mobile device to provide information regarding our Services, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications. You may opt-out of receiving promotional messages from us by following the instructions in those messages or by contacting us at legal@asteri.io. If you opt out, we may still send you administrative, transactional, or relationship messages, such as those about your account or our ongoing business relations including but not limited to administrative confirmations, order confirmations, important updates regarding our Services and notices regarding this Privacy Policy and our Terms of Service.

  1. How We Respond to Do Not Track Signals

Because consumers are often unaware that their “do not track” beacons are active, they frequently do not reflect the actual preferences of our users. However, we do respond to the federal Do Not Track signal.

  1. Your Privacy Rights as California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Asteri or one of our subsidiaries may choose to opt-out of our disclosure of personal information to third parties for direct marketing purposes.

If you choose to opt-out, you may email or write to us at the contact information listed in Section 15 Contact Us below.

  1. Law, Assignment, Personal Information Rights

Third Party Content And Links To Third Party Websites.  Our Sites may contain content hosted or served by third parties or link to websites operated by affiliates of PRH or third parties. Please be advised that the practices described in this Privacy Policy for PRH do not apply to information gathered by these third parties. We are not responsible for the actions and privacy policies employed by any third party, and our hosting of third party content or linking to third party websites does not constitute an endorsement of the content or business practices of those third parties.

Public Areas, Forums, Reviews, And Community Areas.  Please remember that any information you share in public areas, such as forums, message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what you disclose and do not post any personal information that you expect to keep private. Please consult our Terms of Use and the applicable guidelines, if any, for use of our forums and other community areas for more information.

Governing Law.  Asteri is headquartered in the State of Louisiana, in the United States. These Sites are published in the United States. We attempt to protect the personal information of all users of our Sites and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to our services, but our family of Sites are located and targeted to United States citizens and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personal information to Asteri. The jurisdiction for our Terms of Service or Privacy Policy is Shreveport, Louisiana and the proper venue for all litigation are the state and/or federal courts in Caddo Parish, Louisiana.

Assignment.  We may change our ownership or corporate organization while providing the Sites and Services. We may also sell certain assets associated with the Sites. As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot ensure that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Rights With Respect To Your Personal Information.  Depending on the jurisdiction, you may have the right to access, correct, delete, restrict use of or receive a copy of, certain information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing such information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services. You may review, update or modify certain of the personal information that is stored in your user account on the Site (if you have one) by logging into the “My Account” or similar area of the Site. If you are located in the U.S., you can also contact us at legal@asteri.io. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on your requests, if allowed or required by applicable laws.

Transfer Of Your Personal Information To The U.S.  If you are located outside the United States, you should be aware that your Personal Information may be transferred to and processed in the United States, the laws of which may have different levels of privacy protection from your country. By using our Sites, you thereby consent to the general use of your information as provided in this Privacy Policy and to the transfer of that information to, and processing and storage of that information in, the United States.

Changes To This Privacy Policy.  As our Sites continue to develop, we may add new services and features to them. In the event that these additions affect our Privacy Policy, or if other changes in our privacy practices or applicable laws necessitate changes to the Privacy Policy, this document will be updated accordingly. If we make a material change in the way we use your personal information, we will provide prominent notice of the change on the Sites or in an email to you. We will not, however, materially change our policies and practices to make them less protective of personal information we have previously collected from you without your express consent.

How to Opt-Out of Email Newsletters.  You may always opt-out of receiving future commercial emails and newsletters from Asteri. We provide you with the opportunity to opt-out of receiving such communications from us by clicking on the “unsubscribe” link within the email you receive. You may also opt out of receiving further communications from us by sending us a message at legal@asteri.io. Please note that your request not to receive unsolicited commercial emails from us will not apply to messages that you request or that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial messages.

  1. Contact Us

If you have any questions about this Privacy Policy, you may contact us as follows:

Asteri Networks, Inc.

P.O. Box 507

Shreveport, LA 71162-0507

 

email: legal@asteri.io

 

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