PRIVACY POLICY

Last Updated April 8, 2025

This privacy policy (“Privacy Policy”) explains how information about you is collected, used and disclosed by Newsbang, Inc. (the “Company”, “we”, “our” or “us”). This Privacy Policy applies to information we collect when you use NewsBang (the “Services”).

When we offer the Services in the United States, we may be subject to the data privacy laws, if any, of the state in which you are located. If you are located in the United States, please refer to your state’s data privacy laws to understand your rights.

When we offer the Services in the European Economic Area (“EEA”), we are subject to the European Union’s General Data Protection Regulation (“GDPR”), which applies across the entire European Union. Our data representative in the EEA is DataRep, who you can reach at datarequest@datarep.com quoting <Newsbang, INC> in the subject line.

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 Terms of Service available at https://www.newsbang.com/agreement/terms-of-service (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.

Modifications

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, so please review it frequently. The 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. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so. You can see when this Privacy Policy was last updated by checking the “Last Updated” date displayed at the top of this policy. Any revised Privacy Policy will supersede all previous privacy policies.

You may opt-out of any revised Privacy Policy by cancelling your account through the settings of the Service you are using. If you are not able to cancel your account through the account settings, please contact us at support@newsbang.com. We are happy to assist you.

Contact Us

If you have any questions about this Privacy Policy or any other matter, please email us at support@newsbang.com. You may also submit feedback through NewsBang by navigating to the “Account” button, clicking “Settings,” and then selecting “Feedback.” When submitting feedback, please include a description and/or screenshot.

You may also write to us at:

Newsbang, Inc.

303 Twin Dolphin Drive, #6054

Redwood City, CA 94065, United States

1. Personal Information We Collect

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household or natural person:

Categories of Personal Information

Specific Types Collected

Identifiers

Name, telephone number, username or other online identifier, email address, account password, and region (at the state level within the U.S. and at the provincial, city and/or district levels in other regions, as applicable).

Internet or other similar network information

In-Service browsing and search history and IP address.

Sensitive personal information

We offer certain features to enhance your experience that collect and process your sensitive personal information (also referred to as “sensitive personal data” or “sensitive data” under applicable laws and regulations).

We will collect your account log-in, along with any required security or access code, password, or credentials allowing access to an account.

Other than these types of information, we do not collect any sensitive personal information.

Please see Limit the Use of My Sensitive Personal Information for more details on your privacy rights relating to your sensitive personal information.

User-generated profiles and content

User profile and avatar, occupation and hobbies.

Device information

Hardware model, device size and model, operating system and version, unique device identifiers, country of access, crash reports, request and referral URL’s and/or system activity details.

Software information

Which version of software and what updates a user has installed or uses, and/or the presence of required plug-ins.

Use information

Preferred language, access times, activity, and interactions with our Services, such as the user click-through and session duration.

2. How We Collect Information

We only collect personal information that is necessary for providing the Services in accordance with the principles of legitimacy, legality, necessity, and good faith. We collect internet information, device information, software information, use information from you automatically when you use the Services.

In addition to personal information we automatically collect, you may directly share your personal information with us in the following ways:

· Identifiers. You may share personal information when you create an account with us.

· Customer Support and Other Communications. When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including any contact or identifying information, or any other information you deem helpful.

In addition to the information that we collect directly from you, we also collect certain information from our third party sources listed below (our “Third Party Sources”):

· Third Party Account Registration Services. You may log in to our products or Services through a third party service. In the event you log in to our product or Services through a third party service, after your authorization, we will collect personal information provided to us by the third party. We have identified the names of some third party services that allow you to register for and log in to our products or Services. Please see the links below to learn more about the personal information practices of such services and the personal information collected from the associated third party.

Third Party	Privacy Policy	Personal Information We Receive
Google LLC	Link	Avatar, name, and email address
Meta Platforms, Inc.	Link	Avatar, name, and email address
Apple, Inc.	Link	Avatar, name, and email address

· Third Party Services and User Information. We use third parties to provide analytics and payment services. These third parties may use 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. This Privacy Policy does not apply to, and we are not responsible for third party cookies, web beacons, or other tracking technologies (if any). We have identified the provider names of the third-party analytics and payment services we use. Please see the links below to learn more about the data practices of these third party service providers:

Third Party	Privacy Policy	Personal Information We Receive
AppsFlyer, Inc.	Link	Internet information and activity, device information, and use information
Sensors Data	Link	Internet information and activity, device information, and use information
Stripe, Inc.	Link	Email address

In particular, and in the past twelve (12) months, we collected the following categories of personal information:

Categories of Personal Information		How We Collect It
Identifiers		Directly from you when you create or manage an account with us, and where applicable, from our Third Party Sources.
Internet or other similar network information		Directly from you when you access our Services from a computer and/or other device.

User-generated profiles and comments		Directly from you when you create or manage an account with us, or when you post comments within our Services.
Device information		Automatically from you, when you access our Services from a computer and/or other device, and where applicable, from our Third Party Sources, such as unique device identifiers, device size and model.
Software information		Automatically from you when you use our Services, and where applicable, from our Third Party Sources.
Use information		Automatically from you when you use our Services, including the user’s interaction within our Services, such as the user click-through and session duration.

3. How And Why We Use Your Personal Information

We will only use your personal information with your consent.

The personal information you permit us to collect and process allows us to provide you with the Services, give you notices regarding the Services, carry out our obligations and enforce our rights in connection with the Services, and fulfill any other purpose for which you provide it.

The internet, device, software, and use information we collect helps us to improve the Services and deliver a better and more personalized experience by allowing us to estimate our audience size and usage patterns, store information about your preferences, improve features in the Services, and recognize when you use the Services.

Before using your personal information beyond the purposes outlined in this Privacy Policy, we will inform you in a timely and reasonable manner, obtain your consent, and explain why we would like to use your personal information.

In some cases, we may use your personal information for our legitimate interests or those of a third party, including to provide, maintain, develop, and protect our Services and features, to provide you with support, to send you administrative and technical communications regarding the Services, to conduct and enhance our internal business practices and organizational efforts, and to prevent bad behavior such as fraud, violations of our policies, unauthorized access and modification of the Service and our systems or disclosure of certain information.

In rare cases, we may need to use your personal information to comply with our legal and regulatory obligations, including to conduct checks to identify our users and verify their identity (where appropriate), to comply with certain laws and regulations, to conduct audits, and to engage in inquiries or investigations by law or regulatory bodies.

Because we are continuously improving our products and Services, we may launch optimization functions from time to time which may increase or change the scope, purpose and/or method of collecting and using your personal information. In the event any optimization functions increase or change the scope, purpose, and/or method of collecting and using your personal information, we will clearly explain it to you by updating this Privacy Policy and providing you with notice.

In particular, and over the past twelve (12) months, we collect and use the below types of personal information in the following contexts for the following reasons:

Context of Use	Personal Information Collected	Used…
Account registration	Username, name, email address, phone number and password.	With your consent For our legitimate interests (fraud prevention, user service and management)
Account management	Region, avatar, username, name, nickname, personal profile.	With your consent For our legitimate interests (user service and management) To comply with our legal and regulatory obligations
Search	Device information, log information, in-Service browsing and search history, timing, and times. We collect this information to quickly match the content you need and the content you may be interested in, as well as to improve our products and services.	With your consent For our legitimate interests (user service and management)
Customer service and dispute resolution	We may need you to provide your real name, mobile phone number, email and other contact information, and city / region information to help you solve problems. We may also collect your communication information with us (including text / picture / audio and video / call record form), and other necessary information related to your request.	With your consent For the performance of our contract To comply with our legal and regulatory obligations For our legitimate interests (user service and management)
Product optimization	We may collect your device information, log information (operation log, service log), bugs and crashes reports to conduct analysis on user behavior and product performance, in order to improve our services in the future.	With your consent For our legitimate interests (user service and management)

4. Who We Reveal Your Personal Information To

You may ask us to share your personal information in a portable format with a third party of your choosing by submitting a verifiable request in accordance with Section 9 (How to Exercise Your Rights) of this Privacy Policy. We do not sell your personal information.

In certain circumstances, we may disclose (i.e., share, release, disclose, disseminate, make available, transfer, or otherwise communicate) personal information with others for our operational and business purposes. We will only disclose your personal information for legal, legitimate, necessary, specific and clear purposes, and will only disclose the personal information necessary to provide services. At the same time, we will enter into agreements with third party recipients where necessary and require them to process your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. Except as described in this Privacy Policy, we will not disclose your personal information to any other third parties. In particular, we may disclose personal information to:

· Affiliates. We may disclose your personal information to our affiliates, including companies within the Newsbang, Inc. group and the professional advisors of the Company, such as lawyers, auditors and insurers, where necessary in connection with such professional advisor services. Our affiliates are subject to the processing scope and purpose restrictions of this Privacy Policy. If an affiliate wants to change the purpose of processing for your personal information, we or the affiliate will ask for your authorization again.

· Service Providers. We may disclose your personal information to our service providers, who work on our behalf for the purposes described throughout this Policy and receive and process personal information for our business purposes. All of our service providers are contractually obligated to protect personal information to the highest degree required under law. If you refuse to allow our service providers to collect the personal information necessary for providing specific services, you may not be able to use such services in our platform. Our service providers are not authorized to use your personal information for any other purpose. Our service providers include:

Service Provider	Categories Shared in the Last 12 Mos.	Purpose
OpenAI, LLC (ChatGPT)	User-generated profiles and content Use information	To provide AI-powered functionalities
Meta Platforms, Inc.	User-generated profiles and content Use information	To provide AI-powered functionalities and for marketing purposes
Google LLC	Email address User-generated content	For region-related functions (at the state level within the U.S. and at the provincial, city and/or district levels in other regions, as applicable), marketing and to understand how our users interact with our Services
AppsFlyer Inc.	Device information (such as unique device identifiers) Use information	To assess the effectiveness of our advertising campaigns
Sensors Data	Device information (such as unique device identifiers, size and model) Use information (such as user’s interaction within our Services including user click-through and session duration)	To assess the effectiveness of our advertising campaigns
Stripe, Inc.	Device information (such as unique device identifiers)	To provide payment services, if and when such service become active
Microsoft	User-generated profiles and content Use information	To provide AI-powered functionalities
Llamaindex	User-generated content	To provide AI-powered functionalities
MailChimp	Email address	For marketing
Recombee	User-generated profiles and content Use information	To provide AI-powered functionalities

We also may disclose personal information with any competent law enforcement body, regulatory body, government agency, court or any other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise or defend our legal rights, or to protect the vital interests of you or someone else.

In case of a merger, acquisition, bankruptcy, or liquidation of our Company where the transfer of personal information may be involved, we will require new companies and/or organizations that come into possession of your personal information to continue to be bound by this Privacy Policy. If the new company or organization wishes to change its practices with respect to the collection and processing of your personal information and as outlined in this Privacy Policy, such new company or organization will ask for your consent before doing so.

We may also disclose anonymized, aggregated information (no longer personal information) with selected third parties for statistical or research purposes.

5. Where Your Personal Information Is Held

We store information about users on servers primarily located in the United States. If you are accessing our Services from outside of the United States, please know personal information you submit may be transferred to and stored on servers in the United States. The data protection and other laws of the relevant states of the United States might not be as comprehensive as those in your country. By submitting your data and/or using our Services, you acknowledge that your data might be transferred to, stored and processed in the United States and other countries where we may choose to store data in the future.

We ensure that all personal information collected directly from the EEA and stored in the United States complies with GDPR requirements. We implement the standards outlined in Exhibit A as a binding internal obligation. Exhibit A contains the provisions from the Standard Contractual Clauses (“SCCs”) approved by the European Commission (even though we collect the data directly rather than receiving it from another data exporter) that are not already covered in this Privacy Policy. This approach ensures that direct collection and storage in the United States of EEA personal information adheres to the same standards of data protection required by the European Commission for international transfers. If you would like further information about our practice with regards to collecting and storing personal information in the United States, please contact us by sending an email to DataRep at datarequest@datarep.com quoting <Newsbang, INC> in the subject line.

6. How Long Your Personal Information Is Retained

We will not retain your personal information for longer than necessary to achieve the purposes set out in this Privacy Policy. When it is no longer necessary to retain your personal information, we will delete and/or anonymize it. In the event the jurisdiction in which you are located has personal information retention requirements that are not compatible with those listed in this Privacy Policy, the requirements of such jurisdiction with respect to personal information retention shall control.

Category of Personal Information		Our Retention Practice
Identifiers		We retain these types of personal information for as long as needed to provide our Services, respond to your questions, complaints, or claims, or as required by law.
Internet or other network activity
Messages content
User-Generated profiles and content
Device information
Use information

7. How Long Your Personal Information Is Kept

Typically, we will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to your questions, complaints, claims or as required by law. We will not retain your personal information for longer than necessary for the purposes set out in this policy. We will delete your personal information in accordance with our data retention and deletion policy. In cases where we are legally obliged or permitted to keep your personal information longer, we may restrict the processing of your data instead of deleting it (e.g., by restricting access to it, anonymization), as far as legally permissible or required. In the event the jurisdiction in which you are located has personal information retention legal requirements that differ with those listed in this Privacy Policy, the rules and regulations of such jurisdiction with respect to personal information retention shall control. Generally, different retention periods apply for different types of personal information as follows:

Category of Personal Information		Our Retention Period or Practice
Identifiers		as long as is necessary for the purposes set out in this Policy
Internet or Other Network Activity		as long as is necessary for the purposes set out in this Policy
User-Generated Profiles and Content		as long as is necessary for the purposes set out in this Policy
Device Information		as long as is necessary for the purposes set out in this Policy
Software Information		as long as is necessary for the purposes set out in this Policy
Use Information		as long as is necessary for the purposes set out in this Policy

8. How Your Personal Information Is Kept Secure

We implement commercially reasonable technical, administrative, and organizational measures to protect personal information from being accidentally lost, used or accessed in an unauthorized way. Notwithstanding the security measures that have been taken and the legal requirements that have been implemented, we cannot guarantee the security of your personal information when you use or communicate through unsafe channels. Therefore, you should also take measures to ensure the security of your personal information, such as changing your account password regularly. We will notify you and any applicable regulator of a suspected data security breach when we are legally required to do so.

9. Your Personal Information Rights

You have specific rights regarding your personal information. This section describes your rights. You, or an authorized agent acting on your behalf, may exercise your personal information rights by submitting a verifiable request directly or through our Services (see Section 9 (How To Exercise Your Rights) below).

If an authorized agent submits a request to know or delete your personal information, we require you to (i) provide your authorized agent with signed permission to exercise your rights, (ii) verify your own identity directly with us, and (iii) directly confirm with us your authorized agent has permission to submit the request.

Your Right To…		Details of Your Right
Know About Our Practices With Respect To Your Personal Information		Upon receipt of a verifiable request, we will confirm whether or not we are processing your personal information, and inform you of the categories of personal information we collected about you, the categories of sources for the personal information we collected about you, our basis or purpose for collecting such information, and the third parties with whom we shared your personal information.
Access Your Personal Information in a Portable Format		You can access the personal information submitted to us at any time. Upon receipt of a verifiable request, we will deliver a copy of your personal information to you or another entity free of charge and in a readily useable format.
Correct Your Personal Information		In the event you discover the personal information we have about you is incorrect, upon receipt of a verifiable request we will correct such information and direct our service providers, contractors, or other third party affiliates to similarly correct the information.
Delete Your Personal Information		You may delete your personal information by deleting your account with us. In addition, subject to certain lawful exceptions, upon receipt of a verifiable request we will delete your personal information from our records and direct our service providers, contractors or other third party affiliates to delete your personal information from their records unless they have obtained your separate consent for processing.
Cancel Your Account		You may cancel your account with us anytime through a verifiable request, by deleting your account directly through our Services, or by contacting us at support@newsbang.com. After you cancel your account, (i) you will no longer be able to log in and use our products and services with this account; (ii) the content, information, data, and records under your account will be deleted or anonymized (unless otherwise required by applicable law); and (iii) after the cancellation of an account is completed, it cannot be recovered.
Limit the Use of Your Sensitive Personal Information		Under various applicable privacy laws, you have the right to request that we limit our disclosure or use of your sensitive personal information to only what is necessary to perform our Services or provide features as requested by you. We self-limit the use of your sensitive personal information by only collecting and using your sensitive personal information as necessary to provide our Services when you choose to activate and use features that necessitate such information. We do not use your sensitive personal information for any other purposes. If you have any questions about our use of or your rights with respect to your sensitive personal information, please contact us at support@newsbang.com.
Limit the Use of Your Ancillary Personal Information		In some cases, you may provide us with personal information that is not strictly necessary for our provision of the Services to you (for example, an avatar or nickname). You can restrict our use of any of your personal information unnecessary for the provision of our Services to you by navigating to the settings of the Service you are using and deleting such personal information. If you are not able to restrict our use of your personal information unnecessary for the provision of our Services to you through the account settings, please contact us at support@newsbang.com. We are happy to assist you. In the event you request us not to use ancillary personal information, we will only collect the personal information necessary to perform the functions of our Services. Your refusal to provide certain categories of personal information will only result in your inability to use certain functions of our Services that require that information but will not affect your normal use of other functions of our Services.

10. How To Exercise Your Rights

If you have established an account with us, to easily access, view, update, correct, delete or port your personal information, or to update your subscription preferences (if applicable), please sign into your account and visit the account settings. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time by deleting your account or contacting us. If you make a request to delete your personal information and that data is necessary for the products or Services you have purchased (if applicable), the request will be honored only to the extent it is no longer necessary for any Services purchased (if applicable) or required for our legitimate business purposes or legal or contractual record keeping requirements.

To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us at support@newsbang.com.

Only you, or a person authorized by law to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.

The verifiable request must:

Provide sufficient information including phone number and email address that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

If your account is lost, you can verify through verification email or contact customer support to reset your password. However, in this process, you need to provide some personal information to verify your identity.

Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

We will send you confirmation of receipt of any verifiable request within ten (10) business days of its receipt. We endeavour to respond substantively to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing.

If you have an account with us, we will deliver our written response to that account or by the method you submitted your request. If you do not have an account with us, we will deliver our written response by the method you submitted your request.

If we cannot comply with a verifiable request, we will explain our reasons to you in writing, if applicable. Where we inform you that we cannot comply with a verifiable request, you may submit an appeal to us within a reasonable period of time following your receipt of our decision to refuse to process your request. In the event you submit an appeal, we will respond to you in writing within forty-five (45) days and disclose any action taken or not taken in response to your appeal and an explanation of our decisions. In some U.S. states, you may have the right to submit your concerns with the result of the appeal to your Attorney General.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another without hindrance.

Typically, you will not have to pay a fee to access your personal information or to exercise any of your privacy rights. However, except in relation to consent withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request. We may also refuse to comply with your request in such circumstances.

We may decline to comply with your request under the following circumstances, and in accordance with applicable laws and regulations:

Where it is related to our obligations under law and/or regulation
Where it is related to national security and national defense security
Where it is related to public safety, public health and major public interests
Where it is related to criminal investigation, prosecution, and trial
Where there is sufficient evidence to show that you have subjective malice or abuse of rights
Where responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations
Where trade secrets are involved
Other conditions stipulated by applicable laws and regulations

11. Your Controls

We give you control over our use and collection of your personal information. In this section, we detail your controls.

Control

Details

Our Use Of All Personal Information

You can restrict our further use of your personal information by cancelling your account through the settings of the Service you are using.

If you are not able to cancel your account through the account settings, please contact us at support@newsbang.com. We are happy to assist you.

In the event you request us not to use your personal information any further, we will halt processing of your personal information unless necessary for the performance of our contract with you, or if processing is necessary to comply with a legal obligation or to protect the rights and interests of ourselves or a third party.

Push Notifications

You can deactivate push notifications by changing your “Notifications” via your device.

12. Financial Incentive Notice

We will not discriminate against you in any manner prohibited by applicable law for exercising any of your controls or rights over your personal information. However, we may offer you certain permitted financial incentives related to the collection and/or retention of your personal information, such as programs, benefits, or other offerings. These may be deemed a financial incentive, loyalty program, or price or service difference under applicable law. We are providing you with the information contained in this section so that you may make an informed decision on whether to participate in our programs, such as:

· Limited-Time Promotions, Contests, or Sweepstakes: From time-to-time, we may offer certain financial incentives limited to a specific time period, such as limited-time sweepstakes, contests, and other promotions. In exchange for participation in these promotions, you may be offered a financial incentive, such as a prize. As part of these limited-time promotions, contests, or sweepstakes, we may collect your personal information, such as your username, name, email address, and/or phone number. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program.

· One-Time Promotions: We may offer you one-time promotions from time-to-time, and may collect your personal information related to the one-time promotion, such as your username, name, email address, and/or phone number. Participation in a one-time promotion is governed by the applicable terms and conditions for the program.

· Surveys: We may also offer users the opportunity to participate in surveys. In exchange for participation you may be offered a financial incentive. As part of these surveys we may collect personal information, such as your name, username, email, phone number, preferences, experiences, beliefs, opinions, and other responses to the survey questions.

· Referrals: We may offer you certain financial incentives when you refer a friend to use our Services. To make a referral, we may require you to provide us with your username, name, telephone number, and/or email address.

Such financial incentives may not be available at all times. The amount and terms of such financial incentives will be presented to you at the time of the offer. The monetary value of any financial incentive will be based on our good-faith estimate of the benefit we receive when you accept our financial incentive offer. We calculate that monetary value by comparing our costs to offer you the financial incentive to the benefit we receive when you accept our offer.

By participating in any of our promotional programs, you agree that the benefits are reasonably related to the value of your personal information collected and retained. Participation in any promotional program is always optional, and you can terminate your participation by contacting us at support@newsbang.com.

13. Permission Authorizations

In order to provide you with convenient and high-quality services, we may request some permissions on your device. If you have previously granted us permission authorizations, you may choose to turn off some or all permissions in the setting function of the client or device you are using. The methods for granting or withdrawing permissions may be different on different devices.

Authorization		Services and Functions
Address book authorization		You can find and add contacts from your address book in some of our Services.
Microphone authorization		You can send voice messages in some of our Services.
Camera authorization		You can use the camera to take photos, capture and upload videos and pictures, and participate in platform activities authorized by you on certain Services.
Photo album and storage authorization		You can upload your photos/pictures/videos and locally cached video and audio files by authorizing the access to your photo album, so that you can change your avatar, publish and share comments, or engage with other features on certain Services.
Calendar authorization		You can add reminders created on certain Services to alert you at the right time.

14. How We Respond to Do Not Track Signals

We currently do not respond to Do Not Track signals, but we are continuously reviewing our practices to ensure the best experience for our users.

15. Our Policies Regarding Children

As set out in our Terms of Service (available at https://www.newsbang.com/agreement/terms-of-service), you must be at least 18 years old and have the requisite power and authority to access and/or use our Services. If you are still a minor (i.e., under 18 years old), you must obtain the consent of your parent or legal guardian to use our Services.

If you are the legal guardian of a minor, please pay attention to whether the minor uses our Services or provides his or her personal information after obtaining your authorization and approval. If you have questions about the personal information of the minor under your guardianship, please contact us at support@newsbang.com. We are happy to assist you.

Our Services are not intended for children under the age of thirteen (13) (a “Child” or “Children”), and we do not knowingly collect any personal information from Children. Children should not use or attempt to use our Services, and if you are a Child, please do not attempt to use our Services or send any information about yourself to us.

In the event that we learn that we have inadvertently gathered personal information from a Child, 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 may submit a request to delete such information by contacting us at support@newsbang.com. We are happy to assist you.

16. Filing a Complaint

We hope that we can resolve any query or concern you raise about our use of your personal information. If you would like to make a complaint regarding our privacy practices, please contact us at support@newsbang.com . If you are an EEA resident, you may also contact our EEA representative by sending an email to DataRep at datarequest@datarep.com quoting <Newsbang, INC> in the subject line. We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved, you may be able to lodge a complaint with a supervisory authority or other authority local to you.

User Location

File a Complaint…

European Union

With the data protection supervisory authority corresponding to your location within the European Union. You can find your data protection regulator here.

United States

Certain United States data privacy laws may enable you to lodge a complaint with your attorney general or another regulatory body.

EXHIBIT A

SECTION I

Clause 1

Purpose and scope

(a) The purpose of the clauses outlined under this Exhibit A (the “Clauses”) to the Privacy Policy is to list additional measures we adopt based on the SCCs. Some of our measures have already been reflected in the Privacy Policy, and this Exhibit A only describes the measures that we adopted but not covered in the Privacy Policy. We adopt these measures as a self-imposed obligation to ensure GDPR compliance when collecting personal data directly from individuals in the EEA and storing it in United Staetes.

(a) The terms not defined here have the same meaning as in the Privacy Policy. Where these Clauses use terms that are defined in GDPR, those terms shall have the same meaning as in GDPR.

(b) These Clauses shall be read and interpreted in the light of the provisions of GDPR. These Clauses shall not be interpreted in a way that conflicts with rights and obligations provided for GDPR.

Clause 2 – 7

[Reserved]

SECTION II – OBLIGATIONS

Clause 8

Data protection safeguards

We warrant that we have used reasonable efforts to ensure our US-based operations and systems implement appropriate technical and organizational measures to satisfy our obligations under these Clauses.

8.1 – 8.4 [Reserved]

8.5 Security of processing

(a) In the event of there is a personal data breach, we will take appropriate measures to address the personal data breach, including measures to mitigate its possible adverse effects.

(b) In case of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, we will without undue delay notify the competent supervisory authority pursuant to Clause 5. Such notification shall contain i) a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), ii) its likely consequences, iii) the measures taken or proposed to address the breach, and iv) the details of a contact point from whom more information can be obtained. To the extent it is not possible for us to provide all the information at the same time, we may do so in phases without undue further delay.

(c) In case of a personal data breach that is likely to result in a high risk to the rights and freedoms of natural persons, we will also notify without undue delay the data subjects concerned of the personal data breach and its nature, together with the information referred to in paragraph (e), points ii) to iv), unless the we have implemented measures to significantly reduce the risk to the rights or freedoms of natural persons, or notification would involve disproportionate efforts. In the latter case, we will shall instead issue a public communication or take a similar measure to inform the public of the personal data breach.

(d) We will document all relevant facts relating to the personal data breach, including its effects and any remedial action taken, and keep a record thereof.

8.6 Sensitive data

Where we collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions or offences (hereinafter “sensitive data”), we will apply specific restrictions and/or additional safeguards adapted to the specific nature of the data and the risks involved. This may include restricting the personnel permitted to access the personal data, additional security measures (such as pseudonymisation) and/or additional restrictions with respect to further disclosure.

8.7 Transfers

We will not disclose the personal data to a third party located outside the European Union, unless the third party is or agrees to be bound by these Clauses. Otherwise, a transfer by us may only take place if:

(i) it is to a country benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679 that covers the transfer;

(ii) the third party otherwise ensures appropriate safeguards pursuant to Articles 46 or 47 of Regulation (EU) 2016/679 with respect to the processing in question;

(iii) the third party enters into a binding instrument with the us ensuring the same level of data protection as under these Clauses, and we provide a copy of these safeguards to such third party;

(iv) it is necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings;

(v) it is necessary in order to protect the vital interests of the data subject or of another natural person; or

(vi) where none of the other conditions apply, we have obtained the explicit consent of the data subject for a transfer in a specific situation, after having informed him/her of its purpose(s), the identity of the recipient and the possible risks of such transfer to him/her due to the lack of appropriate data protection safeguards. In this case, we shall provide a copy of the information provided to the data subject.

Any transfer is subject to compliance by us with all the other safeguards under these Clauses, in particular purpose limitation.

8.8 Processing under the authority

We will ensure that any person acting under our authority, including a processor, processes the data only on our instructions.

8.9 Documentation and compliance

(a) We will keep appropriate documentation of the processing activities carried out under our responsibility.

(b) We will make such documentation available to the competent supervisory authority on request.

Clause 9

Use of processors

(a) We, as the data controller, maintain the right to engage processors as necessary for our Services. A list of current processors is maintained in Section 4 (Who We Reveal Your Personal Information To) of the Privacy Policy. We will notify data subjects if we make changes to this processor list. We ensure all processors are bound by appropriate contractual terms to protect personal data in compliance with applicable data protection laws.

(b) Where we engage a processor to carry out specific processing activities, we will do so by way of a written contract that provides for the same data protection obligations as those binding us under these Clauses. We will ensure that the processor complies with the obligations to which we are subject pursuant to these Clauses.

(c) We will maintain a copy of the processor agreement and any subsequent amendments. To the extent necessary to protect business secrets or other confidential information, including personal data, we may redact the text of the agreement.

(d) We will remain fully responsible for the performance of the processor’s obligations under its contract with us. We will document any failure by the processor to fulfill its obligations under that contract.

Clause 10

Data subject rights

(a) We will cease processing personal data for direct marketing purposes if the data subject objects to it.

(b) We will not make a decision based solely on the automated processing of the personal data (hereinafter “automated decision”), which would produce legal effects concerning the data subject or similarly significantly affect him/her, unless with the explicit consent of the data subject or if authorised to do so under the laws of the country of destination, provided that such laws lay down suitable measures to safeguard the data subject’s rights and legitimate interests. In this case, we will:

(i) inform the data subject about the envisaged automated decision, the envisaged consequences and the logic involved; and

(ii) implement suitable safeguards, at least by enabling the data subject to contest the decision, express his/her point of view and obtain review by a human being.

(c) Where requests from a data subject are excessive, in particular because of their repetitive character, we may either charge a reasonable fee taking into account the administrative costs of granting the request or refuse to act on the request.

(d) We may refuse a data subject’s request if such refusal is allowed under the laws of the country of destination and is necessary and proportionate in a democratic society to protect one of the objectives listed in Article 23(1) of the GDPR.

(e) If we intend to refuse a data subject's request, we will inform the data subject of the reasons for the refusal and the possibility of lodging a complaint with the competent supervisory authority and/or seeking judicial redress.

(f) We accept that the data subject may be represented by a not-for-profit body, organisation or association under the conditions set out in Article 80(1) of the GDPR.

(g) We will abide by a decision that is binding under the applicable EU or Member State law.

(h) We agree that the choice made by the data subject will not prejudice his/her substantive and procedural rights to seek remedies in accordance with applicable laws.

Clause 11-12

[Reserved]

Clause 13

Supervision

(a) The supervisory authority of one of the Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the offering of goods or services to them, or whose behaviour is monitored, are located, shall act as competent supervisory authority.

(b) We agree to submit ourselves to the jurisdiction of and cooperate with the competent supervisory authority in any procedures aimed at ensuring compliance with these Clauses. In particular, we agree to respond to enquiries, submit to audits and comply with the measures adopted by the supervisory authority, including remedial and compensatory measures. We shall provide the supervisory authority with written confirmation that the necessary actions have been taken.

SECTION III – LOCAL LAWS AND OBLIGATIONS IN CASE OF ACCESS BY PUBLIC AUTHORITIES

Clause 14

Local laws and practices affecting compliance with the Clauses

(a) We warrant that we have no reason to believe that the laws and practices in the United States (or other third country of destination where our processor is located) applicable to the processing of the personal data by us, including any requirements to disclose personal data or measures authorising access by public authorities, prevent us from fulfilling our obligations under these Clauses. This is based on the understanding that laws and practices that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679, are not in contradiction with these Clauses.

(b) We declare that in providing the warranty, we have taken due account in particular of the following elements:

(i) the specific circumstances of the transfer, including the length of the processing chain, the number of actors involved and the transmission channels used; intended transfers; the type of recipient; the purpose of processing; the categories and format of the transferred personal data; the economic sector in which the transfer occurs; the storage location of the data transferred;

(ii) the laws and practices of the third country of destination– including those requiring the disclosure of data to public authorities or authorising access by such authorities – relevant in light of the specific circumstances of the transfer, and the applicable limitations and safeguards;

(iii) any relevant contractual, technical or organisational safeguards put in place to supplement the safeguards under these Clauses, including measures applied during transmission and to the processing of the personal data in the country of destination.

(c) We warrant that, in carrying out the assessment, we have made our best efforts to gather all relevant information and we will continue to ensure compliance with these Clauses.

(d) We agree to document the assessment and make it available to the competent supervisory authority on request.

Clause 15

Obligations in case of access by public authorities

15.1 Notification

(a) We agree to notify, where possible, the data subject promptly if we:

(i) receive a legally binding request from a public authority, including judicial authorities, under the laws of the country of destination for the disclosure of personal data transferred pursuant to these Clauses; such notification shall include information about the personal data requested, the requesting authority, the legal basis for the request and the response provided; or

(ii) become aware of any direct access by public authorities to personal data transferred pursuant to these Clauses in accordance with the laws of the country of destination; such notification shall include all information available to us.

(b) If we are prohibited from notifying the data subject under the laws of the country of destination, we agree to use our best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible. We agree to document our best efforts in order to be able to demonstrate them on request.

(c) We agree to preserve the information pursuant to the paragraphs above for the duration of these Clauses and make it available to the competent supervisory authority on request.

15.2 Review of legality and data minimisation

(a) We agree to review the legality of the request for disclosure, in particular whether it remains within the powers granted to the requesting public authority, and to challenge the request if, after careful assessment, we conclude that there are reasonable grounds to consider that the request is unlawful under the laws of the United States (or the country of destination where our processor is located), applicable obligations under international law and principles of international comity. We will, under the same conditions, pursue possibilities of appeal. When challenging a request, we will seek interim measures with a view to suspending the effects of the request until the competent judicial authority has decided on its merits. We will not disclose the personal data requested until required to do so under the applicable procedural rules.

(b) We agree to document our legal assessment and any challenge to the request for disclosure and, to the extent permissible under the laws of the United States (or the country of destination where our processor is located), make the documentation available to the competent supervisory authority on request.

(c) We agree to provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request.

Clause 16

[Reserved]