Effective date: March 1, 2023

This privacy policy (this “Policy”) describes the types of information that LifeStreet Corporation and LifeStreet International (including their subsidiaries and affiliates – “LifeStreet Inc”, “WebAMG Sarl”, “WebAMG Ukraine”, “LifeStreet” or “we”) collects from users of its corporate Web site, https://lifestreet.com, as well as any Web site that directly links to this Policy when you click on “Privacy” or “Privacy Policy” in the Web site footer (each, a “Site”). This Policy also describes the services we provide to our clients (our “Services”) as well as the information we collect pursuant to our provision of our Services. Unless otherwise provided in this Policy, this Policy does not cover our offline data practices.

This Policy is effective as of the date set forth above. We encourage you to check this Policy from time to time. If we make material changes that will affect any personal information that we have already collected from you, we will make reasonable efforts to notify you of the changes and to give you the opportunity to opt out. Your continued use of this Site constitutes your acceptance of the current posted Policy. If you have questions about our privacy policy, please contact us as provided below.

Definitions

The capitalized terms listed below have the following meanings when used in this Policy:

• Aggregated Information is information about groups or segments of individuals that use our Services, e.g., how many people accessed a Property on a given day or from a given geographical area. Aggregated Information does not include Personally Identifiable Information.
• Anonymous Information is information that does not (and cannot reasonably be used to) identify an individual. However, Anonymous Information when combined with Personally Identifiable Information becomes Personally Identifiable Information.
• Client refers to a mobile application developer, advertiser, or publisher that directly or indirectly uses our Services.
• Cookies are files that Web servers place on an Internet user’s computer that are designed to store basic information and to recognize the user’s browser. As discussed below, we use Cookies in connection with your use of the Site. We also use Cookies in connection with our provision of Services, which permits us to associate your device with other information that resides in our database so that we can personalize your experience with the Services. These Cookies do not store any Personally Identifiable Information. As with all Cookies, you can set your browser to notify you before you receive these Cookies so that you have the chance to accept them. You can also set your browser so that it will not accept Cookies. However, if you disable Cookies, then you will not have access to many features that make your interaction with our Site and the Services more efficient and some of the Services may not function properly.
• Device Information refers to the information automatically collected from a consumer’s device pursuant to our Client’s use of our Services. Device Information is Anonymous Information (i.e., not Personally Identifiable Information).
• Personally Identifiable Information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.
• Property is an application or Web site that is owned, operated, or controlled by a Client.
• Web Beacon (or a “clear GIFs” or “pixel tag”) is software that can be used to display an image (usually a single pixel) on a website, email, or other communication. A Web Beacon is usually used to transfer an individual’s unique user identification (often in the form of a Cookie) to a database in order to associate that individual with previously acquired information about that individual. We use Web Beacons keep track of your online behavior (e.g., the websites you visit, the mobile applications you use, etc.) in order to help us to determine your interests.

Your use of the site

You can visit and navigate through our Site to information about our company, our Services, and the products offered without telling us who you are and without revealing any information that can personally identify you. As discussed above, we use Cookies and other technology on our Site in connection with a hosted Web site analytics service that helps us better understand how our visitors use the Site. We review the anonymous information provided by these uses of Cookies (e.g., browser type, operating system, IP address, Internet domain) to better understand how our visitors navigate through the Site; learn what content is being reviewed; administer the Site; manage online advertising on the Site; and communicate with you about your LifeStreet account, your interactions with the Services or your contacts’ interactions with the Services. No Personally Identifiable Information is collected through our use of these Cookies.

You may wish to request information about our Services, the Site, or our company. In order to facilitate the distribution of this content, we may ask you to provide Personally Identifiable Information. Based on the nature of your request, we may also ask for additional information, such as how you anticipate you (or your company) will make use of our Services and how you heard about us. We store the information you provide for archival purposes and for our own marketing purposes if we feel that it is consistent with the nature of the inquiry. We will not use this information for any other purpose unless you give us permission to do so. Again, all of this information is provided by you on a voluntary basis only and is not required in order for you to use and enjoy our Site.

Our Sites may offer opportunities for you to register for free information, seminars, or demonstration copies of our Services. These registration forms are often linked to LifeStreet mailing lists, and require users to provide Personally Identifiable Information (such as name and e-mail address), which we use to send users information about our company and our Services. We also use this information to contact site visitors by e-mail for marketing purposes if they have granted us permission (on the mailing list form or other forms on our Site) to send it to them, and for administrative purposes such as providing time and location of seminars. Users may also be contacted by phone or postal mail for marketing purposes

Public Fora

We may at times offer you the option to post content to a blog, message board, or chat room. In the course of doing so, you may provide Personally Identifiable Information. You should be aware that any visitor may view your postings on a blog, on a message board, or in a chat room. Further, any information that you may post, including your profile information, is available to all users of that blog, message board, or chat room, and thus is neither private nor confidential. We cannot guarantee the security of such information that is disclosed or communicated online in these public areas, and you do so at your own risk. We reserve the right at any time, in our sole discretion, to remove any content that you may post on any blog, message board, or chat room and/or restrict your access to any blog, message board, or chat room. We further reserve the right to republish any user postings from blogs, message boards, or chat rooms elsewhere on the Internet in any format.

Your interactions with the user community programs we have with third party social networking sites such as Facebook may be displayed on this Site and used by us in a manner consistent with this Policy. Your interactions may also be displayed in your social networking profile. These interactions may be viewable by anyone that has access to that profile, depending on your privacy settings with the social networking site. You should review the privacy policies of these social networking sites to understand who may have access to your interactions and how the Site may use them.

Our provision of services

LifeStreet provides application Services that enable its Clients to deliver advertising to consumers based on their behavior and interest. If you interact with a Property or otherwise with our Services, we may collect the following information so that we can provide our Service to our Client:

• Geographic location (e.g., current city).
• Carrier.
• Device make/manufacturer.
• Operating system.
• Property name.
• Activities regarding ad interaction (e.g., views, clicks, and other actions).
• Language settings.
• Connection speed.
• IP Address.
• Android Advertising ID.
• Browser type.
• Apple’s Identifier for Advertiser.
• E-Mail address in case we have contract relations and(or) e-mail was listed in a registration form for receiving free information and Company updates.

All of this information is Anonymous Information (i.e., not Personally Identifiable Information). Once we collect this Device Information, it may be encrypted or hashed depending on the sensitivity of the information in question. We may also combine your Device Information with other, similar data from other consumers to create Aggregated Information

We use Cookies, Web Beacons, and other technologies to collect and use Device Information. Our Cookies are not specific to any of our Clients. Accordingly, if you choose to opt-out of our Cookie for any LifeStreet Client, you will be opted out for all LifeStreet Clients. If you would like to opt out of our use of Cookies for these purposes there is a simple procedure to follow. Click here to replace your LifeStreet Cookie with an opt-out LifeStreet cookie.

When our Client uses our Services to request that we serve an ad to you, we collect Device Information that we use as provided in this Policy (you grant the necessary consents for such collection to occur when you download or use our Client’s application). We use Device Information as follows:

• To provide our Services to our Clients.
• To improve our Services.
• To deliver targeted advertisements.

We may track and use Device Information over time and across multiple Client applications (or Online Behavioral Advertising) and/or combine Device Information with other Anonymous Information in order to deliver targeted advertisements through the Services

As discussed above, we do not automatically collect any Personally Identifiable Information from you (unless you volunteer such information via our Site) but may obtain Personally Identifiable Information from our Clients in connection with their use of the Services. If you are a Client, we collect the following types of from you in order to provide our Services to you. Some of this information we must collect is Personally Identifiable Information:

• Registration information when you create your account with us. In order to register for the Services, we require you to provide us with a username and password and your contact information, such as first and last name, email address, company name, company address.
• Transaction information when you request information from us, pay us for your use of the Services, or receive a payment from us in connection with your use of the Services, such as your contact information, bank or financial account information, credit card or debit card numbers, and other information we need in order to respond to your request or process your payments.
• Technical, viewing, and usage information that relates to your interaction with the Site, such as your location, the unique identifier or Internet Protocol address of the device or computer you use to access the Site, and the amount of time you spend on the Site.

Opting out

If you decide to opt out of our targeted advertising, then ads we deliver to you on behalf of our Clients will be delivered to you based only on the Anonymous Information that is automatically transmitted when an ad request is received by our ad servers. In such case, any unique identifier such as the Android Advertising ID, Apple’s Identifier for Advertising, or the LifeStreet Cookie will not be used to deliver ads to you. The Anonymous Information that is automatically transmitted includes your device type, browser type, Internet service provider, information about the general content of the site or page displayed on your browser, and other Anonymous Information provided by the Web site or content provider. When you opt out, our systems will know that you have opted out and will not attempt to assign other unique identifiers in the future. PLEASE NOTE, however, that if you erase or otherwise alter your browser’s or device’s cookie file (including upgrading certain browsers) or use a new or different device, you may need to opt out again.

You may opt of receiving targeted ads from us by clicking here.

As discussed above, we do not automatically collect Personally Identifiable Information from you (unless you volunteer such information) but may obtain Personally Identifiable Information from our Clients in connection with use of the Services.

Opting out on your mobile device. Open https://www.lifestreet.com/optout and instructions there. Please note, using another device with same SIM-card will require to perform opt out again.

Data security

We are committed to protecting your Personally Identifiable Information from unauthorized access, use, or disclosure. LifeStreet takes reasonable steps to protect all data in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. LifeStreet controls and physically protects media and establishes appropriate operating procedures to protect documents, computer media, input/output data and, system documentation from unauthorized disclosure, modification, removal, and destruction.

Prior to disposal, LifeStreet checks all items of equipment containing storage media to remove or securely overwrite data and licensed software. Devices containing sensitive information are physically destroyed or the information is destroyed, deleted or overwritten.

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure all information we collect from loss, misuse, unauthorized access or disclosure, alteration, or destruction. However, no data security measures can be 100% secure. As such, we cannot guarantee the security of data in our possession or data that is on, or transmitted via, the Internet.

Data privacy

LifeStreet complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States, respectively. LifeStreet has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, LifeStreet commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact LifeStreet at [email protected] lifestreet.com/privacy.

LifeStreet has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Where a complaint cannot be resolved by any of the before mentioned recourse mechanisms, individuals may have a right to invoke binding arbitration under the Privacy Shield Panel as a recourse mechanism of ‘last resort’.

The Federal Trade Commission (FTC) has jurisdiction over LifeStreet compliance with the Privacy Shield.

With whom we may share your information

We will share your information with third parties only in the ways that are described in this Policy. The information we collect is not shared, rented, or sold to any third-parties.

Personally Identifiable Information. We may provide your Personally Identifiable Information as follows:

• To companies that provide services – to help us with our business activities such as responding to your inquiries, offering customer service, or processing credit card payments. These companies are authorized to use your information only as necessary to provide these services to us. We can provide Personally Identifiable Information with partners who help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the LifeStreet and the broader advertising ecosystem.
• Cross-border transfers of shared information with EU and Swiss entities are covered by Contractual Addendums under Article 28 (GDPR).
• As required by law or governmental authority, such as to comply with a subpoena, or similar legal process.
• LifeStreet reserves the right to use or disclose personal information provided to LifeStreet in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
• When we believe in good faith that disclosure is necessary to protect our rights (such investigating and/or enforcing possible violations of this Policy or another agreement with you), to protect your safety or the safety of others; or to investigate fraud.
• To any person or entity (and their employees and agents) that seeks to acquire any of our business or assets via acquisition, merger, sale, reorganization, liquidation or similar business transfer.
• To any other third party with your prior consent to do so (in which case your Personally Identifiable Information will be subject to that third party’s privacy policies).
• In cases where an EU individual’s data is transferred onward to third parties pursuant to the Privacy Shield, Lifestreet may be potentially liable.

Anonymous Information

In addition to the types of disclosures of your Personally Identifiable Information that we may make as set forth above, we may share your Anonymous Information with our Clients and other third parties as provided in this Policy. As discussed above, we may combine your Anonymous Information with similar information of other consumers to create Aggregated information, which we may share with our Clients and the general public in the course of marketing our Services use otherwise for general analytics of the Services and our Site.

Enforcement

We use a self-assessment approach to assure compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and consistently applied. However, if you believe we have not complied with the terms of this Policy, please feel free to contact BBB or us as provided below.

Data integrity

We process data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the owning person. To the extent necessary for those purposes, we take reasonable steps to ensure that data is accurate, complete, current, and reliable for its intended use.

Changes in our business or this policy

As we continue to develop our business, we may sell certain or all of our assets. In the event that all or substantially all of our assets are acquired in a transaction, information we have collected from use of this Site or in connection with our provision of Services (including your Personally Identifiable Information) may be an asset that is reviewed and transferred. Such a transaction will be disclosed per the guidelines below.

This Policy may be amended from time to time. If we decide to revise this Policy, we will post any revised Policy on this Site and/or to other places we deem appropriate so our visitors can be aware of what information we collect, how we use it, and under what circumstances, if any, we may disclose it. If, however, we are going to use your Personally Identifiable Information in a manner different from that stated at the time of collection, we will post a notice on the Site no less than 30 days in advance of such use.

Links to other websites

The Site may contain links to other Web sites. We are not responsible for the privacy practices or the content of such other Web sites.

Children

This Site is not intended to nor does it seek to receive any information from children under the age of 13. We do not use the Services with the intent to solicit data from or market to children under the age of 13 and in fact ask that children under the age of 13 refrain from providing Personally Identifiable Information when they use our Services. If you believe that your child has provided Personally Identifiable Information to us, feel free to contact us as provided below and we will delete it from our files.

Access or update your information

We provide you with the opportunity to review, modify, and delete any Personally Identifiable Information that you have previously provided to us pursuant to your visits to our Site or your use of our Services. You can send us an email or write to us as set forth below.

LifeStreet and Google Authorized Buyers Program

LifeStreet, as a participant in the Google Authorized Buyers Program, has committed to following the Program’s guidelines. It is recommended that you familiarize yourself with how Google’s products utilize data from websites and apps that employ their services, which is explained in the partner-facing documentation. To learn more, please refer to Google’s Platform program policies.

Contact information

Questions, comments, or complaints regarding this Policy or LifeStreet’s data collection and use practices can be sent to:

LifeStreet Corporation
981 Industrial Rd
Suite D
San Carlos, CA 94070

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.