Exhibit 1 – Personal Data Processing Agreement

This agreement (the ”Personal Data Processing Agreement”) has been entered into between Adtraction and You (the ”Publisher”).

1. Introduction and scope

Adtraction and the Publisher have entered into an agreement which enables the Publisher to provide space on its website or other internet marketing channels for links and advertisements for the websites that have a Publisher program registered with Adtraction (the ”Publisher Agreement”).

Adtraction collects and stores personal information about individuals who register as Publishers via Adtraction’s website. Personal information is defined as all types of information that can directly or indirectly be linked to an individual, including name, address and telephone number.

Adtraction and the Publisher are referred to individually as a ”Party” and jointly as the ”Parties”.

This Personal Data Processing Agreement applies for the processing of Personal data within the framework of Adtraction’s service and its obligations to monitor and register Traffic that is directed via the Publisher’s website to the Advertiser’s website.

This Personal Data Processing Agreement covers all processing of Personal data from the Publisher and which Adtraction process.

This Personal Data Processing Agreement terminates automatically when the Publisher Agreement terminates, for whatever reason.

2. Definitions

”Personal data” is an identifier such as a name, an identification number, location data, an online identifier to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. To process Personal data means collection, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, align or combining, restricting, erasing or destructing, Personal data.

”Applicable Personal Data legislation” means all national and international rules of data protection that is applicable during this Personal Data Processing Agreement’s validity time. The definition includes the EU General Data Protection Regulation (EU) 2016/679) ”GDPR”) which will be directly applicable and take effect on 25 May 2018. Until the GDPR takes effect, the Parties shall follow applicable data protection legislation in the country where they operate (in Sweden the Swedish Personal Data Act (1998:204) applies).

3. Personal data which Adtraction process

Adtraction collects and process the following Personal data:

  • Name,
  • Address,
  • E-mail address,
  • Phone number,
  • IP-address,
  • Personal identity number,
  • Bank account number,
  • Other information that you provide within the framework of Adtraction’s service.

4. Purpose of processing personal data

Collected Personal data will be used to provide access to Adtraction’s services, to pay the Publisher, administration, intern analyzes and to fulfill other commitments.

5. Consent

By accepting the terms of this Personal Data Processing Agreement, the Publisher consents that the Publisher’s Personal data will be collected and processed as set out in this Personal Data Processing Agreement, i.e. that the personal data of the Publisher can be used to:

  • Enable access to Adtraction’s services
  • Paying compensation
  • Administration
  • Internal analyzes
  • Fulfill commitments under applicable laws or agreements with Publisher or Advertiser
  • Be handled and dispensed to Adtraction’s subsidiaries and Adtraction’s subcontractors/processors
  • Store, dispense and share information as a response to legal inquiries (for example search of premises, court order, summons or similar requests) or when it is required by law or otherwise when it is necessary to detect and prevent criminal activity. Personal data may in those cases be handled and stored for a longer period of time than what is necessary for other uses of Personal data.

The Publisher has the right to recall its consent. The recall shall be made in writing to Adtraction.

6. Publisher’s Rights

The Publisher has the right to obtain information of the Personal data concerning him or her which is being processed by Adtraction, and the Publisher has the right to access to such Personal data in a digital format.

The Publisher also has the right to request Adtraction to rectify or erase Personal data or restrict Adtraction’s processing of Personal data concerning the Publisher or to object to such processing if it is allowed according to Applicable Personal Data Legislation.

Adtraction has an obligation to erase Personal data where one of the following grounds applies:

  • The Personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
  • The Publisher withdraws the consent on which the processing is based upon and there is no other legal ground for the processing,
  • The Publisher objects to the processing pursuant to Article 21(1) in the GDPR and there is no overriding legitimate grounds for the processing or if the Publisher objects to the processing pursuant to Article 21(2) in the GDPR,
  • The Publisher’s data has been unlawfully processed by Adtraction.

The Publisher has the right to lodge a complaint of Adtraction’s processing of Personal data to the Swedish Data Protection Authority.

7. Transfer of personal data

The Publishers Personal data can be handled by Adtraction’s subsidiaries and subcontractors/processors if it is necessary to achieve the purpose for which the Personal data has been collected under this Personal Data Processing Agreement.

Adtraction is allowed to use subcontractors/processors to process Personal data in accordance with this Personal Data Processing Agreement.

8. Security Safeguards

Adtraction will take appropriate technical and organizational measures to protect Personal data against unauthorized access, destruction and change as well as ensure that only Personal data which is necessary for each specific processing purpose of is processed.

9. Changes and amendments

The Publisher agree that this Personal Data Processing Agreement can be changed by Adtraction in order for it to be in accordance with Applicable Personal Data Legislation. In such case the Publisher will be notified and asked to give its consent to those changes.

10. Dispute, choice of law and forum

This Personal Data Processing Agreement shall be governed by the substantive law of Sweden. Any dispute, controversy or claim arising out of or in connection with this Personal Data Processing Agreement, or the breach, termination or invalidity thereof, shall be settled by general courts in Sweden, with Stockholm District Court as court of first instance.

11. Contact information to the controller

Adtraction is responsible for the processing of Personal data under this Personal Data Processing Agreement. If the Publisher has questions about Adtraction’s handling of Personal data, please contact Adtraction at info@adtraction.com or +46 8-35 92 00.