Privacy Policy | Reea Digital Limited

1. Privacy Policy Scope

The current Privacy Policy serves the purpose of explaining in an utmost simple and transparent manner the way in which the personal data is gathered and managed by means of accessing the https://www.reeadigital.com/ domain.

We hereby mention that this Privacy Policy has a limited nature and is only applicable to your interaction with REEA Digital Limited by means of the pages that are presented within the https://www.reeadigital.com/ domain. We hereby provide a cautionary notice that it does not represent the totality of the conditions and of every personal data-related management that is carried out, as well as that this document constitutes an integral part of at the very least the Documentation including Our Terms of Access, Use and/ or Interaction Business Strategy and Policy, Our Privacy Strategy and Policy and/ or Our Cookie(s) Information Interaction Strategy and Policy. Its nature is that of Additional applicable internal documentation and as such is applicable within the order of precedence that is enforced within the previously-mentioned Documentation.

Our Terms of Access, Use and/ or Interaction Business Strategy and Policy, Our integral Privacy Strategy and Policy , as well as Our Cookie(s) Information Interaction Strategy and Policy, which contain the general use terms that are applicable at the REEA Digital Limited general level.

The current Privacy Policy applies to:

All of the visitors who access existing web pages within the https://www.reeadigital.com/ domain, regardless of their legal status and regardless of the manner in which they end up navigating within this domain.

The personal data category refers to any type of information regarding an identified or an identifiable individual person.

A few common examples are the full of partial name, the Email address, the phone number, the date of birth or the IP address from which the person engages with our platform. In a wider spectre, we can include information regarding the device used to engage with our platform, the operating system version, the browser version, or information which derives from the location or which has a public nature within the category of personal data.The management refers to the entirety of the operations which we may carry out upon the data, such as for example the:

Gathering

Storing

Organising

Transfer

Erasure

The personal data is gathered and managed to precise and limited ends whenever you visit the https://www.reeadigital.com/ Internet website, completely voluntarily and in the absence of any constraint whatsoever decide to contact REEA Digital Limited by using the contact means placed at your disposal to this end, or you decide to use certain available services or applications which specifically require the use of certain personal data. In certain situations, we gather and use personal data that is available within the public space and which are legally made available, such as those published by various State institutions.

2. The types of collected data

The personal data which we gather directly or by means of certain third party services include:

The IP address, when you access Internet pages

The name of the accessed page

Identification data like for example: last name, first name, Email address, phone number, when you decide to contact REEA Digital Limited and these are offered voluntarily by means of consent or which we consider objectively-necessary or at the very least useful in our proprietary business interest in order to be able to contact you regarding the purpose for which you express your consent and/ or interest.

Statistical data, in anonymous form, which even though individually (or in an isolated manner) cannot lead to direct identification, by means of their correlation with other sets of data, exceptionally have the potential to be used for identifying a person.

This data may include for example:some text

The location established on the basis of the IP address, or following your consent, provided by means of the device used for accessing our platform.

The Browser used for navigation, its version and functions

Other information which is accessible by means of the utilized Browser or application, like for instance the version of the operating system or the resolution used by your device.

The names of the accessed pages and/ or of the downloaded files

The source of the preceding page

REEA Digital Limited does not carry out processing that would lead to the identification of persons on the basis of the statistical data, this data being gathered by means of third party services and places at our disposal in an anonymous format. Most times, the gathering of this information may be blocked by configuring the utilized device appropriately, or by means of refusing our access to this data whenever your consent is required to this end.

3. Sensitive Data and/ or regarding minors

REEA Digital Limited does not collect and does not process Sensitive Data, or which relates to minors by means of the pages that are available within the Internet address https://www.reeadigital.com/. We hereby specifically notify you not to send any type of personal data, other than those enumerated within section 2 of this document either voluntarily or accidentally by means of the forms placed at your disposal.We also specifically hereby notify you of the duty to not provide any type of personal information within the pages which offer you the possibility to input or post comments.

4. The purposes for which we utilize the personal data

The IP address - is gathered for the purpose of ensuring the security requirements, in accordance with the legal requirements that are currently in force as well as for the purpose of adhering to the internal norms and regulations regarding the information security.

Identification data - is being gathered and processed in exclusive compatibility with the purposes for which you express your interest or with those that we have established in our own legitimate proprietary business interest, such as, for example, within the process of answering offer-issuing requests, or that of establishing a pre-contractual business relationship. To this end, they will be transferred within the REEA Digital Limited organisation to one or more departments or internal structures (including but without limitation employees, contractual personnel or personnel under legal control). As the case may be and taking into account your specific consent or our legitimate proprietary business interest, we will also use it within the ambit of marketing or information dissemination campaigns as far as the content alterations, those of the terms of use or that of this Privacy Policy are concerned. We hereby specifically notify you regarding the fact that there are instances in which REEA Digital Limited is held to notify you, on the basis of legislative provisions or of our proprietary legitimate interest, even in the absence of a specific agreement stemming from your part, whenever there are grounds which indicate the fact that you might be adversely-impacted, that our business relationship could be impacted including but without limitation in respect of the pre-contractual stage in which we might find ourselves, or that the notification is justified on the basis of our proprietary business interest. Subsequently, we hereby enumerate a series of a few examples of such instances: fraud prevention, the loss or unauthorized disclosure of certain information, the unavailability of certain services, the need to update the personal date, obtaining a consent in respect to a newly-relevant type of processing etc.

Statistical Data - is used anonymously in order to:some text

Create reports for the purposes of improving the browsing experience, the manner in which we present the information, or in order to ensure the appropriate functionalities in line with the technological evolution (including but without limitation the field of information security).

Monitor the trends and/ or identify certain potential security breaches;

5. Personal Data Transfer

For the purpose of improving the services, the communication and/ or the experience of our visitors, the data will be transferred as the case may be, within the scope of the purpose for which it has been obtained, towards:

REEA Digital Limited Internal Departments (including employees, contractual staff or personnel under legal control), which have specific duties to monitor and solve your requests;

Governmental Authorities, such as the fiscal, judicial, police, regulatory or arbitrage ones in the situations imposed by means of the law;

The lawful tutelage representatives, the legal representatives in the events in which the data subject is considered to be a minor in accordance with the applicable legislation;

Data Processors in accordance with the legislation that is in force.

The internal communication is carried out in all situations in accordance with the internal information security management system, which is ISO 27001 certified, as well as with adherence to the 2016/679 EU Regulation (the General Data Protection Regulation, “GDPR”).The statistical data is collected by means of specialized services, or indirectly provided by means of certain functionalities which serve the purpose of improving your experience and which can be in turn offered by means of certain third party services.Within the pages of the https://www.reeadigital.com/ address we use the following services:

Google Analytics, owned at the date of the last accessing by Google LLC - we hereby invite you to decide upon whether to consult the terms of using this service at the up to date Internet address, currently https://policies.google.com/terms (date of the last accessing November 13th 2018)

Facebook Pixel, owned at the date of the last accessing by Facebook Inc. - we hereby invite you to decide upon whether to consult the terms of using this service at the up to date Internet address, currently https://www.facebook.com/about/privacy (date of the last accessing November 13th 2018)

LinkedIn (including widgets, buttons, share buttons functionalities), owned at the date of the last accessing by the LinkedIn Corporation - we hereby invite you to decide upon whether to consult the terms of using this service at the up to date Internet address, currently https://www.linkedin.com/legal/user-agreement (date of the last accessing November 13th 2018)

Twitter (including widgets, buttons, share buttons functionalities), owned at the date of the last accessing by Twitter Inc. - we hereby invite you to decide upon whether to consult the terms of using this service at the up to date Internet address, currently https://twitter.com/en/tos (date of the last accessing November 13th 2018)

6. The rights and the manner in which we uphold them

REEA Digital Limited carries out every reasonable effort in order to uphold and secure the rights of the users of the https://www.reeadigital.com/ domain. The rights over the personal data are:

The right of acces to the personal data - In a reasonable and free manner, you enjoy the right to request a report regarding the personal data which we manage, in accordance with the provisions of the GDPR.

The right to rectification - In the instances in which you notice disparities, or in which you become aware of the alteration of certain personal data which is managed by REEA Digital Limited, which are no longer accurate, you enjoy the right to request their rectification, in accordance with the provisions of the GDPR. In our own proprietary business interest, we hereby notify you regarding your duty to exercise this right as often as the circumstance becomes applicable, in accordance with the provisions of the GDPR.

The right to object to the personal data management - You enjoy the right to request the cessation of certain types of procedures being carried out by REEA Digital Limited regarding the personal data, in accordance with the provisions of the GDPR. This right may be exercised whenever a certain type of operation is considered to be groundless. We will take the request into consideration and we will clearly notify you regarding the manner of proceeding, the legal basis and the decision to solve your request.This right may not be exercised, or the request will be denied, if the management of the personal data derives from a requirement provided for by the legislative framework which is in force, if it is in accordance with the provisions of an ongoing contract, if it adversely affects a third party (except for the case in which by means of the favourable solving of your objection we may continue to protect that third party appropriately), or if it may influence the investigations of certain State authorities. Moreover, you may not oppose the management which constitutes a part of, affects, or may affect the REEA Digital Limited security systems.We nevertheless assure you of the fact that we will process you requests at any possible time, in strict compliance with the provisions of the applicable regulatory framework, and especially with those of the GDPR.

The right related to profiling and automated decision-making - Grants you the possibility to oppose the decision-making being carried out by automated management systems, without the intervention of a real person. REEA Digital Limited does not apply such management procedures to the personal data that is gathered by means of the webpages within the https://www.reeadigital.com/ domain.

The right to restrict data processing - Grants you the possibility to request the restriction of the management of the personal data in the following circumstances:some text

You are aware that we manage personal data which no longer complies with reality, or there is inaccurate information present.

There are sufficient reasonable grounds in order to consider that the carried out management is illegal.

You wish to specifically store the data, by means of issuing an agreement to this end in writing, but you do not wish that this data would be included, partially or completely, within certain management-type procedures.

A request is issued by means of which you claim your “Right to restrict data processing” in respect to the personal data which is managed by REEA Digital Limited within the ambit of our proprietary legitimate business interest.

The right to data portability - Grants you the possibility to request the transfer of the personal data, by means of automation, whenever this is possible from a technical standpoint, on the basis of a contract or of a specific consent, issued in writing.

The right to “be forgotten” (to erasure) - Represents the right to request the erasure of the personal data within the following circumstances:some text

The data is no longer necessary for the management, it does no longer serve the purpose for which it has been gathered, or it becomes inaccurate.

The legal basis for the management disappears by means of legislative modifications, or by means of the retraction of a previously-issued consent.

The right to lodge a complaint - Ensures your option to register a complaint in the instances in which you are unsatisfied with the manner in which we respond, or due to the quality of our responses, respectively that of the solutions which we offer in response to the requests which you have made in respect to the gathering or management of the personal data.

The right to compensation and legal counsel - Represents your right to request compensation and legal counsel in the circumstances in which proven damages are due as a consequence of personal data management-type procedures being carried out by REEA Digital Limited in its Data Controller capacity.

We hereby mention that in every situation we are bound by the legal duty to appropriately verify the identity of the data subject and as a consequence of this fact this could imply the request of additional specific personal data.

The management of the advertising materials

We hereby reserve the right to unilaterally decide, at any given time, the cessation of a negotiation or the cessation of providing services or the refusal to manage information or personal data (including advertising materials), without this decision being construed in such a manner as to impact the outstanding duties between REEA Digital Limited and yourself in the capacity of our Client. Upon the cessation of the contractual relationship, the delivery and receipt of the entirety of the information will be acknowledged by means of a record which will exonerate REEA Digital Limited from any future liability and will transfer the entirety of the risks associated with any liability upon yourself for the following period starting from the moment of the cessation of the contractual relationship with the REEA Digital Limited commercial entity.

You hereby acknowledge your exclusive liability and ensure us regarding the fact that any advertising content is acknowledged by you insofar as its origin and belonging is concerned previous to any publication of such. You are directly acknowledging the responsibility of upholding of the REEA Digital Limited Documentation, as well as the upholding of the documentation of the companies which offer you the platforms within which the marketing campaigns and contests are carried out, which you select prior to entry within the REEA Digital Limited contractual relationship or in any case at the same time of the moment of such entry in the limited circumstance in which you also request assistance services related to the registrations within these platforms.

REEA Digital Limited will not, under any circumstance, become liable for any information which is managed in the sole interest of our clients. The entirety of the information will be initially approved by you in your capacity of Client and Data Controller, and periodically as well, so that prior to any action undertaken by REEA Digital Limited these will be decided upon, initiated and organized by yourself while bearing the entire legal liability over the content. REEA Digital Limited will only subsequently proceed to execute these actions in accordance with your precise and specific instructions, in its capacity of Service Provider and Data Processor.

REEA Digital Limited is not in any manner liable for your contractual relationship with the companies which offer you the platforms within which the marketing campaigns and contests are carried out, which is independent from the relationship between our organizations, case in which you remain completely and exclusively liable and owe the duty to uphold your duties therein. We hereby also reserve our right to recover any damages which might have been caused to us due to our forwarding of certain funds on your account and in your instance in the event in which alterations or cessations of our contractual relationship with you arise.

REEA Digital Limited, in its capacity of Data Processor in respect to you, the Client, in your capacity of Data Controller, actively become involved at any given time in order to protect the personal data which we come into contact with. The authorized personnel which we involve in its management is selected and operates with the upholding of the principles of the minimization and anonymization of the personal data. The personal data to which the current section makes reference to are both your personal ones or those belonging to the organization which you represent, as well as those of the visitors and clients of your own organization. We constantly review our data and systems in order to ensure an optimal degree of privacy and security.

We hereby mention that in our capacity of Data Processor, we also gather financial data in order to manage your online presence and in order to be able to engage you within certain marketing campaigns or contests. The payments are made by you, the contractual relationships in this regard being established directly between yourself and the the companies which offer you the platforms within which the marketing campaigns and contests are carried out. Moreover, we hereby reserve the right to contact you regarding our contractual relationship. The legal basis of the processing is represented by your specific consent to this extent, issued by means of the contractual duties which you undertake.

Notification regarding the copyright

The copyright and any other relevant rights as far as intellectual property is concerned belong to the Client within the ambit of its individual social media networks profiles in its capacity of Personal Data Controller in the absence of a provision to the contrary. The Client grants a free and universal license right to the REEA Digital Limited commercial entity in order for the latter to be entitled to edit, use, modify, rectify, adjust, eliminate any information or part thereof in connection with these authorship rights and any other relevant rights as far as intellectual property is concerned outside of the Client’s individual social media networks profiles, in its capacity of Data Processor.

We hereby reserve the right to modify these aspects without prior notification except for the publishing of the last up to date version within the Internet webpage. The most recent version which is in force is represented by the one which is published on the https://www.reeadigital.com/ Internet page at any given time.

You hereby acknowledge the fact that the provision of services by REEA Digital Limited to you in your capacity of Client presupposes at any given time the full acknowledgement of any subsequent modifications of these provisions.

8. Exercising your rights

All of the rights may be exercised by using the means and contact data placed at your disposal within the “Contact us” section at the end of the current Privacy Policy.

9. How we protect the Personal Data

REEA Digital Limited engages in every reasonable effort in order to protect the data, including that of a personal nature, of all the persons with which it comes into contact. To this end it constantly strives to improve the internal policies and procedures, as well as to improve its own security systems and the training of its personnel.Some of these measures are, for example:

The designation of a Data Protection Officer (entrusted with the personal data protection, “DPO”)

The designation of an Information Security Management Officer/ Manager

The implementation of an ISO27001-certified Information Security Management System. This system implies a series of technical (monitoring systems, compliant equipment, specialized personnel, physical and cybernetic security measures etc.) and organisational (operational policies, procedures) safeguards which apply to the entirety of the personnel

The adoption of an internal organizational code of conduct, applicable to the entirety of its staff

Providing the special legal support regarding the local and international legislation which impacts the personal data

Carrying out ongoing training sessions with the involved personnel in the fields of personal data protection and of information security in general

Ensuring the safeguards of adequate organisational and security systems to the benefit of the partners and collaborators whenever personal data is managed in the capacity of Controller by means of the enforcement of specific contractual provisions.

10. Personal data storage timeframes

Depending on the specific nature of the processing and on that of the duties imposed upon us by the in force legislative framework, the personal data storage timeframes may vary from a low of a few days to a high of a number of years. We hereby mention that the storage timeframes include the archiving timeframe. Thus, the storage timeframes are closely correlated to the validity timeframes of certain issued documents, it is relative to the purpose of the processing and may be influenced by legal provisions regarding to the prescription of certain situations as provided for by the Criminal Code, the Civil Code or other normative provisions that are currently in force.

We hereby assure you that in all given instances we will promptly analyze the possibility of the utmost removal of the data from the entirety of the systems within which its processing is no longer necessary or does no longer correspond to the purpose for which it has been gathered (for example, we will be able to remove the account from a marketing list, so that you will stop receiving notifications, but we will not be able to delete the issued invoices in the event in which good or services have been purchased, as there are specific legal provisions in place imposed by the Tax Code regulating the storage timeframes in such instances). Moreover, we are bound to contact you if there is a legal basis for this action (such as the event of a security breach in which financial data has been compromised, or if the results of our analysis regarding the situation indicates the possibility that you have been impacted from a material and/ or moral standpoint).

On the basis of the above-mentioned, we may state that the REEA Digital Limited policies provide for, in accordance with the current regulatory framework that is in force, durations of storing the personal data starting from 30 days and reaching up to 70 years. As the case may be, the necessary duration that must pass prior to removal in the event of certain specific requests will be transmitted to you via the reply to your request.

Specifically in the case of the https://www.reeadigital.com/ domain:

- The web logs (journals) and those resulted from the security systems will be maintained for a duration of 12 months on the basis of the legislative requirements and that of the legitimate interest (the analysis of security systems, the fulfilment of certain contractual duties).

- Statistical data will be stored in a granular manner for 12 months , and in an aggregated manner for a maximum duration of 3 years.

- The identification data that is sent by means of the contact form will be stored for a duration of 12 months in the situations in which the incidence of a contractual relationship is not reached.

11. Contact us

A. DPO (Data Protection Officer, entrusted with the protection of the personal data, Personal Data Protection Officer)

In order to exercise the rights contained within the current Privacy Policy, in order to receive additional information regarding the gathering and management of personal data by REEA Digital Limited, or for any issues which imply personal data and especially in the event in which minors are involved in accordance with the normative regulatory provisions that are in force, we hereby notify you of your right and duty to immediately and without undue delay contact the REEA Digital Limited Data Protection Officer (DPO):

Name: Murad Khan Address: House: 630, Road: 9, Avenue: 3, MirpurDOHS, Dhaka-1216, Bangladesh. Phone: +8801521110621 Email: office@reeadigital.com

IN FORCE

Version 1.0 - August 1st, 2023

VERSION(S) HISTORY

1. Version 1.0 - in force August 1st, 2023

Date of Last Change: August 1st, 2023

Questions about this document?office@reeadigital.com / DPO: Murad Khan