ULTRA-RED’s GDPR Compliance

Last revised: March 1, 2020

What’s GDPR?

On May 25th, 2018, the EU’s General Data Protection Regulation (GDPR) came into effect. This significant legislation created a consistent approach towards data protection across Europe, and grants EU citizens & residents more control over their personal data.

At ULTRA-RED, we are serving clients worldwide, and have therefore decided to take a proactive and wholesome approach in complying with the GDPR, and have taken this opportunity to enhance the privacy of our entire userbase – not only in the EU but worldwide.

In addition to maintaining internal and external policies and procedures to ensure and reflect our compliance, we developed tools and features to make it easier for our users to exercise the rights available to data subjects under the GDPR – regardless of their location. These tools also help us to better serve our media partners all over the world, as we enable them to build independent, thriving communities while keeping with global privacy standards.

While our services are offered to website publishers and media partners, our users are in fact the readers and commenters of such partners. This page was created to provide relevant information and to address the concerns of such users.

What do we do at ULTRA-RED to follow GDPR Requirements?

ULTRA-RED respects the privacy of our users and are committed to protect the privacy of Users who access, use or engage with our solutions. In order to make sure we are always working in accordance with GDPR regulations, we are continually working to ensure that both our product and our legal terms are in line with the GDPR and will continue to ensure they keep in line continuously.

What type of information do we collect?

We may collect two types of data and information from our Users.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:

• Subscription Information: When you register to the Services through our website, we may collect from you the following information: full name, job title, email address, phone number, home address, work address, as well as any other information you agreed to share with us.
• Voluntarily Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services.
• Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers, as well as other information which relates to your activity through the Services.
• Other Sources Information: We may search and store parts of the Internet, the Darknet, and other public databases to check for security risks which may negatively affect our clients and Users. We may also collect your personal information that is publicly available on these sources. For the avoidance of doubt, we may collect this personal information solely as part of providing certain security services to our clients and Users. We do not focus our efforts on collecting personal information relating to particular individuals in the public who have no specific relevance to our Users or clients.
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For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

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What do we do with your information?

We use and share Personal information we collect to:

• Provide our Services (e.g., to raise the awareness of our clients and Users to the risks associated with certain types of public information and to address security issues);
• Identify and authenticate your access to certain features of the Services;
• Send you relevant push notifications, which are based on different activities offered by the Services;
• Perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
• Support and troubleshoot the Services and to respond to your queries;
• Investigate and resolve disputes in connection with your use of the Services;
• Detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
• Investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

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How are we protecting your information?

We take great care in implementing and maintaining the security of the Services and safeguarding information that relates to you. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard such information, we cannot be

responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you believe that your privacy was not treated in accordance with our Privacy Policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, it will be advisable to contact us directly at: gdpr@ultrared.ai.

How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at: gdpr@ultrared.ai.

Your privacy is important to us!

If you have any questions or comments regarding our privacy practices, please feel free to reach out to us at info@ultrared.ai.