Privacy Policy

Last updated: 02/18/2025

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1. Introduction

Welcome to Mookee. Shuffle Note Inc. (“Mookee”, “us”, “we” or “our”) operates mookee.io, mookee.fans and mookee.link and their subdomains (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to mookee.io, mookee.fans and mookee.link on all platforms, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. We are a Canadian corporation subject to the Canadians laws. Canada may not offer a level of privacy protection as great as that offered in other jurisdictions. Since our servers are located in Canada, your data may be transferred to, stored, or processed in Canada. By using Service, you agree to the collection and use of information in accordance with this Privacy Policy and you understand and consent to the collection, storage, processing, and transfer of your data to our facilities in Canada and those third parties we share your data with as described in this Privacy Policy and our Terms of Service. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Our Terms of Service (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

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2. Definitions

SERVICE means the mookee.io, mookee.fans and mookee.link websites operated by Shuffle Note, Inc.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

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3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

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4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Cookies and Usage Data
Purchase Data
Billing Information
Social Media Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

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Non-Personal Data

While using our Service, we may ask you to provide us with certain Non-Personal Data. “Non-Personal Data” is any information not relating to an identified or identifiable natural person. Non-Personal Data we may collect includes:

Usage Data: as more fully explained below.
Cookies and Tracking Technologies: as more fully explained below.
Aggregate Information: data about how you use the Service combined with data about how others use the Service in order to help us better develop new features and tailor the Service.

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Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, plug-ins, add-ons, location, the version of the Service you are using, and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

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Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

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Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

Other tracking technologies are also used, such as beacons, tags, and scripts, to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies: We use Session Cookies to operate our Service.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
Security Cookies: We use Security Cookies for security purposes.
Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

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Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location, and other data.

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5. Use of Data

Shuffle Note, Inc. uses the collected data for various purposes:

to provide and maintain our Service;
to notify you about changes to our Service;
to allow you to participate in interactive features of our Service when you choose to do so;
to provide customer support;
to gather analysis or valuable information so that we can improve our Service;
to monitor the usage of our Service;
to detect, prevent, and address technical issues;
to fulfill any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
to provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
in any other way we may describe when you provide the information;
for any other purpose with your consent.

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6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Shuffle Note, Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

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8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a) Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(b) Business Transaction

If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.

Other Cases

We may disclose your information also:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business;
to fulfill the purpose for which you provide it;
for the purpose of including your company’s logo on our website;
for any other purpose disclosed by us when you provide the information;
with your consent in any other cases;
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

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9. Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at contact@mookee.io.

In certain circumstances, you have the following data protection rights:

The right to access, update, or to delete the information we have on you;
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
The right to object. You have the right to object to our processing of your Personal Data;
The right of restriction. You have the right to request that we restrict the processing of your personal information;
The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable, and commonly used format;
The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

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11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this Privacy Policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/.

According to CalOPPA we agree to the following:

users can visit our site anonymously;
our Privacy Policy link includes the word “Privacy,” and can easily be found on the page specified above on the home page of our website;
users will be notified of any privacy policy changes on our Privacy Policy Page;
users are able to change their personal information by emailing us at contact@mookee.io.‍

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

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12. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data, and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

(a) What personal information we have about you. If you make this request, we will return to you:

The categories of personal information we have collected about you.
The categories of sources from which we collect your personal information.
The business or commercial purpose for collecting or selling your personal information.
The categories of third parties with whom we share personal information.
The specific pieces of personal information we have collected about you.
A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

(b) To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

(c) To stop selling your personal information. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law.

If you submit a request to stop selling your personal information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your personal information, send an email to contact@mookee.io.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by one of the following means:

By email: contact@mookee.io

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

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13. Service Providers

We may employ third-party companies and individuals to facilitate our Service and/or that help us promote, provide, or support our Service or the services of our customers (“Service Providers”), provide Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

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Google Analytics‍

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

We also encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

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Microsoft Clarity‍

Microsoft Clarity is a web analytics service offered by Microsoft that provides insights into website user behavior, including session recordings and heatmaps. It tracks and reports website traffic to help us understand how users interact with our Service.

For more information on the privacy practices of Microsoft Clarity, please visit the Microsoft Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement.

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Amplitude‍

Amplitude is an analytics service provided by Amplitude Inc. that tracks and monitors user behavior to help us analyze how our Service is being used. Amplitude collects data to provide insights into user engagement, retention, and other metrics.

For more information on the privacy practices of Amplitude, please visit their Privacy Policy: https://amplitude.com/privacy.

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15. CI/CD Tools

We may use third-party Service Providers to automate the development process of our Service.

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GitHub‍

GitHub is provided by GitHub, Inc.

GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects, its purpose, and how the protection of the data is ensured, please visit the GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

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Google Cloud Platform (GCP)

Google Cloud Platform is provided by Google LLC.
GCP offers cloud computing services, including hosting, CI/CD automation, and infrastructure management to support our development and deployment processes.

For more information on what data Google Cloud Platform collects, its purpose, and how data protection is ensured, please visit the Google Cloud Privacy Policy page: Google Cloud Privacy Policy.

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16. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

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Opting Out of Receiving Email Communications from Us‍

If you no longer want to receive marketing-related emails from us, you may opt out via the unsubscribe link or by notifying us at contact@mookee.io. We may still send you important messages regarding administrative matters, updates, disputes, and customer service issues that are required to provide you with the Service.

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Opting Out of Receiving SMS Messages from Us‍

Mookee offers you mobile alerts regarding its and/or its business partners’, customers’, vendors’, event organizers’, suppliers’, advertisers’, or sponsors’ information, migrations, products, events, marketing, advertising, and promotions by SMS messaging (“SMS Messaging”). Enrollment in SMS Messaging requires you to provide your mobile phone number and agree to this Privacy Policy and Mookee’s Terms of Service before the SMS Messaging starts.

To stop receiving SMS Messaging from Mookee, reply with STOP to any SMS Messaging you received from Mookee or use the unsubscribe link we may provide within any of Mookee’s SMS Messaging. This is the exclusive method for opting out. After texting STOP to Mookee, you may receive one additional message confirming that your request has been processed. Text HELP to any SMS Messaging you received from Mookee for support.‍

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Cookies and Other Tracking Technologies‍

Mookee and/or its business partners, customers, vendors, event organizers, suppliers, advertisers, or sponsors may use cookies and other tracking technologies such as pixels and web beacons on the Service to administer the Service, track your movements around the Service, analyze trends, serve targeted advertisements, and gather demographic information.

You can control the use of cookies at the individual browser level. Our third-party partners may use cookies or other tracking technologies to provide you advertising on other sites based upon your browsing activities and interests. If you want to opt-out of interest-based advertising, please visit http://preferences-mgr.truste.com/, or if located in the European Union, visit http://www.youronlinechoices.eu.

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Web Beacons‍

When we send emails to customers and/or users, we may use web beacons to track who opened the emails and clicked links to measure campaign performance and improve features for our customers and/or users. We also use web beacons in the emails we deliver for our customers and/or users to create reports about campaign performance and determine what actions our subscribers and/or users took.

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Our Relationship with Subscribers‍

Our customers may import into the Services Personal Data they have collected from their subscribers or other individuals. We have no direct relationship with Customers’ subscribers or any individuals other than our customers.

Customers are responsible for making sure they have the necessary permissions for us to collect, store, and process Personal Data about our customers’ subscribers or other individuals. A subscriber should unsubscribe directly from a customer’s email, newsletter, or other communication or contact the customer directly to change, update, or delete the subscriber’s data. If a subscriber contacts us, we will refer you to that customer and support them in responding to your request if necessary.

Consistent with this Privacy Policy, we may transfer customer or subscriber Personal Data to our Service Providers. All Service Providers agree to protect Personal Data in accordance with this Privacy Policy.

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Google AdSense DoubleClick Cookie‍

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.

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17. Behavioral Remarketing

Shuffle Note, Inc. uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.

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Google Ads (AdWords)

‍Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

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X‍

X remarketing service is provided by X Corp.

You can opt out of X's interest-based ads by following their instructions: https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads.

You can learn more about the privacy practices and policies of X by visiting their Privacy Policy page: https://x.com/privacy.‍

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Meta‍

Meta remarketing service is provided by Meta Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/business/help/182371508761821?id=176276233019487.

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

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18. Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe‍

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy.

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19. Links to Other Sites and Public Data

Third-Party Sites‍

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. When you click on links to third-party sites, you may leave the Service. This Privacy Policy does not cover any collection, use, or disclosure by third parties through any applications, websites, products, or services that we do NOT control or own, or any third-party features or services made available through the Service. By using the Service, you expressly relieve Mookee from any and all liability arising from your use of any third-party website.

The inclusion of a link or accessibility of third-party sites does not imply endorsement of such third-party sites by us. All trademarks, trade names, and logos of third parties featured on the Service belong to their respective owners.

Each merchant and third-party payment processor collects and shares your information according to its own privacy policy and terms of service. Mookee is not responsible for the actions of third-party processors or merchants, including how such entities treat your information. You are responsible for knowing and understanding their policies and terms.

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Public Data‍

We may provide areas on the Service where you can publicly post information. This information may be read, collected, and used by anyone. We do not control or endorse the information posted by third-party users, are not liable for your or third-party posts to the Service, and specifically disclaim any liability resulting from such posts.

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20. Children's Privacy

Our Service is not intended for use by children under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

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21. Other Region and State-Specific Privacy Laws and Rights

Depending on where you live, you may have certain state or country-specific rights regarding your Personal Data. Under some of these laws and regulations, where applicable, you may have the right to access, deletion, correction, verification, portability, opt-out of tracking for targeted advertising purposes, opt-out of profiling, among other rights. To exercise any rights under these or other applicable data protection laws, please email us at contact@mookee.io.

You may also have the right to file a complaint about Mookee’s collection and processing of Personal Data. To file a complaint, contact the applicable supervisory authority or data protection authority.

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22. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on this page or our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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23. Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: contact@mookee.io.

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Data Import Addendum

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This binding addendum (this “Addendum”) is between Shuffle Note, Inc. (“Mookee”) and Customer and supplements the Mookee Customer Terms of Service or the Platform Terms (the “Agreement”) between Mookee and Customer. Capitalized terms used but not defined herein shall have the meanings ascribed to such terms in the Agreement. For good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties agree to supplement and amend the Agreement as follows:

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1. Data Imports; License

Subject to Mookee’s then-current data import functionality and policies (including, without limitation, Mookee’s requirements regarding form and formatting of imported data), Mookee will ingest certain data, information, and other materials uploaded, transmitted, or otherwise provided to or through the Service by Customer, including without limitation pre-collected telephone numbers (collectively, “Data Imports”) so as to permit Customers to send messages via Mookee Numbers solely to individuals residing in any country (and other Territories as may be added by Mookee from time to time, if any). Customer hereby grants to Mookee a non-exclusive license to host, copy, process, use, transmit, and disclose all Data Imports as necessary to perform its obligations and exercise its rights under this Addendum and the Agreement.

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2. Representations and Warranties

Customer, for itself and on behalf of its Authorized Users, represents, warrants, and covenants that:

(a) it owns or otherwise has all necessary rights to the Data Imports to grant to Mookee all rights and licenses set forth herein;

(b) Mookee’s ingestion and use of Data Imports on or through the Service does not and will not violate Applicable Law, the AUP, or the privacy rights, publicity rights, copyrights, contract rights, intellectual property rights, or other rights of any person or entity;

(c) Customer/Authorized User will not upload or otherwise provide any Data Imports to the Service that contain any Restricted Data;

(d) the upload, posting, or other submission of Data Imports to the Service does not and will not result in a breach of contract between Customer/Authorized User and any third party;

(e) Customer/Authorized User will not knowingly collect personally identifiable information from children under thirteen (13) in connection with Data Imports and/or the Service; and

(f) when using the Service to send messages, Customer will, and will cause Customer/Authorized User to:

(i) comply and maintain appropriate records to demonstrate its compliance with all Applicable Laws and the AUP;
(ii) ensure the content of all messages complies with Applicable Laws and the AUP;
(iii) send messages only to individuals from whom Customer has obtained all necessary and legally required consent to do so in accordance with its obligations under Applicable Laws;
(iv) promptly notify Mookee of all requests made by individuals to stop receiving messages from Mookee on behalf of Customer; and
(v) verify any previously collected Data Imports have been collected in accordance with Applicable Laws.

Customer’s responsibilities as set forth in this Section 2 and the Agreement will remain the sole responsibility and liability of Customer notwithstanding that Mookee may offer templates, advice, guidance, or suggestions relating to any of the matters that are Customer’s responsibility and notwithstanding that Mookee may be engaged to provide services related to such responsibilities of Customer.

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3. Indemnification

Customer will indemnify, defend, and hold Mookee, its affiliates, and their respective directors, officers, employees, agents, successors, and assigns (each, a “Mookee Indemnitee”) harmless from and against any losses, damages, liabilities, debts, and expenses, including reasonable attorneys’ and experts’ fees that may be incurred by a Mookee Indemnitee in relation to any demand, suit, cause of action, or governmental/regulatory inquiry/proceeding arising from or relating to any:

(a) use of the Service by Customer or any Authorized User in violation of this Addendum, the Agreement, Applicable Laws, or the AUP;
(b) breach of Customer’s representations, warranties, or covenants contained herein;
(c) Data Imports uploaded, transmitted, or otherwise provided to the Service and/or Mookee’s use thereof in the exercise of its rights or performance of its obligations hereunder; or
(d) allegation that Customer or Authorized User used the Service, or otherwise caused Mookee, to send messages in violation of any Applicable Laws.

Customer may not enter into any settlement on a Mookee Indemnitee’s behalf without the Mookee Indemnitee’s prior written consent. Each Mookee Indemnitee shall have the right to employ separate counsel and participate in its defense at its sole expense.

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4. Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: contact@mookee.io

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Personal Data Protection Policy

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1. Introduction

We at Shuffle Note, Inc. are committed to processing personal data securely and respecting the privacy of the concerned individuals.

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Version No. and Date of the Last Update:

v. 1.0.0

February 18, 2025

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Approved by:‍

Felix Brochier, CEO of Shuffle Note, Inc.

This policy shall be reviewed annually or each time when changes in our data processing occur.

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2. Scope and Definitions

Scope.‍

This Personal Data Protection Policy (the “Policy”) describes Shuffle Note, Inc. internal rules for personal data processing and protection. The Policy applies to Shuffle Note, Inc., including Shuffle Note, Inc. employees and contractors (“we,” “us,” “our,” “Mookee”). The management of each entity is ultimately responsible for the implementation of this policy, as well as to ensure, at the entity level, there are adequate and effective procedures in place for its implementation and ongoing monitoring of its adherence. For the purposes of this Policy, employees and contractors are jointly referred to as the “employees.”

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Privacy Manager.‍

Privacy Manager is an employee of Mookee responsible for personal data protection compliance within Mookee (the “Privacy Manager”). The Privacy Manager is in charge of performing the obligations imposed by this Policy and supervising other employees, subject to this Policy, regarding their adherence to this Policy. The Privacy Manager must be involved in all projects at an early stage to take personal data protection aspects into account as early as the planning phase.

The designated Privacy Manager at Shuffle Note, Inc. is Felix Brochier.

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EU Representative.‍

As an entity processing personal data in accordance with the EU’s legislation but located outside of the European Union, Mookee must appoint a representative within one of the EU Member States. The task of the representative is to be a contact point for, including but not limited to, supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with this Regulation.

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Term

Definition

Competent Supervisory Authority

Means a public authority that is responsible for regulating and supervising personal data protection with regards to activities of Mookee.

Data Breach

Means a breach of the security and/or confidentiality leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed. This includes, but is not limited to, emails sent to an incorrect or disclosed list of recipients, unlawful publication of Personal Data, or unauthorized access to personal information.

Data Controller

Means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines (makes a decision) the purposes and means of the processing of Personal Data.

Data Processor

Means a natural or legal person, public authority, agency, or other body which processes the Personal Data on behalf of the data controller.

Data Protection Laws

Mean any laws and legal rules on personal data use and protection applicable to the activities of Shuffle Note, Including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, GDPR).

Data Subject Request (DSR)

Means any request from the Data Subject concerning their personal data and/or data subject rights.

Data Subject

Means a natural person whose Personal Data we process. Data Subjects include, but are not limited to, users, website visitors, employees, contractors, and partners of Mookee.

Personal Data

Means any information relating to an identified or identifiable Data Subject; a Data Subject can be identified by reference to an identifier such as a name, identification number, location data, online identifier, or to one or a combination of factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that Data Subject.

Processing

Means any operation or set of operations which is performed by Mookee on Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Standard Contractual Clauses

Means the European Commission Decision of February 5, 2010, on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council (2010/87/EU).

Third Party

Means a natural or legal person who accesses the Personal Data for further processing and is not an employee, member, or corporate affiliate of Mookee. This definition does not apply to natural persons who provide services to Mookee as contractors on a regular basis.

User

Means a Data Subject who uses our services provided on Mookee’s website.

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3. Data Processing Principles

Mookee’s processing activities must align with the principles specified in this section. The Privacy Manager must ensure that Mookee’s compliance documentation, as well as data processing activities, comply with these data protection principles.

We must process Personal Data in accordance with the following principles:

Lawfulness, Fairness, and Transparency:
- We shall always have a legal ground for processing (as described in Section 3 of this Policy), collect data adequate to the purpose and legal grounds, and ensure that Data Subjects are aware of the processing.
Purpose Limitation:
- Collected data must be for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. We must not process Personal Data for purposes not specified in compliance documentation without obtaining specific approval from the Privacy Manager.
Data Minimization:
- Data collected must be adequate, relevant, and limited to what is necessary for the purposes of processing. We ensure data collected is not excessive and is strictly necessary.
Accuracy:
- We endeavor to delete inaccurate or false data about Data Subjects and ensure it is updated as necessary. Data Subjects may request corrections to their Personal Data.
Storage Period Limitation:
- Data should be kept in a form that permits identification of Data Subjects for no longer than necessary for processing purposes. Storage periods must comply with Data Protection Laws and this Policy.
Confidentiality, Integrity, and Availability:
- Data must be processed in a manner ensuring appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using suitable technical and organizational measures.

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Accountability

We shall demonstrate compliance with Data Protection Laws (the accountability principle). In particular, we must ensure and document relevant procedures, efforts, and internal/external consultations on personal data protection, including:

The appointment of a person responsible for Mookee’s data protection compliance.
Where necessary, a record of a Data Processing Impact Assessment.
Development and implementation of notices, policies, and procedures, such as the Privacy Notice, this Policy, or Data Breach response procedures.
Staff training on compliance with Data Protection Laws.
Assessment, implementation, and testing of organizational and technical data protection measures.

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Records of Processing Activities

The Privacy Manager must maintain Mookee’s Records of Processing Activities, an accountability document prepared in accordance with Article 30 of the GDPR. These records must include at least the following information for each processing activity:

Contact details of Mookee, the EU Representative, and, where applicable, the Data Protection Officer.
Name of the activity, its purposes, and legal basis, along with the legitimate interests of Mookee (if applicable).
Categories of Data Subjects and Personal Data involved.
Data retention periods.
General description of applicable security measures.
Recipients (including joint controllers, processors, and contractors), and details of international data transfers with safeguards applied.
References to Data Processing Impact Assessments (if applicable).
Records of data breaches involving personal data (if applicable).

If Mookee acts as a data processor, additional information must include:

Names and contact details of controllers and their representatives (if applicable).
Categories of processing activities.
Details of third countries or international organizations receiving Personal Data and applicable safeguards.
General description of technical and organizational security measures.

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Legal Grounds

Each processing activity must have one of the lawful grounds specified in this section to process the Personal Data. If we do not have any of the described grounds, we cannot collect or further process the Personal Data.

If Mookee intends to use personal data for purposes other than those specified in the Records of Processing Activities, the Privacy Manager must evaluate, determine, and, if necessary, collect/record the appropriate legal basis.

Performance of the Contract:
- Where Mookee has a contract with the Data Subject (e.g., website Terms of Use or an employment contract), and the contract requires the provision of personal data from the Data Subject, the applicable legal ground will be the performance of the contract.
Consent:
- To process personal data based on consent, we must obtain consent before processing and keep evidence of the consent with the records of the Data Subject’s Personal Data. The Privacy Manager must ensure:
  - The Data Subject is free to give or refuse consent.
  - Consent is given actively (e.g., no pre-ticked checkboxes).
  - Requests for consent clearly articulate processing purposes and provide other required information.
  - The Data Subject can freely revoke consent.
Legitimate Interests:
- Mookee has the right to use personal data for legitimate interests related to its business activities, such as marketing analysis. The Privacy Manager must ensure:
  - Legitimate interests are clearly defined and recorded in the Records of Processing Activities.
  - Risks to Data Subject rights are identified and addressed.
  - Data Subjects have reasonable expectations about the processing.
  - Data Subjects are allowed to opt-out from processing for legitimate interests.
If any of the above conditions are not met, the Privacy Manager must propose a different legal ground for processing, such as consent.
Legal Compliance and Public Interest:
- Mookee may be required by EU laws or laws of EU Member States to process Personal Data. Examples include compliance with financial or labor laws.
- We must:
  - Process personal data strictly per legal requirements.
  - Not use or store collected data for purposes other than legal compliance.
  - Inform Data Subjects about the scope and conditions of processing.

If legal requirements from other countries apply, the Privacy Manager must evaluate and propose an alternative legal ground, such as legitimate interests or consent.

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Access to Personal Data

Need-to-Know Basis:
- Employees may access personal data only when strictly necessary for activities specified in the Records of Processing Activities.
Access Control:
- Employees and contractors must have proper credentials to access Personal Data.
- Department heads must maintain a list of employees authorized to access personal data.
- The Privacy Manager has the right to review and request amendments to access lists.
Employee Training and Awareness:
- Department heads must ensure employees are aware of Data Protection Laws and comply with this Policy.
- Employees must receive adequate data protection training.
Confidentiality:
- Employees must keep data confidential and process it using only approved methods (software, premises, etc.).
- Data must not be disclosed outside management instructions.
Incident Reporting:
- Employees must report suspicious activities, data breaches, or non-compliance to the Privacy Manager.
- Employees unsure about processing or disclosing data must consult the Privacy Manager before acting.
Occasional Access:
- Occasional access to personal data for unlisted activities is prohibited unless strictly necessary and approved by the Privacy Manager.

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4. Third Parties

Before sharing personal data with any person outside of Mookee, the Privacy Manager must ensure that this Third Party has an adequate data protection level and provides sufficient data protection guarantees in accordance with Data Protection Laws. This includes, but is not limited to, compliance with the processorship requirements (Art. 28 of the GDPR) and international transfers compliance (Section 5 of the GDPR). Where necessary, the Privacy Manager must make sure that Mookee enters into the appropriate data protection contract with the third party.

Employees may share personal data with third parties only if, and to the extent, explicitly prescribed by their manager and specified in the Records of Processing Activities.

If we are required to delete, change, or stop processing the Personal Data, we must ensure that the Third Parties with whom we shared the Personal Data fulfill these obligations accordingly.

Whenever Mookee is engaged as a data processor on behalf of another entity, the Privacy Manager must ensure Mookee complies with its processorship obligations. In particular, the following must be adhered to:

The appropriate data processing agreement in accordance with the Data Protection Laws must be in place.
The Privacy Manager must supervise compliance with data processing instructions from the controller, including:
- The scope of processing activities.
- Involvement of sub-processors.
- International transfers.
- Storage and further disposal of processed personal data.

Personal data processed under the processor role must not be processed for any purposes other than those specified in the relevant instructions, agreement, or other legal act regulating the relationships with the controller.

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5. International Transfers

If we have employees, contractors, corporate affiliates, or Data Processors outside of the EEA, and we transfer Personal Data to them for processing, the Privacy Manager must ensure that Mookee takes all necessary and appropriate safeguards in accordance with Data Protection Laws.

The Privacy Manager must assess the available safeguards and propose to Mookee’s management the appropriate safeguard for each international transfer. The following regimes apply to the transfers of Personal Data outside of the EU:

Adequate Jurisdictions:
- Where the European Commission decides that a country has an adequate level of personal data protection, the transfer does not require additional safeguards. The full list of adequate jurisdictions can be found on the relevant page of the European Commission’s website.
Standard Contractual Clauses (SCCs):
- To transfer Personal Data to contractors or partners (Data Processors or Controllers) in other third countries, we must conclude Standard Contractual Clauses with that party. Draft versions and guidance can be found on the relevant page of the European Commission’s website.
Binding Corporate Rules (BCRs) or Codes of Conduct:
- If we have a corporate affiliate or entity in other countries, we may choose to adopt Binding Corporate Rules in accordance with Article 47 of the GDPR or an approved code of conduct pursuant to Article 40 of the GDPR.
Approved Certifications:
- We may transfer Personal Data to entities with an approved certification in accordance with Article 42 of the GDPR, which certifies an appropriate level of data protection.

Information Obligations:‍

As part of our information obligations, Mookee must inform Data Subjects that their Personal Data is being transferred to other countries and provide details about the safeguards used for the transfer. This information obligation must be performed in accordance with Subsection 6.2.

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Derogations:‍

In exceptional cases (the “Derogation”), where the safeguards mentioned above cannot be applied and a transfer of Personal Data is required, one of the following conditions must be met:

Explicit consent (active statement) from the Data Subject must be obtained.
The transfer must be strictly necessary for the performance of the contract between Mookee and the Data Subject.
Other derogation conditions must apply, in accordance with Data Protection Laws.

The Privacy Manager must pre-approve any Derogation transfers, document the approved Derogations, and record the rationale for them.

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6. Rights of Data Subjects

Our Responsibilities

Privacy Manager Responsibility:
The Privacy Manager is ultimately responsible for handling all DSRs received by Mookee. In the case of receiving any outstanding or unusual DSRs, employees must seek advice from the Privacy Manager before taking action.
Departmental Responsibilities:
- Customer Support within Mookee is responsible for handling DSRs from Mookee Users daily.
- The Human Resources department handles DSRs from Mookee employees.
DSR Handling:
- All DSRs from Users must be addressed and answered via contact@mookee.io.
- DSRs from employees may be addressed directly to the HR manager or at contact@mookee.io.
- The responsible employee must respond to the DSR within one (1) month. If the response requires more time, the Privacy Manager must be consulted, and the Data Subject must be informed about the extended response period (up to two additional months).
Verification and Documentation:
- Verification: Employees must ensure the Data Subject’s identity matches their claims by validating connections between personal data records and the Data Subject. If verification fails, the Privacy Manager must refuse the request and notify the Data Subject within one (1) month.
- Documentation: Every DSR must be documented, including the date, type of request, decision made, and reasons for refusal (if applicable).

Rights of Data Subjects

The Right to Be Informed:
Mookee must notify each Data Subject about the collection and processing of their Personal Data, including:
- Name and contact details of Mookee.
- Legal basis for data collection and processing.
- Categories of data collected.
- Retention periods.
- Rights of Data Subjects.
- Safeguards for international transfers.
  This information is provided via the Privacy Policy on Mookee's website for Users and standalone employee privacy statements for employees/contractors.
The Right to Access Information:
Data Subjects may:
- Learn if Mookee processes their data.
- Obtain case-specific information on processing.
- Receive a copy of their Personal Data upon request.
The Right to Rectification:
Data Subjects can request corrections to inaccurate or outdated data. Mookee must update such information promptly.
The Right to Restrict Processing:
Data Subjects may request a temporary halt in data processing under these conditions:
- Contesting data accuracy.
- Believing data is processed unlawfully.
- Objecting to processing while the request is considered.
  During this time, Mookee must restrict processing to storage or legal compliance only.
The Right to Withdraw Consent:
Data Subjects may revoke consent at any time. Mookee must record this change and cease consent-based processing. Withdrawal does not affect the lawfulness of prior processing.
The Right to Object to Processing:
Data Subjects may object to processing based on legitimate interests, such as marketing. Mookee must:
- Evaluate the objection.
- Cease processing if no overriding interest exists.
- Maintain records to ensure data is not processed for objected purposes.
The Right to Erasure ("To Be Forgotten"):
Data Subjects may request data erasure if:
- The data is no longer needed for its purpose.
- Consent is withdrawn or processing is objected to.
- Data is processed unlawfully.
  Conditions where erasure can be denied include:
- Compliance with legal obligations.
- Use for scientific, historical, or statistical purposes under proper safeguards.
Data Portability:
Data Subjects may request their data be transferred to a third party in a machine-readable format if:
- The data was collected under contract performance or consent.
  To comply, employees must consolidate the data and send it to the designated organization.

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7. New Data Processing Activities

Notification to Privacy Manager

Before introducing any new activity involving the processing of personal data, the employee responsible for its implementation must inform the Privacy Manager.

Upon receiving information about a new activity, the Privacy Manager must:

Determine whether a Data Processing Impact Assessment (DPIA) and/or consultation with the Supervisory Authority is necessary. If so, ensure the DPIA is conducted and/or the Supervisory Authority is consulted in accordance with the requirements of this section and Data Protection Laws.
Determine the legal basis for the processing and take further action to document it if necessary.
Ensure the processing activity aligns with this Policy, other Mookee policies, and Data Protection Laws.
Add the processing activity to the Records of Processing Activities.
Amend privacy information statements and inform the concerned Data Subjects accordingly, where required.

Data Processing Impact Assessment (DPIA)

To ensure current or prospective processing activities do not and will not violate Data Subjects’ rights, Mookee must conduct a DPIA, where required by Data Protection Laws. The DPIA is a risk-based assessment designed to identify risks and measures to mitigate them.

The Privacy Manager, involving competent employees and/or external advisors where necessary, must conduct a DPIA if at least one of the following conditions is met:

The processing involves new technologies (e.g., Artificial Intelligence, autonomous devices) that create significant legal, economic, or similar effects for the Data Subject.
Automated profiling or personal scoring that creates legal or similar effects for the Data Subject.
Processing sensitive data on a large scale, such as:
- Data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or orientation.
- Data relating to criminal convictions or offences.
Collecting or processing Personal Data from publicly accessible sources on a large scale, or combining/matching datasets.
The Supervisory Authority lists the activity as requiring a DPIA.

DPIA Details

A DPIA must include:

A systematic description of processing operations and purposes, including:
- Data categories, Data Subjects, processing scale (frequency, volume, number of records, etc.), recipients, retention periods, and international transfers (if applicable).
An assessment of the necessity and proportionality of processing operations in relation to their purposes.
An assessment of risks to Data Subjects' rights and freedoms, including risks of:
- Discrimination, identity theft, fraud, financial loss, reputation damage, loss of confidentiality, or deprivation of control over Personal Data.
- Unauthorized reversal of pseudonymization or significant economic or social disadvantage.
- Processing involving vulnerable individuals (e.g., children) or large volumes of personal data affecting many Data Subjects.
Measures to address risks, including safeguards, security measures, and mechanisms ensuring compliance with Data Protection Laws.

Consultation with the Supervisory Authority

If the DPIA does not identify effective measures to address risks, the Privacy Manager must consult the competent Supervisory Authority to seek guidance. Mookee must not proceed with the activity until the Supervisory Authority approves it.

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8. Data Retention

General Rule

The Privacy Manager must ensure that Mookee clearly defines the data storage periods and/or criteria for determining storage periods for each processing activity. The periods for each processing activity must be specified in the Records of Processing Activities.

Each department within Mookee must comply with the data storage periods in accordance with the retention schedule provided in the Records of Processing Activities. The Privacy Manager must supervise each department to ensure compliance with this requirement.

After the storage period ends, personal data must be:

Removed from the disposal of the department responsible for processing.
If no longer needed for other purposes, destroyed completely, including from backup copies and other media.

If personal data is still necessary for other processing purposes after the storage period for a specific activity has ended, the department manager must:

Ensure the data is not used for the ceased activity.
Restrict access to the data unless required for other activities.

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Exemptions

The rules specified in Subsection 8.1 have the following exceptions:

Business Needs:
- Data retention periods can be extended (up to 60 days) if deletion would interrupt or harm ongoing business operations. The Privacy Manager must approve such extensions.
Technical Impossibility:
- In cases where deletion is technically impossible or disproportionately difficult (e.g., where deletion might breach system integrity or cannot be achieved in backup systems), the data may be retained, subject to:
  - Approval by the Privacy Manager.
  - Appropriate amendments to the Records of Processing Activities.
Anonymization:
- Personal Data may be further processed for any purposes (e.g., marketing) if fully anonymized after the retention period expires. Anonymization requires deleting all personal identifiers and connections so that reidentification of the Data Subject is impossible.

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9. Security

Each department within Mookee must take appropriate technical and organizational measures to protect personal data under their responsibility against unauthorized, unlawful, and/or accidental:

Access
Destruction
Modification
Blocking
Copying
Distribution
Other illegal actions by unauthorized persons

The employee responsible for supervising personal data security within Mookee is Felix Brochier. This individual is responsible for:

Implementing guidelines and specifications on data protection and information security.
Advising Mookee management on planning and implementing information security.
Being involved in projects at an early stage to incorporate security-related aspects during the planning phase.

Detailed security measures are described in Mookee's Security Policy.

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10. Data Breach Response Procedure

Response Team

In the case of a Data Breach, the CEO of Mookee shall urgently form the Data Breach Response Team (the “Response Team”), which will handle the breach, notify the appropriate persons, and mitigate risks.

The Response Team must be a multi-disciplinary group headed by the CEO of Mookee and include:

The Privacy Manager.
A privacy law specialist (internal or external).
Knowledgeable and skilled information security specialists within Mookee or outsourcing professionals, if necessary.

The team ensures that all employees and contractors adhere to this Policy and provides an immediate and effective response to any suspected, alleged, or actual Data Breach affecting Mookee.

The Response Team's duties include:

Communicating the Data Breach to the Competent Supervisory Authority(-ies).
Communicating the Data Breach to affected Data Subjects in cases of high risk to their rights and freedoms.
Informing third parties about the breach when data obtained as a processor is involved.
Notifying Mookee’s contractors or third parties processing the affected Personal Data.
Taking technical and organizational measures to mitigate and cease the breach.
Recording the breach in the Records of Processing Activities and filing an internal Data Breach report.

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Notification to Supervisory Authority

Mookee must inform the Competent Supervisory Authority about the Data Breach without undue delay and, where possible, within 72 hours of becoming aware of the breach.

The Competent Supervisory Authority is determined by the residence of the affected Data Subjects.
If multiple countries are involved, Mookee must inform all relevant authorities.

The notification must include:

Nature of the Data Breach, including the categories and approximate number of Data Subjects and Personal Data records affected.
Contact details of the Response Team, Privacy Manager, or CEO.
Likely consequences of the Data Breach.
Measures taken or proposed to mitigate risks and adverse effects.

Notifications must use Mookee's Data Breach Notification Form.

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Notification to Data Subjects

When a Data Breach poses a high risk to Data Subjects’ rights and freedoms, Mookee must notify them without undue delay.

The notification must include:

Description of the breach, its causes (if disclosed), and what happened.
Measures taken by Mookee to address the breach.
Recommendations for mitigating risks (e.g., password changes).
Contact information for the Response Team or its members.

Exemptions to notifying Data Subjects include:

Mookee implemented protections, such as encryption, that render data inaccessible.
Measures were taken to ensure high risk is no longer likely to materialize.
Notification would involve disproportionate effort, in which case a public communication or similar effective measure may be used.

Any exemptions must be documented, including reasons for not notifying and actions taken.

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Communication with Third Parties

If a Data Breach involves Personal Data shared with or processed on behalf of a third party, Mookee must notify the third party within 24 hours.

When acting as a Data Processor, Mookee must:

Inform the third party.
Mitigate consequences of the breach.

Notifications to Supervisory Authorities and Data Subjects are the responsibility of the third party.

If Mookee receives a breach notification from a Data Processor or another third party, the CEO shall:

Form the Response Team.
Request detailed breach information.
Inform Supervisory Authorities and Data Subjects if necessary.
Follow the steps outlined in this procedure.

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ANNEX 1 TO THE PERSONAL DATA PROTECTION POLICY

European National Data Protection Authorities

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Austria

Österreichische Datenschutzbehörde

Hohenstaufengasse 3

1010 Wien

Tel. +43 1 531 15 202525

Fax +43 1 531 15 202690

e-mail: dsb@dsb.gv.at

Website: http://www.dsb.gv.at/

Art 29 WP Member: Dr Andrea JELINEK, Director, Österreichische Datenschutzbehörde

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Belgium

Commission de la protection de la vie privée

Commissie voor de bescherming van de persoonlijke levenssfeer

Rue de la Presse 35 / Drukpersstraat 35 1000 Bruxelles / 1000 Brussel

Tel. +32 2 274 48 00

Fax +32 2 274 48 35

e-mail: commission@privacycommission.be

Website: http://www.privacycommission.be/

Art 29 WP Vice-President: Willem DEBEUCKELAERE, President of the Belgian Privacy commission

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Bulgaria

Commission for Personal Data Protection

2, Prof. Tsvetan Lazarov blvd. Sofia 1592

Tel. +359 2 915 3580

Fax +359 2 915 3525

e-mail: kzld@cpdp.bg

Website: http://www.cpdp.bg/

Art 29 WP Member: Mr Ventsislav KARADJOV, Chairman of the Commission for Personal Data Protection

Art 29 WP Alternate Member: Ms Mariya MATEVA

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Croatia

Croatian Personal Data Protection Agency

Martićeva 14

10000 Zagreb

Tel. +385 1 4609 000

Fax +385 1 4609 099

e-mail: azop@azop.hr or info@azop.hr

Website: http://www.azop.hr/

Art 29 WP Member: Mr Anto RAJKOVAČA, Director of the Croatian Data Protection Agency

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Cyprus

Commissioner for Personal Data Protection

1 Iasonos Street,

1082 Nicosia

P.O. Box 23378, CY-1682 Nicosia Tel. +357 22 818 456

Fax +357 22 304 565

e-mail: commissioner@dataprotection.gov.cy

Website: http://www.dataprotection.gov.cy/

Art 29 WP Member: Ms Irene LOIZIDOU NIKOLAIDOU

Art 29 WP Alternate Member: Mr Constantinos GEORGIADES

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Czech Republic

The Office for Personal Data Protection

Urad pro ochranu osobnich udaju Pplk. Sochora 27

170 00 Prague 7

Tel. +420 234 665 111

Fax +420 234 665 444

e-mail: posta@uoou.cz

Website: http://www.uoou.cz/

Art 29 WP Member: Ms Ivana JANŮ, President of the Office for Personal Data Protection

Art 29 WP Alternate Member: Mr Ivan PROCHÁZKA, Adviser to the President of the Office

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Denmark

Datatilsynet

Borgergade 28, 5

1300 Copenhagen K

Tel. +45 33 1932 00

Fax +45 33 19 32 18

e-mail: dt@datatilsynet.dk

Website: http://www.datatilsynet.dk/

Art 29 WP Member: Ms Cristina Angela GULISANO, Director, Danish Data Protection Agency (Datatilsynet)

Art 29 WP Alternate Member: Mr Peter FOGH KNUDSEN, Head of International Division at the Danish Data Protection Agency (Datatilsynet)

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Estonia

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)

Väike-Ameerika 19

10129 Tallinn

Tel. +372 6274 135

Fax +372 6274 137

e-mail: info@aki.ee

Website: http://www.aki.ee/en

Art 29 WP Member: Mr Viljar PEEP, Director General, Estonian Data Protection Inspectorate

Art 29 WP Alternate Member: Ms Maarja Kirss

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Finland

Office of the Data Protection Ombudsman

P.O. Box 315

FIN-00181 Helsinki Tel. +358 10 3666 700

Fax +358 10 3666 735

e-mail: tietosuoja@om.fi

Website: http://www.tietosuoja.fi/en/

Art 29 WP Member: Mr Reijo AARNIO, Ombudsman of the Finnish Data Protection Authority

Art 29 WP Alternate Member: Ms Elisa KUMPULA, Head of Department

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France

Commission Nationale de l'Informatique et des Libertés - CNIL

8 rue Vivienne, CS 30223 F-75002 Paris, Cedex 02 Tel. +33 1 53 73 22 22

Fax +33 1 53 73 22 00

Website: http://www.cnil.fr/

Art 29 WP Member: Ms Isabelle FALQUE-PIERROTIN, President of CNIL

Art 29 WP Alternate Member: Ms Florence RAYNAL

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Germany

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit

Husarenstraße 30

53117 Bonn

Tel. +49 228 997799 0; +49 228 81995 0

Fax +49 228 997799 550; +49 228 81995 550

e-mail: poststelle@bfdi.bund.de

Website: http://www.bfdi.bund.de/

The competence for complaints is split among different data protection supervisory authorities in Germany.

Competent authorities can be identified according to the list provided under https://www.bfdi.bund.de/bfdi_wiki/index.php/Aufsichtsbeh%C3%B6rden_und_Landesdatenschutzbeauftragte

Art 29 WP Member: Ms Andrea VOSSHOFF, Federal Commissioner for Freedom of Information

Art 29 WP Alternate Member: Prof. Dr. Johannes CASPAR, representative of the federal states

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Greece

Hellenic Data Protection Authority

Kifisias Av. 1-3, PC 11523 Ampelokipi Athens

Tel. +30 210 6475 600

Fax +30 210 6475 628

e-mail: contact@dpa.gr

Website: http://www.dpa.gr/

Art 29 WP Member: Mr Konstantinos Menoudakos, President of the Hellenic DPA

Art 29 WP Alternate Member: Dr.Vasilios ZORKADIS, Director

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Hungary

National Authority for Data Protection and Freedom of Information

Szilágyi Erzsébet fasor 22/C H-1125 Budapest

Tel. +36 1 3911 400

e-mail: peterfalvi.attila@naih.hu

Website: http://www.naih.hu/

Art 29 WP Member: Dr Attila PÉTERFALVI, President of the National Authority for Data Protection and Freedom of Information

Art 29 WP Alternate Member: Mr Endre Győző SZABÓ Vice-president of the National Authority for Data Protection and Freedom of Information

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Ireland

Data Protection Commissioner

Canal House Station Road Portarlington Co. Laois

Lo-Call: 1890 25 22 31

Tel. +353 57 868 4800

Fax +353 57 868 4757

e-mail: info@dataprotection.ie

Website: http://www.dataprotection.ie/

Art 29 WP Member: Ms Helen DIXON, Data Protection Commissioner

Art 29 WP Alternate Members: Mr John O'DWYER, Deputy Commissioner; Mr Dale SUNDERLAND, Deputy Commissioner

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Italy

Garante per la protezione dei dati personali

Piazza di Monte Citorio, 121 00186 Roma

Tel. +39 06 69677 1

Fax +39 06 69677 785

e-mail: garante@garanteprivacy.it

Website: http://www.garanteprivacy.it/

Art 29 WP Member: Mr Antonello SORO, President of Garante per la protezione dei dati personali

Art 29 WP Alternate Member: Ms Giuseppe BUSIA, Secretary General of Garante per la protezione dei dati personali

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Latvia

Data State Inspectorate Director: Ms Daiga Avdejanova

Blaumana str. 11/13-15

1011 Riga

Tel. +371 6722 3131

Fax +371 6722 3556

e-mail: info@dvi.gov.lv

Website: http://www.dvi.gov.lv/

Art 29 WP Alternate Member: Ms Aiga BALODE

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Lithuania

State Data Protection

Žygimantų str. 11-6a 011042 Vilnius

Tel. + 370 5 279 14 45

Fax +370 5 261 94 94

e-mail: ada@ada.lt

Website: http://www.ada.lt/

Art 29 WP Member: Mr Raimondas Andrijauskas, Director of the State Data Protection Inspectorate

Art 29 WP Alternate Member: Ms Neringa KAKTAVIČIŪTĖ-MICKIENĖ, Head of Complaints Investigation and International Cooperation Division

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Luxembourg

Commission Nationale pour la Protection des Données

1, avenue du Rock’n’Roll L-4361 Esch-sur-Alzette Tel. +352 2610 60 1

Fax +352 2610 60 29

e-mail: info@cnpd.lu

Website: http://www.cnpd.lu/

Art 29 WP Member: Ms Tine A. LARSEN, President of the Commission Nationale pour la Protection des Données

Art 29 WP Alternate Member: Mr Thierry LALLEMANG, Commissioner

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Malta

Office of the Data Protection Commissioner Data Protection Commissioner: Mr Joseph Ebejer

2, Airways House

High Street, Sliema SLM 1549 Tel. +356 2328 7100

Fax +356 2328 7198

e-mail: commissioner.dataprotection@gov.mt

Website: http://www.dataprotection.gov.mt/

Art 29 WP Member: Mr Saviour CACHIA, Information and Data Protection Commissioner

Art 29 WP Alternate Member: Mr Ian DEGUARA, Director – Operations and Programme Implementation

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Netherlands

Autoriteit Persoonsgegevens

Prins Clauslaan 60

P.O. Box 93374

2509 AJ Den Haag/The Hague Tel. +31 70 888 8500

Fax +31 70 888 8501

e-mail: info@autoriteitpersoonsgegevens.nl

Website: https://autoriteitpersoonsgegevens.nl/nl

Art 29 WP Member: Mr Aleid WOLFSEN, Chairman of Autoriteit Persoonsgegevens

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Poland

The Bureau of the Inspector General for the Protection of Personal Data - GIODO

ul. Stawki 2

00-193 Warsaw

Tel. +48 22 53 10 440

Fax +48 22 53 10 441

e-mail: kancelaria@giodo.gov.pl; desiwm@giodo.gov.pl

Website: http://www.giodo.gov.pl/

Art 29 WP Member: Ms Edyta BIELAK-JOMAA, Inspector General for the Protection of Personal Data

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Portugal

Comissão Nacional de Protecção de Dados - CNPD

R. de São. Bento, 148-3° 1200-821 Lisboa

Tel. +351 21 392 84 00

Fax +351 21 397 68 32

e-mail: geral@cnpd.pt

Website: http://www.cnpd.pt/

Art 29 WP Member: Ms Filipa CALVÃO, President, Comissão Nacional de Protecção de Dados

Art 29 WP Alternate Member: Isabel CRUZ, Secretary-General of the DPA

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Romania

The National Supervisory Authority for Personal Data Processing President: Mrs Ancuţa Gianina Opre

B-dul Magheru 28-30

Sector 1, BUCUREŞTI

Tel. +40 21 252 5599

Fax +40 21 252 5757

e-mail: anspdcp@dataprotection.ro

Website: http://www.dataprotection.ro/

Art 29 WP Member: Ms Ancuţa Gianina OPRE, President of the National Supervisory Authority for Personal Data Processing

Art 29 WP Alternate Member: Ms Alina SAVOIU, Head of the Legal and Communication Department

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Slovakia

Office for Personal Data Protection of the Slovak Republic

Hraničná 12

820 07 Bratislava 27

Tel.: + 421 2 32 31 32 14

Fax: + 421 2 32 31 32 34

e-mail: statny.dozor@pdp.gov.sk

Website: http://www.dataprotection.gov.sk/

Art 29 WP Member: Ms Soňa PŐTHEOVÁ, President of the Office for Personal Data Protection of the Slovak Republic

Art 29 WP Alternate Member: Mr Anna VITTEKOVA, Vice President

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Slovenia

Information Commissioner

Ms Mojca Prelesnik Zaloška 59

1000 Ljubljana

Tel. +386 1 230 9730

Fax +386 1 230 9778

e-mail: gp.ip@ip-rs.si

Website: https://www.ip-rs.si/

Art 29 WP Member: Ms Mojca PRELESNIK, Information Commissioner of the Republic of Slovenia

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Spain

Agencia de Protección de Datos

C/Jorge Juan, 6

28001 Madrid

Tel. +34 91399 6200

Fax +34 91455 5699

e-mail: internacional@agpd.es

Website: https://www.agpd.es/

Art 29 WP Member: Ms María del Mar España Martí, Director of the Spanish Data Protection Agency

Art 29 WP Alternate Member: Mr Rafael GARCIA GOZALO

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Sweden

Datainspektionen

Drottninggatan 29 5th Floor

Box 8114

1.20 Stockholm

Tel. +46 8 657 6100

Fax +46 8 652 8652

e-mail: datainspektionen@datainspektionen.se

Website: http://www.datainspektionen.se/

Art 29 WP Member: Ms Kristina SVAHN STARRSJÖ, Director General of the Data Inspection Board

Art 29 WP Alternate Member: Mr Hans-Olof LINDBLOM, Chief Legal Adviser

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United Kingdom

The Information Commissioner’s Office

Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Tel. +44 1625 545 745

e-mail: international.team@ico.org.uk

Website: https://ico.org.uk

Art 29 WP Member: Ms Elizabeth DENHAM, Information Commissioner

Art 29 WP Alternate Member: Mr Steve WOOD, Deputy Commissioner

EUROPEAN FREE TRADE AREA (EFTA)

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Iceland

Icelandic Data Protection Agency

Rauðarárstíg 10

1.Reykjavík

Tel. +354 510 9600; Fax +354 510 9606

e-mail: postur@personuvernd.is

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Liechtenstein

Data Protection Office

Kirchstrasse 8, P.O. Box 684

9490 Vaduz

Principality of Liechtenstein Tel. +423 236 6090

e-mail: info.dss@llv.li

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Norway

Datatilsynet

The Data Inspectorate

P.O. Box 8177 Dep 0034 Oslo

Tel. +47 22 39 69 00; Fax +47 22 42 23 50

e-mail: postkasse@datatilsynet.no

Data Protection Authority: Mr Bjørn Erik THORN

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Switzerland

Data Protection and Information Commissioner of Switzerland

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter Mr Adrian Lobsiger

Feldeggweg 1

3003 Bern

Tel. +41 58 462 43 95; Fax +41 58 462 99 96 e-mail: contact20@edoeb.admin.ch

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