I. INTRODUCTION

ADAPTIVE PLUS INC., registered at 515 suite, 575 Market Str, San Francisco, USA ("we," "us" or "our") takes your privacy seriously. This Privacy Policy ("Privacy Policy") explains our data protection policy and describes the types of information we may process when you install and/or use the Fax Connect software application for mobile devices (the "App", "our App") and explains how we and some of the companies we cooperate with process that information.

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy Policy applies to all users, and others who access the App ("Users").

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ the FOLLOWING PRIVACY POLICY CAREFULLY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

II. INFORMATION WE PROCESS

There are two general categories of information we process.

II.1 Information that you submit

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide complete functionality of the App and perform the requested services.

• Contact Information: Your name, email address, and phone number, when you register or contact us.
• Fax Content: The documents and images you upload and fax using the App. This includes the content of the faxed document, recipient fax numbers, and sending information. We need this data to transmit your fax.
• Payment Information: If you purchase credits or a subscription, we process your payment information (e.g., credit card details). This information is usually processed by a third-party payment processor, but we may retain limited transaction information (e.g. Transaction ID, subscription status).
• Address Book Access: If you grant permission, we may access your device's address book to allow you to easily select fax recipients.

II.2 Information that is Processed Automatically

When you use the App, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the requested services and features of the App.

We use third-party automatic data processing technologies to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise, or respond for how the third parties process your personal data, that might be collected by their own means (not through our App). Due to the fact that some of our third parties declare themselves controllers for the purposes of the GDPR, any information request regarding your personal data should be directed to such third parties.

• Information related to your device. When you use a mobile device to access our App, we may monitor one or more "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device identifier enables generalized reporting or personalized content and ads by the third parties. What data can be processed:
  • type of your mobile device and operational system version which is installed on your mobile device;
  • region information of your mobile device;
  • region associated with your SIM card;
  • Internet Protocol ("IP") address;
  • Identity for Advertisers / Advertising ID which is a string of numbers and letters that identifies your individual smartphone or tablet.
• Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App. The App may use automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies starts automatically when you start using the App.