“Non-Personal Data” - data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Information” – both Personal and Non-Personal Data.
“Software” – software solutions developed and owned by the Company, including, but not limited to marketing platform, SDK and other products, software solutions, business solutions as applicable.
“Services” – result and/or any benefit you receive / may receive / supposed to receive while using the Software or entering into agreements (insertion orders, master service agreements, terms and conditions, etc.) with us.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of state of California, USA applicable to the subject matter, and Regulation as determined above.
1. INFORMATION THAT WE MAY COLLECT
As you use the Software and/or the Services and/or interact with the Site, we may collect and process Information from and about you. We obtain such Information from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to use the Services, the Site and/or the Software in full if that Information is necessary to provide you with the service or if we are legally required to collect it.
If we do combine Non-Personal Data with Personal Data the combined data will be treated as Personal Data for as long as it remains combined.
A. Personal Data Provided by You
Contact and Account Information. When you access or otherwise use the Site or register / sign up for the Software, we may collect certain contact information from you, such as your first and last name, company name, city, state and zip code, email address, office and mailing address, phone number, password, skype name, counter-party's names, company website or other contact details to help you with your experience as established in registration form. This Information is required by us to verify your identity, to establish your account, and set up the Services. After completing registration, you may have the ability to provide optional account information (e.g. your photo).
In case you act as an agent for a third party during registration or use of the Site and/or the Services you should be duly authorized to provide us with necessary amount of the data of such third party. By registering and creating an account, you represent and warrant that you are duly authorized.
Billing information. When using the Software and/or the Services, you may be required to provide additional information such as credit card number, account number, beneficiary’s name and details, account holder, bank name, PayPal information, PayPal account details or other banking and payment information ("Billing Information"), as well as information necessary to secure your transactions, including the whitelist of IP addresses. If you submit payment information in connection with your use of the Services, we utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address, and phone number. In such circumstances, the third party service provider, and not the Company, stores your payment information on our behalf.
The user signing in the Software warrants that he is a legal representative of the business entity and is entitled to provide this kind of information regarding such entity.
Other Information. You may provide us with Information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms, surveys, blog subscription); information you provide in connection with our contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”). Participation in our surveys or contests, filling our forms etc. is voluntary and you may choose whether or not to participate and therefore disclose this information. Such information will be used for purposes of monitoring or improving the use and satisfaction of this site, provide you with assistance and to notify the winners and award prizes (if any).
B. Information Automatically Obtained From Your Interactions with the Service, the Site and/or the Software
In addition to any Information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain Information whenever you visit or interact with the Site or while using the Software and/or the Services.
Tracking technologies that may be used to collect Information from your interactions with the Service, the Site and/or the Software include, without limitation, the following:
Cookies and Similar Technologies. We use “cookie” technology to collect additional website usage data and to improve the Site, the Software and the Services.
Log Data. When you use the Software, the Services and/or the Site, our servers automatically record information that your browser sends whenever you visit Site (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, language preferences, the web-pages you visit, the search terms you use, and any advertisements you may click on. We use this Information to understand and analyze trends, to administer the Site, to learn about user behavior on the Site, to improve the Software and the Services, and to gather demographic information about our user base as a whole. We may also use this Information in our marketing and advertising services as described below.
Links to Other Websites. The Site may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your device, collect data or solicit Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Site and/or Service. We encourage you to read the privacy policies or statements of the other websites you visit.
Service Information. In order to provide the Services to you and to improve your experience, we may collect Information that is created or provided by you in connection with your use of the Services, the Site, the Software (collectively, “Service Information”). Service Information may include Personal Data.
- Device information – when you access the Site, the Services, the Software using a mobile device, we collect certain device information, including the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may also collect other unique device identifiers such as advertiser ID.
- Location information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).
C. Information Collected through Social Media
The Software, the Services and/or the Site may contain links to other websites, including Social Media. Such links provide you the ability to connect with us through Social Media channels.
Please, notice that when you click on such Social Media links and leave the Site, we do not have any control over such third party Social Media. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services (including Social Media) to which links or access are provided through the Site. We encourage you to read the privacy policies or statements of the other websites you visit.
Please, notice that when you use the Software, the Services and/or the Site, or post on forum, chat room, board, or Social Media service, the Personal Data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Data you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. By submitting actions pointed above you grand us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.
If you do not wish to have this information to be shared, do not initiate these connections and actions.
2. HOW WE MAY USE YOUR INFORMATION
We may use Information collected from as described above in the following ways:
To provide the location-based Services we may collect, use, and share precise location data, including the real-time geographic location of your access to Site and/or Software. Where available, location-based Services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used to provide and improve location-based products and services. We may also be obliged to process such information in order to comply with applicable Law and/or Regulation.
Notifications. We may send you notices from time to time relating to your account, the Software and the Services provided to you. These may include Service confirmations and/or notifications, renewal notices, invoices etc. We may also send you service-related announcements when we decide it is necessary to do so; for instance, if the Site, the Software and/or the Services is temporarily suspended for maintenance, or the provision of the Service is delayed or canceled etc. These communications are necessary to the operation of the Software, the Services and/or the Sites and are not promotional in nature. You may opt-out of receiving these communications, though, it may lead to termination of your use/access of the Software and the Services due to impossibility of maintenance of contact with you.
Analytics, surveys, researches. Service Improvement. As it was mentioned above, from time to time, we may conduct surveys, question forms, test features etc. (“Improvement Activities”), and analyze the data we have to develop, evaluate and improve these features, all in order to improve the Site, the Services, the Software and think of new and exciting features for our users. We may use any Information collected from you by such Improvement Activities (including Information obtained with Cookies and similar technologies, Log Data, Service Information, Other Information): (i) to personalize user's experience and to allow us to deliver the type of content and service offerings in which you are most interested; (ii) to improve the Software in order to better serve you and/or to provide the Services more effectively; (iii) to ensure continuous improvement and development of the Software; (iv) to administer the Site, the Software and accompanying Services and to diagnose possible problems; (v) for statistical and analytical purposes.
We may collect information regarding users’ activities on the Site, the Services and the Software and from our other products and services. This information is aggregated (so no end-user can be identified) and used to help us provide more useful information to our users and to understand which parts of the Site, the Services or the Software are of most interest.
We may collect information such as occupation, language, zip code, area code, device identifiers, referrer URL, location, and the time zone where Software is used so that we can better understand user/customer behavior and improve the Site, the Software, the Services and advertising.
Promotional Offers and other Marketing Purposes. We may use Information obtained from you (e.g. your Contact Information) for the Marketing Purposes. For example, by subscribing to our newsletter you may receive tips and announcements straight to your email account. We may also send you promotional material concerning the Software, the Services and/or the Site or our partners’ services (which we believe may interest you).
In some of our email messages, pop-ups, banners and other advertising materials we may use a “click-through URL” linked to content on the Site or the Software. When users/customers click one of these URLs, they pass through a separate web server before arriving at the destination page on the Site or the Software. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format users can read, and they tell us whether mail has been opened. We may use this Information to reduce or eliminate messages sent to users/customers.
Please note that even if you unsubscribe from our promotional or marketing emails, we may continue to send you Service-related notifications, or reply to your queries and feedback you provide us. Moreover, we may still use and share your Information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
Protection of our interests, Safety. We may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Software, the Services and/or the Sites and protect the rights and property of the Company, its users and/or partners. As a way of example, we may collect Personal Data to form conversion IP whitelist.
Compliance with Legal and Regulatory Requirements. We may also use/disclose your Information collected by us in order to comply with applicable legal requirements, industry standards and our policies. We may disclose your Information in situations that we believe to be: (1) emergencies involving potential threats to the physical safety of any person or property if we believe that your Information in any way relates to that threat; (2) you use the Services, Site of Software in a way that we believe may be illegal or inappropriate.
Business Process Management. We can provide some of your Personal Data to our partners, contractors, affiliates if it is necessary for performing agreements between you and us (e.g. Agreements, Insertion Orders etc.) or if it is an essential part of how the Software works. Key points of such Data transfers are highlighted in Section below.
Note to Users Resident in the European Economic Area: If you are located in the European Economic Area or Switzerland, we may process your Personal Data for the abovementioned purposes when:
- you have consented to the use of your Personal Data (e.g., we may seek to obtain your consent for our uses of cookies or similar technologies);
- we need your Personal Data to provide you with services and products requested by you under our contractual relations, or to respond to your inquiries;
- we have a legal obligation to use your Personal Data; or
- we have a legitimate interest in using your Personal Data. In particular, we have a legitimate interest in using your Personal Data to ensure and improve the safety, security, to suppress illegal activity on the Site, the Software or with the use of the Services, to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the rights and property of the Company, its users and/or partners etc.
3. HOW WE MAY SHARE AND TRANSFER THE INFORMATION
We pay particular attention to the protection of your Personal Data. We may disclose the Personal Information we collect about you as described below or otherwise share your information with the following entities, including those outside the European Union or the European Economic Area:
Internal Concerned Parties. We may share your Information with companies, who are our subcontractors, as well as with our employees, in order to provide you with the Software, the Services and/or the Sites. Our employees have limited access to your Information on a “need to know” basis and are bound with non-disclosure contractual obligations.
Service Providers. We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, payment processing. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Our third party service providers are based mainly in the European Economic Area (EEA) and USA. If you are located in the EEA or Switzerland, when transferring your Personal Data outside the EEA or Switzerland, we will comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA or Switzerland and make sure that our third party service providers can guarantee a high level of Personal Data protection. These guarantees may include, e.g. use of standard contractual clauses adopted by the Commission (EU) or participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by the EU-US Privacy Shield.
We use such third-party service providers:
|Google Analytics||Google, LLC; Alphabet Inc. (parent company)||Analyzing Data for marketing purposes and improvement of the Software and Services||https://policies.google.com/privacy?hl=en||End user’s location and IP address, device ID, lifestyle information|
|MailChimp, Mandrill||The Rocket Science Group, LLC||Mailing||https://mailchimp.com/legal/privacy/||Full name, contact information, location and IP address|
|Hetzner Online||Hetzner Online GmbH||Data storage and database maintenance services||https://ru.hetzner.com/hosting/legal/datenschutz||All categories of Information|
|Servers.com||Servers.com||Data storage and database maintenance services||https://www.servers.com/legal/privacy-policy||All categories of Information|
We may also share your Information with other service providers for the abovementioned purposes, with which we will establish cooperation.
Compliance with laws and law enforcement entities. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law and Regulation, we may disclose any Information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Company or a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service, Site or Software and any equipment used to make the Service available, or to comply with the law. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by applicable law, statute, court or administrative order.
Other Third Parties. We may also make certain Non-Personal Data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, functionality available through the Service, statistics and other use. This is not linked to any Personal Data that can identify any individual person.
We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by law or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). However, please, note that some data recipients may be located outside the EEA and Switzerland, as it was mentioned above. By submitting your Personal Data, you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.). We will comply with applicable legal requirements for the transfer of Personal Data to countries outside of the EEA or Switzerland. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection. As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Moreover, before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation.
4. HOW WE PROTECT YOUR INFORMATION
We use such measures to keep your Information safe:
Employees. We chose our employees after a strict background check regarding their business reputation, whether involved in scandals, etc. Each employee has to take probation during which we check his skills, but also his reliability, honesty, his fit for our corporate culture, law abidingness, etc. We limit access to your Information for our employees on a “need to know” basis. The employee gets access only to that Information that he directly needs to perform his work. Moreover, each employee is bound with contractual non-disclosure obligations (NDA), which will remain in force even after the termination of the relationship between the employee and the Company.
Data transmission between Company’s subdivisions and employees is not allowed, except when directly authorized by the top management personnel or expressly provided in their job description.
Staff training. To make sure Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Company. We give our employees a briefing (training) regarding the following: on safety and rules for handling Data (including the requirements of the GDPR); when moving away from the workplace, the employee blocks his/her computer; it is forbidden to install any software on the workstations without the permission of the system administrator; it is forbidden to store Data (in any form) in unprotected locations (environment); it is forbidden to take Data carriers outside the office.
We constantly improve our Data protection mechanisms and methods of training employees.
Access control. We maintain industry-standard physical, electronic and procedural safeguards designed to protect Personal Data in our possession from loss, misuse, and unauthorized access. We provide following security measures: access to the building by an individual card through the security point; access to the offices through code and fingerprint; in different offices there are different code and fingerprints for access, which allows the employee to enter only to the office assigned to him (access to all offices is provided only to the top management personnel); access to the working computer by password and login (only the employee knows); access to the Software with Data only by the employees user ID and password.
Relations with contractors and third party service providers. In addition to abovementioned security measures that we provide when cooperate with third party service providers, we also choose our contractors (subcontractors) on the same principles, on which we select employees. Contractors come for a specific task. They delete all received Data after the job is completed. They also sign the NDA on the same principles as our employees. They receive access only to the Data that is directly necessary for the task.
We choose only those contractors and third party service providers that have long been on the market and have established themselves as exceptional companies with a perfect reputation. An exception may be the need to use a contractor from a completely new sphere in which there is still no established market and companies a long time working on it; in such cases, we will implement all the necessary additional measures of data control and protection, as required by law.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of storage, is 100% secure. While we strive to use commercially acceptable means to protect your Information, we cannot guarantee that the Site or the Data stored during your use of the Software is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Site, the Platform, the Software or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
Moreover, notice that you are solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting Information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk.
Your obligations regarding security of your Data are the following: not to disclose your contact information and other data, which allows/enables unauthorized access to the Software, Services and/or Site or any other actions, connected to the Software, Services and/or Site on your behalf; make reasonable efforts to secure your actions in Internet and your use of the Software, Services and/or Site. You are solely responsible for the correctness, appropriateness fullness etc. of the provided data and warrant to us that you have all rights to provide us with such data.
5. YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION
Regarding your Information you are entitled to:
A. the right to express and withdraw consents, including reading or registering cookies,
B. the right to objection, including:
- objection to the processing of your Data for direct marketing purposes;
- reasoned objection to the processing of your Personal Data within the legitimate interests of the Company, for reasons related to your particular situation;
- objection to the processing of your Data for any other purpose, pointed in this Policy. Notice, that such objection may lead to impossibility to use the Site, the Services, the Software and/or may lead to termination of our contractual relations with you (if any);
C. the right to access your Data, including obtaining a copy of the Data to be processed (in written, or by providing access to your Personal Data on our server (other type of storage), or sending it to you by email or on CD/DVD/other device, or in other applicable way, etc.);
D. the right to rectify (correct) your Personal Data if your Data in our possession is inaccurate or incomplete;
E. the right to delete your Data if your Data is no longer necessary for the purpose for which it was collected, and Company has no grounds for its processing, e.g. based on your consent or legal obligation. Moreover, you may ask to delete your Data at any time, but in such case it may lead to impossibility to use the Site, the Services, the Software and/or may lead to termination of our contractual relations with you (if any);
F. the right to transfer your Data provided to us by you in a machine-readable format, e.g. if you want to share it with another service provider;
G. the right to restrict processing of your Personal Data by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
In addition to the abovementioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.
In order to fulfill your request, we are required to verify your identity so that your data does not go to an unauthorized person. In case if you send a relevant request on behalf of company (in cases where Personal Data may be applicable to the company as pointed in Law and/or Regulation), we should be sure you are duly authorized to receive such data about such company. As a way of example, but not limited to: if you send request from the same email you used during registration and with the same signature you usually use in your emails (if there were any between us), we reasonably consider that it is you, who asks for your Personal Data. In cases if you use other email address (not the one who registered on the Site/signed up for the Services) we shall ask for additional verification (unless such additional emails/persons were pointed as trustworthy during registration).
Company, within one month of receiving your request, shall provide you with information about the actions taken in connection with your request. If necessary, the deadline for your request can be extended up to 60 days due to the complex nature of the request or the number of requests.
If your request turns out to be unreasonable or excessive, in particular due to its repeated nature, we may request a reasonable fee for the fulfillment of the request or refuse to take action in connection with the request.
In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you and the relevant Data Protection Authority know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in your personal account, in national news, on the Site or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if you are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
6. RETENTION PERIOD
We will retain your Personal Data for as long as necessary to provide the Services, provide access to the Software/Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable time. We make commercially reasonable efforts to store your Personal Data no longer than for 3 months. After such period, we make a revision of it. However, as it was mentioned above, we may delete your Personal Data at any time before such 3-month period terminates, in case if purpose we collected it for is no longer applies. We make no warranties your Personal Data will be available for any specific period of time (3 months, or less or more etc.). Please consider that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
Please, notice that under applicable regulations, we may keep records containing client/customer/user Personal Data, billing information, communications and anything else as required by applicable laws and regulations or on a basis of legitimate interest (e.g. for defending our interests).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing Site and/or Software. Children under the age of 16, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Site and/or Software, unless their parent provided verifiable consent or as part of the child account creation process (if this type of account is applicable). We do not knowingly collect Personal Information from children under 16, or equivalent minimum age depending on jurisdiction. If we learn that we have collected the Personal Data of a child under 16, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with Law and/or Regulation.
8. OTHE PROVISIONS AS REQUIRED BY LAW
A. Do Not Track Signals
We use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords to track you over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. As well, be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
B. Notice for Minors
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate (e.g. in the event that the modifications materially alter your rights or obligations hereunder).
10. NO RIGHTS OF THIRD PARTIES
11. QUESTIONS AND COMPLAINTS