Privacy Policy

Privacy Notice
Notice last update: 27/01/2025

(MI Spekter). ( “us” or “we”) respects your privacy and is committed to protecting it through
our compliance with this Privacy Notice (“Privacy Notice”). This Notice describes how and why
we might access, collect, store, use, and/or share (“Process”) your Personal Information when
you use our services, access our website, or purchase our products (“Services”), and how you
may exercise your rights. In this Notice, “Personal Information” means any information by
which you can be identified or contacted, such as your name (first and last), home, billing or
other physical address, email address, telephone number, billing information, etc., as well as
any information associated with the foregoing.

By using this Website and providing Personal Information, you acknowledge that the Personal
Information may be processed pursuant to the terms of this Notice. If you do not agree with
the practices described in this Notice, please do not provide us with Personal Information or
use the Website. If you still have any questions or concerns, please contact us at info@mispekter.com.

TABLE OF CONTENTS

  1. WHAT PERSONAL INFORMATION DO WE COLLECT?
  2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
  3. HOW DO WE USE YOUR PERSONAL INFORMATION?
  4. HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?
  5. COOKIES AND OTHER TECHNOLOGIES
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
  7. TARGETED ONLINE ADVERTISING AND SOCIAL MEDIA
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. THIRD PARTIES AND LINKS TO OTHER WEBSITES
  13. INTERNATIONAL TRANSFERS OF PERSONAL DATA
  14. DO WE MAKE UPDATES TO THIS NOTICE?
  15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you express an
interest in obtaining information about us or our products and Services, when you participate
in activities on the Services, or otherwise when you contact us. Personal Information Provided
by You.
The Personal Information that we collect depends on the context of your interactions with us
and the Services, the choices you make, and the products and features you use. We collect the
following types of Personal Information:

  • Contact information (identifiers), including name, personal contact information,
    emergency contact information, date of birth;
  • Demographic information such as age, gender, country, interests, and preferences;
  • Employment information completed as part of any application for a position with us;
  • Organizational data, including work contact details (e.g., address, email, phone
    number), position/title, job function, professional license number(s), employee ID,
    work eligibility information;
  • Registration information, such as username and password;
  • Transaction data, such as purchases and inquiries;
  • Device information, such as operating system type and version number, manufacturer
    and model, cookie information, device identifier, device event information, unique
    identifiers, browser type, screen resolution, IP address, websites visited before
    browsing to our Website, general location information such as city, state or geographic
    area; and information about their use of and actions on or in our websites or mobile
    applications, such as pages or screens accessed, how long spent on a page or screen,
    navigation paths between pages or screens, information about their activity on a page
    or screen, access times, and length of access;
  • Marketing information, including inferences about you, such as user preferences for
    receiving marketing communications and details about how users engage with our
    marketing communications;
  • Clickstream data or other information about your online activities (e.g., browsing
    actions, usage patterns), including across our websites and third-party websites, which
    we obtain through the use of cookies, web beacons, and other similar technologies
    (see our Cookie Preference tool for more information)
  • Information collected via automated means; and
  • Other information that Website users voluntarily provide to us through “Contact Us”
    features or similar communication channels.

MI Spekter, our service providers (including distributors, sales agents and recruitment
agencies), and other third parties (including third-party websites) may collect this type of
information about you over time, in which case such Personal Information shall be processed in
accordance with this policy. This information is collected via various mechanisms, such as via
cookies, pixels, tags, web beacons, embedded scripts, through our mobile applications, and
similar technologies. We use Google Analytics. To learn more about Google Analytics’
advertising features, including how to opt-out of Google Analytics, click here. For more
information about Google Analytics, please refer to “How Google Uses Information From
Websites or Apps that Use Our Services,” which can be found here, or any other URL Google
may provide from time to time. This type of information may also be collected when reading
our emails, please refer to “Marketing Communications” below for more information. Please
refer to “Cookies and other Technologies” below to learn more about disabling cookies or how
to opt out of the use of browsing behavior for purposes of targeted advertising.

2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Website users directly provide us with most of the data we collect. We may collect some
information indirectly from you based on your interactions with our Website, subject to certain
restrictions and regulations depending on your jurisdiction and applicable laws.
We also collect Personal Information when you make orders or inquiries with us, whether
through our website or other sales channels and through other third party service providers
and suppliers (see above). Examples of the sources where we collect Personal Information from
include:

  • When a Website user provides it directly to us;
  • When a visitor comes to our Website, automatically with pixels, cookies, and other similar technologies (as further described below);
  • From joint marketing partners;
  • From third-party sources, such as third parties, data brokers, social media, or other sources (including recruitment agencies); and
  • When a user downloads and interacts with one of our mobile applications.

We may collect Personal Information when a Website user:

  • Browses and/or searches our Website(s);
  • Registers, subscribes, or creates an account with us;
  • Purchases products from MI Spekter through our Website(s);
  • Opens, clicks on, or responds to our e-mail or online offers;
  • Voluntarily provides us with information through web forms or surveys which we may then link to Personal Information that were previously provided;
  • Contacts customer service to speak with a representative or make use of our customer support tools;
  • Signs-up for our e-mail updates and newsletters;
  • Connects, links or “shares” our Website(s) via social networking websites;
  • Provides ratings or reviews of our products and services; or
  • Applies for a job at info@mi-spekter.com

3. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use Personal Information to fulfill contractual relationships with customers and vendors to
be able to deliver goods and services and to fulfill the following legitimate business purposes:

  • Establishing an online MI Spekter account at user request;
  • Processing online purchase orders, tracking and keeping users informed about the status of their order;
  • Determining whether an individual is a suitable candidate for any open jobs at MI Spekter;
  • Providing customer service (for example, answering questions or responding to a request);
  • Sending reminders, updates, support, administrative messages, service bulletins, and requested information;
  • Provide marketing and promotional communications and deliver targeted and relevant advertising and relevant offers, which includes making better predictions about content and marketing offers that may interest users; and
  • Communicating and providing additional information that may be of interest to Website users about MI Spekter products and services at their request.

We use the Personal Information we collect when we have legitimate business reasons to do
so, pursued by a third party or us, so long as it is compatible with Website users’ rights and
expectations of privacy. Our lawful basis for processing your Personal Information is in
furtherance of such legitimate interests

This includes to:

  • Operate, maintain, and improve our Website(s), our services, and our products;
  • Perform analytics and conduct customer research;
  • Perform due diligence screenings;
  • Perform recruitment activities;
  • Allow users to participate in interactive features of our Website(s) when they choose to do so;
  • Administer online surveys or special offers from us;
  • Improve our Website(s), customer service, products and services and overall user experience;
  • Enhance other information we have about Website users to help us better understand them and determine their interests; and
  • Identify Website user preferences so we can notify them of new or additional products, services, and promotions that might be of interest.

As with many other websites, as Website users navigate through and interact with our Website,
we may use automatic collection technologies to collect certain information about equipment,
and browsing actions and patterns, including:

  • Details of a user’s visit to our Website, including the resources that a Website user’s access and use on our Website, traffic data, location data, logs, language;
  • Date and time of access, frequency, last date of their visit to our Website, and other communication data;
  • Information about a device and internet connection, including, but not limited to, operating system, host domain, and browser type (for example Internet Explorer);
  • Details of referring websites (URLs); and
  • We may, on occasion, record their session on our Website for qualitative analysis of user experience design.
  • For your rights as a MI Spekter job applicant please contact info@mi-spekter.com

If a Website user does not want Personal Information used, for example, to send newsletters or
directly market MI Spekter products or services, they have the right to modify their preferences
at any time. A Website user can click “unsubscribe” at the bottom of every email to be
removed from that mailing list, modify their cookie preferences and at the footer of this
Website or submit a consumer request by emailing us at info@mi-spekter.com
We will only send you such materials where you have provided your explicit consent, or where
we are permitted to do so under the applicable rules governing online marketing and sales
(including where a “soft opt-in” option is available).
Our Website has collected the following Personal Information from users of the Website within
the last twelve (12) months:

Personal information category Core purposes of processing Third-party types involved Processing role and transfer characterization Opt-out applies?
Identifiers (e.g., name, email, device IDs, IP address) Account administration;customer support; Website functionality: fraud prevention and security; analytics and Website performancе; targeted advertising and remarketing (only where permitted); to enable use of our sites, services, and products, to communicate
with you, and to
understand how our users
interact with our sites; to
improve our offerings
  • Service providers (hosting, CRM, customer support)
  • Security/fraud partners
  • Analytics providers
  • Measurement partners
  • Ad networks/demand partners
  • Social media platforms (when pixels are enabled)
  • We share this data for targeted or context behavioural advertising. We do not sell this data for monetary considerations.
  • Service providers/processors/service provider contracts; no secondary use
  • Analytics/measurement configured as service provider/processor where feasible; otherwise limited to aggregate reporting
  • Ad networks/social platforms for cross-context behavioral advertising; sale/share under applicable law unless user opts out
  • Yes, for advertising/remarketing uses (sale/share) via “Do Not Sell or Share” and GPC
  • No for strictly necessary, security, and core service-provider uses
Device and network activity
data (e.g., cookie IDs, user
agent, screen resolution,
browsing/session data)
Website operation;
performance monitoring;
debugging; fraud
prevention; audience
measurement; A/B
testing; targeted
advertising/remarketing
(only where permitted)
  • Tag management and consent platform
  • Analytics providers
  • Performance monitoring/telemetry providers
  • Ad networks/demand partners
  • Social media platforms
  • Tag management/CMP-processor/service provider
  • Analytics/performance processor/service provider where feasible; otherwise limited to aggregated metrics
  • Ad networks/social platforms for cross-context behavioral advertising under sale/share under applicable law unless user opts out
  • Yes, for advertising/remarketing uses (sale/share) via “Do Not Sell or Share” and GPC
  • No for strictly necessary, performance-as-a-service-provider (non-advertising) uses
Clickstream and interaction
data (e.g., pages viewed,
navigation paths, events,
session replay where
enabled)
Usage analytics; product
improvement; content
personalization onWebsite; conversion
measurement; targeted
advertising/remarketing
(only where permitted)
  • Analytics providers
  • Session analytics/replay providers
  • Measurement partners
  • Ad networks/demand partners
  • Analytics/session analytics: processor/service provider where feasible and configured to avoid collection of sensitive fields; no secondary uses
  • Measurement partners: processor/service provider or limited controller-to-controller measurement depending on tool
  • Ad networks for cross-context behavioral advertising: sale/share unless user opts out
  • Yes, for advertising/remarketing uses (sale/share) via “Do Not Sell or Share” and GPC
  • No for on-website personalization analytics when performed by service providers with contractual restrictions
Organizational/professional data (e.g., work email, title, specialty) Lead handling: B2B sales and marketing; account eligibility validation; customer communications; event/webinar administration
  • CRM and marketing automation service providers
  • Email/SMS delivery vendors
  • Event management platforms
All disclosed as processor/service provider with contractual restrictions; no sale/share Generally no; processing is service-provider based. Users may opt out of marketing communications via unsubscribe and manage cookies for advertising tags separately.
Inferences and marketing preferences Tailoring on-Website content; frequency capping; marketing list management; analytics
  • Marketing automation platforms
  • Analytics providers
  • Preference center/CMP
Processor/service provider with contractual restrictions; no sale/share for inferences derived from sensitive categories Opt-out of marketing communications via unsubscribe; cookie-level choices govern any advertising tags

We collect and disclose personal information as described in the matrix above and also as set
out in this privacy notice. Where we engage service providers or processors, we contractually
restrict their use of personal information to our documented instructions and prohibit
secondary use and disclosure. Where our use of advertising technologies may constitute a
“sale” or “share” of personal information under applicable law, we honor your right to opt out.
You may exercise your “Do Not Sell or Share My Personal Information” choice at any time via
our consent management platform, and we also process Global Privacy Control (GPC) signals in
a frictionless manner. When you opt out or when a GPC signal is detected, we prevent the
firing of advertising/remarketing tags and the disclosure of data to ad networks and social
media platforms for cross-context behavioral advertising. Strictly necessary and securityrelated processing may continue to ensure the Website functions properly.

MI Spekter only retains personal information for as long as necessary to carry out the purposes
for which we originally collected it and for other legitimate business purposes, including to
meet our legal, regulatory, or other compliance obligations.

4. HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?

Access to Personal Information is restricted to individuals that are required to have access to
Personal Information for the purposes described above.

We may also share or disclose Personal Information with the following categories of persons in
different ways and for different reasons, as appropriate and in accordance with local laws and
regulations:

  • Within MI Spekter, to other affiliates and subsidiaries in our normal business operations and as needed to address our structure.
  • Service Providers, Contractors, or Third Parties. To Service Providers, Contractors, or Third Parties, including in connection with technology and security support, and other standard business operations. They will also not share your Personal Information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
  • Social Media Networks. Some of our websites have features such as plugins, widgets, and other tools made available by third parties that may result in information being collected or shared between us and the third party. You may have the right to opt out of our use of these technologies, as further described in this Notice.
  • Advertising Service Providers and Third Parties. To analytics providers and advertising service providers and third parties. For example, if you have accepted Targeted Advertising cookies using our Cookie Preference tool, then we may track your Website usage (such as the pages you view and actions you have taken on our Website) and show you relevant MI SPEKTER ads on your social media or on other off-platform Websites.
  • Government Entities, Regulators, or Legal Processes. To governmental agencies and regulators (e.g., tax authorities, social security administration), external advisors (e.g., lawyers, accountants, and auditors), courts and other tribunals, and government authorities, to the extent required or permitted by applicable law. In response to a subpoena, court order, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate.
  • Other Disclosures with Website user Consent. We may ask if a Website user would like us to disclose Personal Information with other unaffiliated third parties who are not described elsewhere in this Notice.
  • Business Transactions. In the event of mergers, reorganizations, or similar corporate restructuring activities, we may disclose information with that company. In some instances, this may include Personal Information.
  • Legal Purposes. To combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and third parties, or as part of legal proceedings affecting MI Spekter.

5. COOKIES AND OTHER TECHNOLOGIES

We use cookies, tags, pixels, web beacons, and other tracking technologies to recognize when a
Website user visits our Websites or interacts with our e-mails to gather information when you
interact with our Services and use our Website. Some online tracking technologies help us
maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and
assist with basic Website functions. We also permit third parties and service providers to use
online tracking technologies on our Services for analytics and advertising, including to help
manage and display advertisements, to tailor advertisements to your interests, or to send
abandoned shopping cart reminders (depending on your communication preferences). The
third parties and service providers use their technology to provide advertising about products
and services tailored to your interests which may appear either on our Services or on other
websites.

Cookies and other technologies are small pieces of data that a Website places on a device or
computer when an individual visits a Website. Cookies and other technologies may involve the
transfer of information from us to a Website user and from a Website user directly to us, to
another party on our behalf, or to another party in accordance with its privacy policy. We may
use cookies to bring together information we collect about a Website user. A Website user can
choose to have their device warn each time a cookie is being sent or can choose to turn off all
cookies through their browser settings. If a Website user turns certain cookies off, the user will
not have access to features that make the Website experience more efficient and some of our
services will not function properly. To the extent these online tracking technologies are
deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the
applicable laws) under applicable U.S. state laws, you can opt out of these online tracking
technologies by submitting a request as described below under section What Are Your Privacy
Rights. To opt out of being tracked by Google Analytics across the Services,
visit https://tools.google.com/dlpage/gaoptout . You can opt out of Google Analytics
Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out
means
include http://optout.networkadvertising.org/ and
http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the
Google Privacy & Terms page.
We use several categories of cookies, and each performs different functions. Website users can
learn more about what cookies we use and what each does by reviewing “Cookie Preferences”
on the footer of our Websites. Website users can learn more about cookies generally and their
functions by visiting an information Website such as allaboutcookies.org.

Categories of Cookies

  • Strictly Necessary Cookies – These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by which amount to a request for services, such as setting privacy preferences, logging in or filling in forms.
  • Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. If these cookies are not allowed, we will not know when a user has visited our Website and will not be able to monitor Website performance.
  • Functionality Cookies – These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If these cookies are not allowed, then some services may not function properly.
  • Targeting or Advertising Cookies – These cookies may be sent through our Website by our advertising service providers or third parties. They may be used by those companies to build an interests profile and show you relevant advertising on other Websites. If these cookies are blocked, a Website user will experience less targeted advertising.
    • Third-party targeted advertising cookies may be placed on a device by third-party advertisers, ad networks, data exchanges, marketing analytics, and other service providers.
    • For example, these cookies may be used to measure the effectiveness of an ad campaign by collecting data on how many people click the ad.

Users can delete any cookies that have been installed in their browser cookie folder. Each
browser follows different procedures to manage settings. Click on any of the browser links
below for instructions on deleting cookies:

6. HOW LONG DO 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 Notice, unless a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements).When we have no ongoing legitimate business need
to process your Personal Information, we will either delete or anonymize such information, 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.

7. TARGETED ONLINE ADVERTISING AND SOCIAL MEDIA

Service providers and third parties that collect information about users’ activities on our
Websites or in our mobile applications may be members of organizations or programs that
provide choices to individuals regarding the use of their browsing behavior or mobile
application usage for purposes of targeted advertising.
In addition to your opt out rights in this Notice, Users may opt out of receiving targeted
advertising on websites through participating members of the following organizations or
programs:

Users of mobile applications may opt out of receiving targeted advertising in mobile
applications through participating members of the Digital Advertising Alliance by installing the
AppChoices mobile application, available here, and selecting the user’s choices. In addition,
mobile device settings may provide functionality to limit our, or our advertising service
providers’ and third parties,’ ability to engage in ad tracking or targeted advertising using the
Google Advertising ID or Apple ID for Advertising associated with mobile devices.

Please note that we also may work with companies that offer their own opt-out mechanisms
and may not participate in the opt-out mechanisms that we linked in this Notice.

Opting out of targeted advertisements does not eliminate advertisements. The advertisements
will still appear but may no longer be relevant to the viewer. Even if a Website user opts out of
targeted advertising not all companies that serve online behavioral advertising are included in
this list, and so you may still receive some cookies and tailored advertisements from companies
that are not listed.

MI Spekter uses Google signals to associate data collected during visits to our Website with
Google information from users who are signed into their Google accounts and have consented
to ads personalization. Google signals help identify and de-duplicate users across multiple
devices and helps us produce relevant remarketing advertising.

Users can opt out of Google ads personalization by logging into their Google account and
navigating to https://myactivity.google.com/myactivity. Users may also opt out of targeted MI
Spekter advertising specifically by disallowing Targeting and Performance Cookies using the
“Cookie Preferences” link in the footer of our Websites.

Marketing Communications

Marketing communications such as emails and newsletters can be stopped at any time by
clicking “Unsubscribe” at the bottom of all MI Spekter communications. Even after opting out
to the above, individuals may continue to receive transactional, service-related, other nonmarketing communications, and general, non-personalized MI Spekter advertisements.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your Personal Information through a system of organizational and technical
security measures. We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the security of any Personal Information
we process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to protect your
Personal Information, transmission of Personal Information to and from our Services is at your
own risk. You should only access the Services within a secure environment. In the event that
we are required by law to inform you of a breach of your Personal Information we may notify
you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our Websites may permit you to create an account. When you do you will be
prompted to create a password. You are responsible for maintaining the confidentiality of your
password, and you are responsible for any access to or use of your account by someone else
that has obtained your password, whether or not such access or use has been authorized by
you. You should notify us of any unauthorized use of your password or account by using one of
the methods listed below under “Contact Us.”

9. DO WE COLLECT INFORMATION FROM MINORS?

The Website is not intended for children under 18 years of age. We do not knowingly collect,
solicit data from, or market to children under 18 years of age, nor do we knowingly sell such
Personal Information. If you are under 18, do not use or provide any information on the
Website or on or through any of its features, or provide any information about yourself to us,
including your name, address, telephone number, or email address. If we learn we have
collected or received personal information from a child under 18 without verification of
parental consent, we will delete that information. If you believe that we might have any
information from or about a child under 18, please contact us at MI Spekter). By using the
Services, you represent that you are at least 18 or that you are the parent or guardian of such a
minor and consent to such minor dependent’s use of the Services.

10. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on where the individual lives and the types of Personal Information at issue, the
individual may have certain rights with respect to their Personal Information. For example,
under local applicable laws, including certain states in the United States the individual may
have the rights listed below. Please note that many of these rights are subject to exceptions
and limitations.

  • Right to Know and Access: You may request to access the following information we have collected and maintained about you in a portable form:

    • The specific pieces of Personal Information we collected about you;
    • The categories of Personal Information we collected about you and the categories of sources;
    • The business or commercial purpose for collecting, disclosing, or selling Personal Information about you; and,
    • The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties (or, depending on your state of residence, a list of specific entities) to whom we sold, shared, or otherwise disclosed that Personal Information.

    Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

  • Right to a Copy: You have the right to obtain a copy of your Personal Information that you have previously provided to us in a portable and readily usable (if technically feasible) format.
  • Right to Delete: You may request that we delete the Personal Information we have collected from you.
  • Opt Out of “Sale,” “Shares,” and Targeted Advertising: Depending on the state you reside in, website users have the right to opt out of the “sale” of your data and the disclosure of your data for cross-context behavioral advertising/targeted advertising (known as a “share” in California). We also honor alternative opt out signals, such as the GPC. We process opt out preference signals in a frictionless manner. Please note that we do not sell Personal Information for Monetary consideration.
  • Right to Correction: You have a right to request the correction of inaccurate Personal Information that we may have on file about you.
  • Right to Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under Applicable Laws.
  • Right to Question the Results of Profiling: You have the right to review your personal information used for profiling, to question the results, to be informed of the reasons of the resulting decision, and to be informed of what actions you can take to secure a different decision. If a decision was based on inaccurate personal information, you have the right to have personal information corrected and the profiling decision reevaluated.
  • Right to Appeal: Depending on your state of residence, you may have the right to request an appeal of a denied consumer request. Please see below for how to submit an appeal.
  • Right to Complain: You may make a complaint to a data protection authority within your place of residence (for UK residents, this is the Information Commissioner. For residents elsewhere in Europe, you can find the relevant authority by using the following website: https://dataprivacymanager.net/list-of-eu-data-protectionsupervisory-authorities-gdpr/), your place of work or the place of the alleged infringement.

In addition, you can also request the restriction of the processing of your Personal Data subject
to the conditions and limitations set out in UK and EU GDPR and can withdraw your consent for
processing (where this is relied on by us as the lawful basis for such processing) at any time.

Your rights and our responses will vary based on the circumstances of the request. If you
choose to assert any of these rights under applicable law, we will respond within the time
period prescribed by such law. In some cases, we may limit or deny your requests to access or
delete your information. This may occur because the law permits or requires us to do so, or if
we are unable to adequately verify your identity.

Please note that we must be able to verify your identity to make sure you are the person about
whom we have collected Personal Information or an authorized representative. Depending on
the type of request, we may conduct the verification process by email or phone using
information that matches our records. The information you must provide as part of the
verification process may include: name, contact information (such as email address or phone
number), relationship with us, and residency. We may also ask for additional information as
needed based on your relationship with us.

You may also designate an authorized agent to submit a request on your behalf to access or
delete your Personal Information. To do so, you must (1) provide that authorized agent written
and signed permission to submit such request, and (2) verify your own identity directly with us.
Please note, we may deny a request from an authorized agent that does not submit proof that
they have been authorized to submit such a request.

California “Shine the Light” Privacy Rights

California’s “Shine The Light” law permits those MI Spekter customers who are residents of
California to annually request a list of their personal information (if any) that MI Spekter
disclosed to third parties for direct marketing purposes in the preceding calendar year, and the
names and addresses of those third parties.
To submit a request to exercise any such rights (if they apply to you), please send us an email at
MI Spekter.

11. CONTROLS FOR DO-NOT-TRACK FEATURES AND GLOBAL PRIVACY CONTROLS

Most web browsers and some mobile operating systems and mobile applications include a DoNot-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in
a revised version of this Notice. Privacy laws require us to let you know how we respond to
web browser DNT signals. Because there currently is not an industry or legal standard for
recognizing or honoring DNT signals, we do not respond to them at this time.

The GPC is an opt-out preference signal (OOPS) that allows users to automatically indicate to
the websites they visit that they would like to opt-out of the “sale” and “sharing” of their
personal information. The GPC signal is an easy way to opt-out because a consumer does not
have to make individualized requests to opt-out on each website they visit. GPC can be
downloaded via a browser extension; some browsers offer a GPC setting. Installing GPC is
simple and helps ensure your personal information is protected. Click here for a video to show
you how to install GPC

12. THIRD PARTIES AND LINKS TO OTHER WEBSITES

Our websites and services may contain links to websites, content, or services owned or
operated by third parties. Please note, we have no control over the privacy practices of
websites or services that we do not own. We encourage you to review the privacy policies of
any third-party website or application for details about what information is collected and how
it is used and/or disclosed.

13. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

MI Spekter has committed itself to comply with this Notice and the applicable data protection
laws and regulations regarding Personal Information collected and stored. We process your
Personal Information in the locations where our business operates, including the UK, Spain, the
United States of America, and elsewhere in the European Economic Community.
For more information on our safeguards, please contact us at “Contact Us” information above.
We will take all steps reasonably necessary to ensure that the data we collect is treated
securely and subject to appropriate safeguards in accordance with this Notice and applicable
legislation.

14. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may
update this Notice from time to time. The updated version will be indicated by an updated
“Revised” date at the top of this Notice. If we make material changes to this Notice, we may
notify you either by prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this Notice frequently to be informed of how we are
protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions about this Notice, the practices of the Website, your dealings with
the Website, or wish to update us with your p references, you may contact us using one of the
following methods: