Privacy Policy

MINORS (CHILDREN) POLICY
We are committed to protecting children’s personal information and comply with the strictest privacy
laws out there. Therefore, in order to become a registered user, one must meet our minimum age
requirements or provide us with a verifiable consent from a parent or legal guardian, please review
our Terms of Service (Minimum Age Requirements section) for more information.
We do not knowingly collect or solicit personal information from anyone under the minimum age
specified in our Terms of Service. If you do not meet minimum age requirements, please do not
register for an Account, do not send any information about yourself to us or other users of the
Platform, including your name, address, telephone number, or email address. In the event that we
learn that we have collected personal information from an individual under the minimum age
requirements without a verifiable consent from a parent or legal guardian, we will delete that
information as quickly as possible. Please contact us if you believe we may have collected information
from a person not meeting our minimum age requirements.

HOW LONG WE KEEP YOUR INFORMATION
We will only keep your personal information for as long as it is necessary for the purposes set out in
this Privacy & Cookie Policy, unless a longer retention period is required or permitted by law (such as
tax, accounting or other legal requirements) or up until such time when you withdraw your consent
for processing it. When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize it, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.

DATA STORAGE
We use servers of AWS, Azure and Google Cloud Platform to safely store your information. The data
centers where we store your information are located in the United States. Please keep in mind that the
data protection and privacy laws of the United States may not be as comprehensive as the laws in
your country. For example, personal data transferred to the United States may be subject to lawful
access requests by federal and state authorities in the United States. By providing your personal
information, you consent to any transfer of your data and processing in accordance with this Privacy
& Cookie Policy.

THIRD PARTY ADVERTISING & LINKS

We allow Platform users to include third party ads inside such users’ Content. These third party ads
may contain links that could lead to third party websites. We have no responsibility or liability for the
content and activities of these linked sites and we encourage you to read their privacy policies before
buying any product or service from them. Nonetheless, we seek to protect the integrity of our
Platform and welcome any feedback (email us at contact@newbasics.media) about these third party
websites.

WE DO NOT RESPOND TO DO NOT TRACK SIGNALS
Our Platform does not respond to and does not support the Do Not Track (DNT) header request field.
If you turn DNT on in your browser, those preferences will not be communicated to us in the HTTP
request header, and we will continue tracking your browsing behavior.

YOUR RIGHTS UNDER GDPR
The European General Data Protection Regulation (“GDPR”) is a regulation in EU law on data
protection and privacy for all natural persons accessing the Internet from the European Union and the
European Economic Area, whatever their nationality or place of residence is. It also addresses the
transfer of personal data outside the EU and EEA areas. Our collection, processing and protecting of
personal information of those who access the Platform from a European country, is compliant with
GDPR.

If you are accessing and using the Platform from the European Union and the European Economic
Area, you have the following rights with regard to your personal information:

a.    the right to be informed about what kind of information about you is collected, stored, processed
and disclosed by us (that is why we have compiled this Privacy & Cookie Policy for you);
b.    the right of access (you can request us to provide you verbally or in writing with the type of
information we store about you and we have a month to respond to your request);
c.    the right to rectify (amend/correct) any personal information about you that is inaccurate;
d.    the right to erasure (some conditions apply, see Data Retention section below);
e.    the right to restrict processing your personal information, however, if you restrict us from
processing a part of your personal information that is essential to our provision of the Platform
and Services, you may be asked to terminate your Account and stop using the Platform;
f.    the right to data portability (the right to data portability allows users of the Platform to obtain and
reuse their personal information for their own purposes across different services; you may
request us to transmit your personal information directly from our servers to another company’s
servers and we will do so if it is technically feasible);
g.    the right to object (for example, you have an absolute right to stop us from using your personal
information for direct marketing – read our opt-out instructions below; you may express your
objection verbally or in writing and we have a month to respond to any such objection; we might
still continue processing your personal information if we are able to show that we have a
compelling reason for doing so);
h.    the right not to be subject to a decision based solely on automated processing, including profiling,
which produces legal effects concerning you or that affects you significantly.

We represent and warrant that your personal information is:

1.    processed lawfully, fairly and transparently;
2.   collected only for specific legitimate purposes;
3.   collection of personal data is adequate, relevant and limited to what is necessary;
4.   accurate and kept up to date (with your help);
5.   stored only as long as is necessary; and
6.   is secure and kept in confidence.

Data Retention: Generally, your personal information will be erased when (i) it is no longer needed for
its original processing purpose, (ii) you withdraw your consent for us to store by deleting your
Account, (iii) there is no preferential justified reason for the processing of your personal information
and you object to our processing of your personal information, or (iv) erasure of your personal
information is required in order to fulfill a statutory obligation under the EU law or the right of the EU
Member States. Therefore, we will make sure your personal information will be erased under all of
the above-mentioned circumstances. You may request us to erase your personal information verbally
or in writing and we have one (1) month to respond to any such request.

Data Breach Notification: Should there be a personal data breach leading to the accidental or unlawful
destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted,
stored or otherwise processed, we will notify you and appropriate supervisory authority without
undue delay and, where feasible, not later than seventy-two (72) hours after having become aware of
it.

Contact us if you would like to exercise any of the above rights.

YOUR RIGHTS UNDER CCPA

The California Consumer Privacy Act (“CCPA”) is a state-wide data privacy law that regulates how
businesses all over the world are allowed to handle the personal information of California residents.
CCPA provides California residents with five core rights to data privacy and an effective way to
control their personal information.
If you are a California resident, you have the following rights with regard to your personal
information:
1.    the right to know what personal information is being collected about you.
2.    the right to know whether your personal information is sold or disclosed and to whom.
3.    the right to say no to the sale of personal information (“the right to opt out”); we have created
            a. Do Not Sell My Personal Information webpage that provides you with more details on this
matter.
4.    the right to access your personal information (under CCPA, a business may provide personal
information to a consumer at any time, but shall not be required to provide personal
information to a consumer more than twice in a 12-month period);
5.    the right to equal service and price, even if you exercise your privacy rights.

Additionally, a California consumer has the right to request that a business delete any personal
information about the consumer which the business has collected from the consumer. However, a
business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:

1.    complete the transaction for which the personal information was collected, provide a good or
service requested by the consumer, or reasonably anticipated within the context of a
business’s ongoing business relationship with the consumer, or otherwise perform a contract
between the business and the consumer;
2.    detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or
prosecute those responsible for that activity;
3.    debug to identify and repair errors that impair existing intended functionality;
4.    exercise free speech, ensure the right of another consumer to exercise his or her right of free
speech, or exercise another right provided for by law;
5.    comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6
(commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
6.    engage in public or peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when the businesses’
deletion of the information is likely to render impossible or seriously impair the achievement
of such research, if the consumer has provided informed consent;
7.    enable solely internal uses that are reasonably aligned with the expectations of the consumer
based on the consumer’s relationship with the business;
8.    comply with a legal obligation;
9.    otherwise use the consumer’s personal information, internally, in a lawful manner that is
compatible with the context in which the consumer provided the information.

Conflict resolution under CCPA: Prior to initiating any action against a business for statutory damages
on an individual or class-wide basis, a California consumer shall provide a business 30 days’ written
notice identifying the specific provisions of this title the consumer alleges have been or are being
violated. In the event a cure is possible, if within the thirty (30) days the business actually cures the
noticed violation and provides the consumer an express written statement that the violations have
been cured and that no further violations shall occur, no action for individual statutory damages or
class-wide statutory damages may be initiated against the business. Contact us should you need to
exercise any of your rights under CCPA.

YOUR RIGHTS UNDER LGPD

Lei Geral de Proteção de Dados (“LGPD”) is the Brazilian general data protection law, which applies to
businesses that process the personal data of users located in Brazil. LGPD establishes rules on
collecting, handling, storing and sharing of personal data managed by organizations.
According to the article 18 of LGPD, individuals have the following nine rights over their data
processing:
1.    The right to receive a confirmation about processing of their personal data;
2.    The right to access their personal data;
3.    The right to correct incomplete, inaccurate or out-of-date personal data;
4.    The right to anonymize, block or delete unnecessary or excessive data or data processed in
noncompliance with the provisions of LGPD;
5.    The right of portability of the data to another service or product provider, by means of an
express request and subject to commercial and industrial secrecy, pursuant to the regulation of
the controlling agency;
6.    The right to delete their personal data;
7.    The right to know who their data is being shared with (e.g., third parties, sub-processors,
public, and private entities);
8.    The right to know how to deny consent and what would be the consequences of denying
consent to collect personal data; and
9.    The right to revoke consent.

MARKETING EMAILS, OTHER COMMUNICATIONS & OPT-OUT OPTION
With your consent you will receive updates, newsletters, invitations to webinars, surveys, offers, ads
and other promotional materials from us via your email. You may indicate a preference to stop
receiving further communications or notifications from us by following the unsubscribe link provided
in the email you receive. Despite your indicated preferences, we may send you service related
communication, including notices of any updates to Platform’s Terms of Service, Privacy & Cookie
Policy, Security Policy, disclaimers, or other statements.

CONTACT US
The Company has appointed a Data Protection Officer (DPO), who will receive requests and
complaints, and who will communicate with Platform users and local authorities concerning any
privacy questions, requests, or issues. To contact us or exercise an of your privacy rights, contact our
DPO, whose contact information you will find below:

NEW BASICS MEDIA LLC
Attention: Data Protection Officer
Email: alex@newbasics.media
Mailing Address: 300 SW 1st Ave #155, Fort Lauderdale, FL 33301, US
Phone: +1 (754) 200-9198