Privacy Policy

Effective Date: August 28, 2018.

Introduction

Welcome! You have arrived at a web site that is provided by Gaptized, Inc.
(“Company or “we,” “our” or “us”). This “Privacy Policy” governs your use ofwww.michaelstrahan.com (including, without limitation, both mobile and online
versions of our site), and also applies to your use of all features,
applications, content, downloads and other services that we make available
through the site and/or that post a link to this Privacy Policy
(collectively, referred to herein as the “Site”),
regardless of how you access or use the Site, whether via personal
computers, mobile devices or otherwise. This Privacy Policy does not apply
to our data collection activities offline or otherwise outside of our Site
(unless otherwise stated below).


To the extent we provide you notice on our Site of different or
additional privacy policies or practices (e.g., at the point
of our collection), those additional terms shall govern such data
collection and use.

In addition, please review the Service’sTerms of Use, which governs your use of the Site. By using our Site,

you consent to our Privacy Policy and Terms of Use and our collection,
use and sharing of your information and data, and other activities, as
described below.

If you do not agree to the terms of this Privacy Policy, please do not
provide us with any Personal Information and do not use this Site.

If you are located or a resident of the EU, please review Section 11 of
this Privacy Policy, which contains our supplemental privacy notice that
applies to you.

Linkable Table of Contents


It is important that you read and understand the entire Privacy Policy
before using the Site. However, this table of contents highlights key
issues and points and you can click on the headings and the “ More” links to be taken to the full explanation.

1.
What Information Does the Site Collect?

(a)
Information You Provide to Us

You may provide us with Personal Information and Demographic Information
such as when you contact us through the Site or sign up to receive our
electronic newsletter. More

(b)

Information We Collect and Store As You Access and Use the Site

Certain information may be collected from you automatically when you access
and use the Site. For example, we and third parties may use Tracking
Technologies (defined below) to collect Usage Information (defined below)
based on your Device Identifier (defined below) for a variety of purposes,
which may include activities over time and across third party locations. More

(c)
Information Third Parties Provide About You




We may obtain information about you from third parties. More

(d)
Interactions with Third-Party Services


If you interact with third-party services, those services may send us
information about you and you or we may send them information about you. More

(e)
Information You Provide About a Third Party


You may provide us information about others, such as when you send a friend
a message. More

(f)
California / Delaware Do Not Track Disclosures


We do not look for or respond to do not track signals, but you may have
certain other options regarding tracking and/or targeting. More




2.
How Do We Use the Information Collected?

We use your Personal Information, Demographic Information and Usage
Information for a variety of purposes detailed in this section. More

3.

How and When Do We Disclose Information to Third Parties?





We may provide your information to third parties under various
circumstances detailed in this Section. These may include:

(a)


When You Request Information From or Provide Information to Third
Parties





If you request information from third parties, request that we send
information to third parties or interact with third party services, content
or tools (including Facebook and other third party share functionality), we
may share your information with such parties and/or they may collect your
information directly. More

(b)
Third Parties Providing Services on our Behalf




Our vendors may collect your information or we may share it with them. More

(c)
Administrative and Legal Reasons




There are a variety of administrative and legal reasons for which we may
share your information. More

(d)
Affiliates and Business Transfer




We may share your information with our affiliates or in the event of a
sale, merger or similar transaction. More


(e)
Sweepstakes, Contests and Promotions




Promotions entrants may be required to consent to certain information
sharing. More

(f)
Your California Privacy Rights

California residents may request information about sharing of certain
personal information with third parties for the third parties’ direct
marketing purposes by contacting us using the methods described in this
Section. More

4.
Ads and Information About You

We and third parties may send you targeted ads based on your location,
information and/or behavior. If you object, you can exercise choices some
third parties may offer. More

5.


Do Third-Party Content, Links to Third-Party Sites and/or
Third-Party Apps Appear on the Site?





We may allow you to access third-party content on the Site, or to link to
third-party applications and locations from the Site, but we are not
responsible for your interaction with third-party content, apps, and
locations. More

6.

How Do I Change My Information and Communications Preferences?




You may change certain information and preferences. More





7.

What About Transfer of Information to the United States?




Data may be transferred to the United States. More

8.
What Should Parents Know About Children?




We do not intend to collect Personal Information from children. If you
think we have, let us know. More

9.
What About Security?




No data security is absolute, but we take reasonable steps to secure data
appropriately. More

10.
What About Changes to the Privacy Policy?




We may change this Privacy Policy as explained here
.

11.

Supplemental Privacy Notice For Residents of the EU and EEA




This Section applies only if you reside in the EU and EEA and provide the
Company with data. More

The Full Detailed Privacy Policy

1. What Information Does the Site Collect?

(a)
Information You Provide to Us

Personal Information and Demographic Information
. On the Site, we may ask you to provide certain categories of information
such as: (1) personally identifiable information, which is information that
identifies you personally, such as your first and last name, email address,
home address and phone number (“Personal Information”);
and (2) demographic information, such as information about your gender and
age (“Demographic Information”). We may collect this
information through various forms and in various places on the Site,
including through “contact us” forms, if you request to receive our
electronic newsletter or when you otherwise interact with the Site. If we
combine Demographic Information with the Personal Information we collect
directly from you on the Site, we will treat the combined data as Personal
Information under this Privacy Policy.


(b) Information We Collect and Store As You Access and Use the Site



In addition to any Personal Information or other information that you
choose to submit to us via our Site, we and our third-party service
providers may use a variety of technologies that automatically (or
passively) collect and store certain information whenever you visit or
interact with the Site (“Usage Information”). This Usage
Information may be stored or accessed using a variety of technologies that
may be downloaded to your personal computer, browser, laptop, tablet,
mobile phone or other device (a “Device”) whenever you
visit or interact with our Site. Usage Information may be non‑identifying
or may be associated with you. Whenever we associate Usage Information with
your Personal Information, we will treat it as Personal Information. This
Usage Information may include:

· your IP address, UDID or other unique identifier (“ Device Identifier”). A Device Identifier is a number that
is automatically assigned to your Device used to access the Site, and our
computers identify your Device by its Device Identifier;

· your Device functionality (including browser, operating system, hardware,
mobile network information);

· the URL that referred you to our Site;

· the areas within our Site that you visit and your activities there,
including remembering you and your preferences;

· your Device location;

· your Device characteristics; and

· certain other Device data, including the time of day, among other
information.

We may use various methods and technologies to collect and store Usage
Information (“Tracking Technologies”). Tracking
Technologies may set, change, alter or modify settings or configurations on
your Device. A few of the Tracking Technologies include, without
limitation, the following (and subsequent technology and methods later
developed):

Cookies
. A cookie is a data file placed on a Device when it is used to visit the
Site. A Flash cookie (or locally shared object) is a data file placed on a
Device via the Adobe Flash plug-in that may be built-in to or downloaded by
you to your Device. HTML5 cookies can be programmed through HTML5 local
storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in.
Regular cookies may generally be disabled or removed by tools that are
available as part of most commercial browsers, and in some but not all
instances can be blocked in the future by selecting certain settings. Each
browser you use will need to be set separately and different browsers offer
different functionality and options in this regard. Also, these tools may
not be effective with regard to Flash cookies or HTML5 cookies. For
information on disabling Flash cookies, go to Adobe’s web site www.adobe.com. Please be aware that if
you disable or remove cookies, Flash cookies, or HTML5 cookies on your
Device, some parts of our Site may not function properly, and that when you
revisit our Site your ability to limit cookies is subject to your browser
settings and limitations.

Web Beacons
. Small graphic images or other web programming code called web beacons
(also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s
pages and messages. Web beacons may be invisible to you, but any electronic
image or other web programming code inserted into a page or e-mail can act
as a web beacon. Web beacons or similar technologies may be used for a
number of purposes, including, without limitation, to count visitors to the
Site, to monitor how users navigate the Site, to count how many e-mails
that were sent were actually opened or to count how many particular
articles or links were actually viewed.

Embedded Scripts
. An embedded script is programming code that is designed to collect
information about your interactions with the Site, such as the links you
click on. The code is temporarily downloaded onto your Device from our web
server or a third party service provider, is active only while you are
connected to the Site, and is deactivated or deleted thereafter.

Browser Fingerprinting
. Collection and analysis of information from your Device, such as, without
limitation, your operating system, plug-ins, system fonts and other data,
for purposes of identification.

ETag, or entity tag
. A feature of the cache in browsers. It is an opaque identifier assigned
by a web server to a specific version of a resource found at a URL. If the
resource content at that URL ever changes, a new and different ETag is
assigned. Used in this manner ETags are a form of Device Identifier. ETag
tracking may generate unique tracking values even where the consumer blocks
HTTP, Flash and/or HTML5 cookies.

Recognition Technologies
. Technologies, including application of statistical
probability to data sets, which attempt to recognize or make assumptions
about users and devices (e.g., that a user of multiple devices is
the same user).

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary
. We may use cookies or other Tracking Technologies that we consider are
strictly necessary to allow you to use and access our Site, including
cookies required to prevent fraudulent activity, improve security or allow
you to make use of Site functionality.

Performance‑Related
. We may use cookies or other Tracking Technologies that are useful in
order to assess the performance of the Site, including as part of our
analytic practices or otherwise to improve the content, products or
services offered through the Site.

Functionality‑Related
. We may use cookies or other Tracking Technologies that are required to
offer you enhanced functionality when accessing the Site, including
identifying you when you visit our Site or keeping track of our specified
preferences, including in terms of the presentation of content on our Site.

Targeting‑Related
. We may use Tracking Technologies to deliver content relevant to your
interests on our Site and third‑party sites based on how you interact with
our content. This includes using Tracking Technologies to understand the
usefulness to you of the content that have been delivered to you.

There may be other Tracking Technologies now and later devised and used by
us in connection with the Site. Further, third parties may use Tracking
Technologies in connection with our Site, which may include the collection
of information about your online activities over time and across
third-party web sites or online services. We may not control those Tracking
Technologies and we are not responsible for them. However, you consent to
potentially encountering third-party Tracking Technologies in connection
with use of our Site and accept that our statements under this Privacy
Policy do not apply to the Tracking Technologies or practices of such third
parties.

(c) Information Third Parties Provide About You

We may receive information about you from your friends and others that use
the Site, such as when they submit your information to us about you.
Additionally, we may, from time to time, supplement the information we
collect directly from you on our Site with outside records from third
parties for various purposes, including to enhance our ability to serve
you, to tailor our content to you and to offer you opportunities that may
be of interest to you. To the extent we combine information we receive from
those sources with your Personal Information we collect on the Site, it
will be treated as Personal Information and we will apply this Privacy
Policy to such combined information, unless we have disclosed otherwise. In
no other circumstances do our statements under this Privacy Policy apply to
information we receive about you from third parties.

(d)
Interactions with Third Party Services

The Site may include functionality that allows certain kinds of
interactions between the Site and your account on a third-party web site,
application or other service. The use of this functionality may involve the
third-party operator providing certain information, including Personal
Information, to us. For example, we may provide third-party sites’
interfaces or links on the Site to facilitate your sending a communication
from the Site. For example, we may use third parties to facilitate emails,
Tweets or Facebook postings. These third parties may retain any information
used or provided in any such communications or other activities and these
third parties’ practices are not subject to our Privacy Policy. Company may
not control or have access to your communications through these third
parties. Further, when you use third-party sites or services, you are using
their services and not our services and they, not we, are responsible for
their practices. You should review the applicable third-party privacy
policies before using such third-party tools on our Site.

(e) Information You Provide About a Third Party

You may send someone else a communication from the Site, such as sending an
invitation to a friend. If so, the information you provide (names, email
addresses, mobile number, etc.) is used to facilitate the communication and
is not used by us for any other marketing purpose unless we obtain consent
from that person or we explicitly say otherwise. Please be aware that when
you use any send-to-a-friend functionality on our Site, your email address,
mobile number, name or user name and message may be included in the
communication sent to your addressee(s).

(f) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other
mechanisms for the expression of consumer choice regarding the collection
of information about an individual consumer’s online activities over time
and across third-party web sites or online services (e.g., browser
do not track signals). Currently, we do not monitor or take any action with
respect to these signals or other mechanisms.


2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage
Information for various purposes, including:

· to provide you with information such as to send you electronic
newsletters or to provide you with special offers or promotional and
marketing materials on behalf of us or third parties, including to let you
know about upcoming events;

· to enable you to participate in a variety of the Site’s features such as
to enable you to participate in online surveys, entry sweepstakes, contests
or other promotions;

· to improve the Site, marketing endeavors or our Site offerings;

· to customize your experience on the Site or to serve you specific content
that we believe is relevant to you;

· to provide customer support;

· to contact you with regard to your use of the Site and, in our
discretion, changes to the Site and/or Site’s policies;

· to improve the overall experience at the Site;

· for internal business purposes; and

· for purposes disclosed at the time you provide your information or as
otherwise set forth in this Privacy Policy.


3. How and When Do We Disclose Information to Third Parties?

We may share non-Personal Information, such as aggregated user statistics,
with third parties. Further, we may share your Device Identifiers with
third parties along with data related to you and your activities. Also, we
may share your Personal Information with third parties with whom we have
marketing or other relationships for the third parties’ direct marketing
purposes. If you are a California resident, you have the right to request
additional information about this sharing, so please see Section (3)(f)
below. In addition, we may share the information we have collected about
you, including Personal Information, as disclosed at the time you provide
your information and as described below or otherwise in this Privacy
Policy. We may disclose your information as follows:


(a) When You Request Information From or Provide Information to Third
Parties

. You may be presented with an option on our Site to
receive certain information and/or marketing offers directly from third
parties or to have us send certain information to third parties or give
them access to it. If you choose to do so, your Personal Information and
other information may be disclosed to such third parties and all
information you disclose will be subject to the third-party privacy
policies and practices of such third parties. In addition, third parties
may store, collect or otherwise have access to your information when you
interact with their Tracking Technologies, content, tools apps or ads on
our Site or link to them from our Site. This may include using third party
tools such as Facebook, Twitter, Pinterest or other third-party posting or
content sharing tools and by so interacting you consent to such third party
practices. It may also include ordering or purchasing products from third
parties through us where we indicate that the third party rather than us is
the seller. We are not responsible for the privacy policies and practices
of such third parties and, therefore, you should review such third party
privacy policies and practices of such third parties prior to requesting
information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf
. We may use third-party vendors to perform certain services on behalf of
us or the Site, such as: (i) to assist us in Site operations; (ii) to
manage a database of customer information; (iii) hosting the Site; (iv)
designing and/or operating the Site’s features; (v) tracking the Site’s
activities and analytics; (vi) enabling us to send you special offers or
perform other administrative services; and (vii) other services designed to
assist us in maximizing our business potential. We may provide these
vendors with access to user information, including Device Identifiers and
Personal Information, to carry out the services they are performing for you
or for us. Third-party analytics and other service providers may set and
access their own Tracking Technologies on your Device and they may
otherwise collect or have access to information about you, potentially
including Personal Information, about you. We are not responsible for those
third party technologies or activities arising out of them. However, some
may offer you certain choices regarding their practices, and information we
have been informed of regarding such choices is available in Section 4
below. We are not responsible for the effectiveness of or
compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons
. We may access, use, preserve, transfer and disclose your information
(including Device Identifiers and Personal Information) to third parties:
(i) to satisfy any applicable law, regulation, subpoenas, governmental
requests or legal process if in our good faith opinion such is required or
permitted by law; (ii) to protect and/or defend the Service’s Terms of Use or other policies applicable to the
Service, including investigation of potential violations thereof; (iii) to
protect the safety, rights, property or security of the Site or any third
party; and/or (iv) to detect, prevent or otherwise address fraud, security
or technical issues. Further, we may use IP address or other Device
Identifiers, to identify users, and may do so in cooperation with third
parties such as copyright owners, internet service providers, wireless
service providers and/or law enforcement agencies, including disclosing
such information to third parties, all in our discretion, subject to
applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer
. We may share your information, including your Device Identifiers and
Personal Information, Demographic Information and Usage Information with
our parent, subsidiaries and affiliates. We also reserve the right to
disclose and transfer all such information: (i) to a subsequent owner,
co-owner or operator of the Site or applicable database; or (ii) in
connection with a merger, consolidation, restructuring, the sale of
substantially all of our interests and/or assets or other corporate change,
including, during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions
. We may offer sweepstakes, contests, and other promotions (any, a “ Promotion”) through the Site that may require
registration. By participating in a Promotion, you are agreeing to official
rules that govern that Promotion, which may contain specific requirements
of you, including, allowing the sponsor of the Promotion to use your name,
voice and/or likeness in advertising or marketing associated with the
Promotion. If you choose to enter a Promotion, Personal Information may be
disclosed to third parties or the public in connection with the
administration of such Promotion, including, in connection with winner
selection, prize fulfillment, and as required by law or permitted by the
Promotion’s official rules, such as on a winners list.

(f) Your California Privacy Rights
. We may elect to share information about you with third
parties for those third parties’ direct marketing purposes. California
Civil Code § 1798.83 permits California residents who have supplied
personal information (as defined in the law) to us to, under certain
circumstances, request and obtain certain information regarding our
disclosure, if any, of personal information to third parties for their
direct marketing purposes. If this law applies to you, you may obtain the
categories of personal information shared by us and the names and addresses
of all third parties that received personal information for their direct
marketing purposes from us during the immediately prior calendar year ( e.g., requests made in 2018 will receive information about 2017
sharing activities). To make such a request, please provide sufficient
information for us to determine if this applies to you, attest to the fact
that you are a California resident and provide a current California address
for our response. To make such a request (limit one request per year),
please send an email to: contact@michaelstrahan.com,
with “California Privacy Rights” as the subject line or mail us a letter
to: Gaptized, Inc., c/o SMAC Entertainment, 1100 Glendon Avenue, Suite
1220, Los Angeles, CA 90024 (Attn: Legal). You must include your full name,
email address, and postal address in your request.

4. Ads and Information About You

Data about your activities online is being collected on our Site for use in
providing advertising tailored to your individual interests. We may use
third parties such as network advertisers and ad exchanges to serve
advertisements across the Internet and may use third party analytics
service providers to evaluate and provide us and/or third parties with
information about the use of these ads on third party websites and viewing
of ads and of our content. Third parties may offer you a choice as to
whether or not to have your information collected for that purpose. This
section of the privacy policy provides details and explains how to exercise
that choice.

You may see certain ads on our Site as well as on other third-party
websites across the Internet because we participate in advertising networks
administered by third parties. These networks track your online activities
over time and across third party websites by collecting information through
automated means, including through the use of the tracking technologies
described elsewhere in this Privacy Policy, and they use this information
to show you advertisements (including our ads) that are tailored to your
individual interests. The information they collect includes information
about your visits to our Site, such as the pages you have viewed. These
third-party tracking technologies may be set to, among other things: (a)
help deliver advertisements to you that you might be interested in; (b)
prevent you from seeing the same advertisements too many times; and (c)
understand the usefulness to you of the advertisements that have been
delivered to you. You acknowledge and agree that associated technology may
access and use your device and may set or change settings on your device in
connection with the associated operations. Note that any images (or any
other parts of content) served by third parties in association with
third-party ads or other content may act as web beacons, which enable third
parties to carry out the previously described activities.

This collection and ad targeting takes place both on our Site and on
third-party websites that participate in the ad network, such as websites
that feature advertisements delivered by the ad network. This process also
helps us track the effectiveness of our marketing efforts. We and
third-party vendors, including Google, use first-party cookies (such as the
Google Analytics cookie) and third-party cookies (such as a Google Ads
cookie) together to report how your ad impressions, other uses of ad
services, and interactions with these ad impressions and ad services are
related to visits to our Site. To learn more about how to opt out of Google
Ads’s use of cookies, visit the Google’s Ads Settings, here.
To learn more about how to opt out of use of the Google Analytics cookies,
visit the opt-out page,

here

.

Third-party tracking technologies are not controlled by us, even if they
use our technology to help store or collect data. Statements regarding our
practices do not apply to the methods for collecting information used by
these third-party advertisers and others or the use of the information that
such third parties collect. We do however work with third parties to make
efforts to provide you with information on their practices and any
available opportunity to exercise choice. The relevant third party’s terms
of service, privacy policy, permissions, notices and choices should be
reviewed regarding their collection, storage and sharing practices. We make
no representations regarding the policies or practices of third-party
advertisers or advertising networks or exchanges or related third parties.
Further, while we may use a variety of companies to serve advertisements on
the website, you may wish to visit

http://www.networkadvertising.org/choices

, which provides information regarding this practice by Network Advertising
Initiative (“NAI”) members, and your choices regarding
having this information used by these companies, including the “opt-out”
procedures of NAI members. Opting out of one or more NAI members only means
that those NAI members no longer will be allowed under their own rules to
deliver targeted content and/or ads to you, which will affect this and
other sites, but does not mean you will no longer receive any targeted
content and/or ads. Also, if your browsers are configured to reject cookies
when you visit this opt-out page, or you subsequently erase your cookies,
use a different device or change web browsers, your NAI opt-out may not, or
may no longer, be effective. Additional information is available on the
NAI’s website accessible by the above link. You may also be able to opt-out
of receiving third-party behavioral ads by visiting the Digital Advertising
Alliance (“DAA”) website at

http://www.aboutads.info/choices/

. Similar limitations may apply to the DAA opt-out. We are not responsible
for effectiveness of or compliance with any third-parties’ opt-out options.


5. Do Third-Party Content, Links to Third-Party Sites and/or
Third-Party Apps Appear on the Site?

The Site may contain content, links or apps that are supplied by a third
party, and those third parties may collect Usage Information and your
Device Identifier when pages from the Site are served to you for their own
commercial purposes. In addition, when you are on the Site you may be
directed to other sites and apps that are operated and controlled by third
parties that we do not control. We are not responsible for the data
collection and privacy practices employed by any of these third parties or
their sites or apps and they may be tracking you across multiple online
services and may be sharing the results of that tracking with us and/or
others. These third parties may have their own terms of service, privacy
policies or other policies and ask you to agree to the same. For example,
if you “click” on a link, the “click” may take you off the Site onto a
different location. These other online services may associate their
Tracking Technologies with you, independently collect information about
you, including Personal Information, and may or may not have their own
published privacy policies. We are not responsible for these third-party
privacy policies or the practices of Third-Party Owners. Be sure to review
any available policies before submitting any personally identifiable
information to a third-party application or otherwise interacting with it
and exercise caution in connection with these applications. We also
encourage you to note when you leave our Site and to review the third-party
privacy policies of all third-party locations and exercise caution in
connection with them.


6. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you
submit to us, such as your contact information provided as part of
registration. The Site may allow you to review, correct or update Personal
Information you have provided through the Site’s forms, and you may provide
updates and changes by contacting us via email at contact@michaelstrahan.com
.If so, we will make good faith efforts to make requested changes in our
then active databases as soon as reasonably practicable (but we may retain
prior information as business records). Please note that it is not always
possible to completely remove or delete all of your information from our
databases and that residual data may remain on backup media or for other
reasons.

You may cancel or modify our email marketing communications you receive
from us by following the instructions contained within our promotional
emails or in some cases by logging into your Site account and changing your
communication preferences. This will not affect subsequent subscriptions
and if your opt-out is limited to certain types of emails the opt-out will
be so limited. Subsequent or different subscriptions will be unaffected.
Please note that we reserve the right to send you certain communications
relating to your account or use of our Site, such as administrative and
Site announcements and these transactional account messages may be
unaffected if you choose to opt-out from receiving our marketing
communications. If you have any questions about the Privacy Policy or
practices described in it, you should contact us via email a

contact@michaelstrahahn.com

.


7. What About Transfer of Information to the United States?

Our Site is operated in the United States and intended for users located in
the United States. If you are located outside of the United States, please
be aware that information we collect, including Personal Information, will
be transferred to, and processed, stored and used in the United States. The
data protection laws in the United States may differ from those of the
country in which you are located, and your Personal Information may be
subject to access requests from governments, courts, or law enforcement in
the United States according to laws of the United States. By using the Site
or providing us with any information, you consent to the transfer to, and
processing, usage, sharing and storage of your information, including
Personal Information, in the United States as set forth in this Privacy
Policy; provided, however, if you are located or a resident of the EU,
please review Section 11 below as we process your data consistent with the
requirements of the GDPR (defined below).

8. What Should Parents Know About Children?

The Site is a general audience web site and we do not knowingly collect any
personal information from children younger than the age of thirteen (13) as
required by U.S. law. We will delete any personal information collected
that we later determine to be from a user younger than the age of thirteen
(13). If you are a parent or guardian of a child under the age of thirteen
(13) and believe he or she has disclosed personal information to us, please
contact us via email at contact@michaelstrahan.com.

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help
protect and secure your Personal Information. However, no data transmission
over the Internet, mobile networks, wireless transmission or electronic
storage of information can be guaranteed to be 100% secure. Please note
that we cannot ensure the security of any information you transmit to us,
and you use our Site and provide us with your information at your own risk.

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time without
notice to you. Any changes will be effective immediately upon the posting
of the revised Privacy Policy and your use of our Site indicates your
consent to the privacy policy posted at the time of use. However, we will
not use your previously collected Personal Information in a manner
materially different than indicated at the time it was collected without
your consent. To the extent any provision of this Privacy Policy is found
by a competent tribunal to be invalid or unenforceable, such provision
shall be severed to the extent necessary for the remainder to be valid and
enforceable.


11. SUPPLEMENTAL PRIVACY NOTICE FOR RESIDENTS OF THE EU AND EEA

This Supplemental Privacy Notice provides additional information on how we
process personal data that we collect or receive from residents of the EU
and EEA and provides information as relates to EU users’ rights, and
Company’s responsibilities, under the EU General Data Protection Regulation
(“GDPR”).


Data Controller and Local Representative

Company is the data controller of your personal data and we are based in
the United States and located at Gaptized, Inc., c/o SMAC Entertainment,
1100 Glendon Avenue, Suite 1220, Los Angeles, CA 90024. If you are located
or a resident of the EU and believe that your data protection rights under
the GDPR have been infringed, please contact our Data Protection Officer
who can be reached at contact@michaelstrahan.com.
If you feel that your request or concern has not been satisfactorily
resolved by us, you may also contact your local data protection authority,
see:

https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en

.

Legal Basis for Processing EU personal data

Company may processes the personal data of EU users based on one (1) or
more of the legal bases below:

  • Legitimate Interest
    . We may process your personal data as required to pursue our
    legitimate business interests, provided our legitimate interests are
    not overridden by your rights and interests. For example, we may
    process your personal data, to manage, develop and improve our products
    and services; support our customers and sales operations; protect our
    staff and assets; communicate information that supplements our products
    and services and ensure compliance with laws and regulations.
  • Performance of an agreement
    . We may process your personal data to enter into agreements with you
    or to fulfil our obligations under agreements with you or your
    organization. This may include delivering and managing our products and
    services or allowing customers to use our products, services and
    supporting tools.
  • Legal obligation
    . We may process your personal data to comply with applicable laws and
    regulations, establish or exercise our legal rights. For example, in
    connection with legal claims, compliance, regulatory and investigative
    purposes.
  • Consent
    . In some instances, we may process your personal data based on your
    consent. This is most common where we cannot rely on an alternative
    legal basis or we are required by law to ask for your consent in the
    context of some of our sales and marketing activities, online data
    collection tools, or surveys. Where the processing of your personal
    data by us, is based on consent, you have the right to withdraw that
    consent without detriment at any time by contacting us at

    contact@michaelstrahan.com

    .

Data Retention Period

We retain transaction data and other personal data for a period of time
that is necessary to fulfill a legitimate business purpose and deleting or
de-identifying the information thereafter, except where longer retention
periods are required by law. We retain unsubscribe requests permanently to
comply with our obligation to refrain from sending marketing emails after
receipt of an opt-out request.

Your Rights under the GDPR

You have the following rights under certain circumstances:

  • Request access or copies of the personal data Company processes about
    you;
  • Correct or rectify your personal data, if inaccurate or incomplete;
  • Delete your personal data, unless an exception applies. For example, we
    may need to keep your personal data to comply with our legal
    obligations;
  • Restrict the processing of your personal data, in certain
    circumstances. For example, if you contest the accuracy of your
    personal data, you may request that we restrict the processing of your
    personal data for the time it takes us to verify the accuracy of the
    data;
  • Data portability, in certain circumstances. In order to deliver our
    products and services, however, we cannot transmit your personal data
    to another organization; and
  • Object to processing of your personal data, in certain circumstances.
    For example, you may object to direct marketing including the use of
    your personal data for direct marketing profiling or where we process
    your personal data because we have legitimate interest in doing so.

These rights may be limited in some situations where we can demonstrate
that Company has a legal obligation or legitimate interest to process your
personal data.

To exercise your rights explained above, please contact us by email with
the details of your request..