PRIVACY POLICY
Effective date: 01/01/2020
1. Introduction
Welcome to Schaad Consulting.
Schaad Consulting (“us”, “we”, or “our”) operates raphaelschaad.com (hereinafter referred to
as “Service”).
Our Privacy Policy governs your visit to raphaelschaad.com, 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. By using Service, you agree to thecollection and use of information in accordance with this policy. Unless otherwise defined inthis Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our
Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with thePrivacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
SERVICE means the raphaelschaad.com website operated by Schaad Consulting.
PERSONAL DATA means data about a living individual who can be identified from thosedata (or from those and other information either in our possession or likely to come into ourpossession).
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 incommon 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.

13. Information Collection and Use
We collect several different types of information for various purposes to provide and improve
our Service to you.
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”). Personallyidentifiable information may include, but is not limited to:(a) Email address(b) First name and last name(c) Phone number(d) Address, State, Province, ZIP/Postal code, City(e) Cookies and Usage 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 or by emailingat hello@raphaelschaad.com.
Usage Data
We may also collect information that your browser sends whenever you visit our Service orwhen 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, thetime and date of your visit, the time spent on those pages, unique device identifiers andother diagnostic data.
When you access Service with a mobile device, this Usage Data may include informationsuch 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.
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 andcustomize 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:(a) Session Cookies: We use Session Cookies to operate our Service.
(b) Preference Cookies: We use Preference Cookies to remember your preferences andvarious settings.
(c) Security Cookies: We use Security Cookies for security purposes.
(d) Advertising Cookies: Advertising Cookies are used to serve you with advertisementsthat may be relevant to you and your interests.
Other Data
While using our Service, we may also collect the following information: sex, age, date ofbirth, 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.
5. Use of Data
Schaad Consulting uses the collected data for various purposes:(a) to provide and maintain our Service;(b) to notify you about changes to our Service;(c) to allow you to participate in interactive features of our Service when you choose to doso;(d) to provide customer support;(e) to gather analysis or valuable information so that we can improve our Service;(f) to monitor the usage of our Service;(g) to detect, prevent and address technical issues;3(h) to fulfill any other purpose for which you provide it;(i) to carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collection;(j) to provide you with notices about your account and/or subscription, including expiration
and renewal notices, email-instructions, etc.;(k) 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 alreadypurchased or enquired about unless you have opted not to receive such information;(l) in any other way we may describe when you provide the information;(m) for any other purpose with your consent.
6. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out inthis Privacy Policy. We will retain and use your Personal Data to the extent necessary tocomply with our legal obligations (for example, if we are required to retain your data tocomply with applicable laws), resolve disputes, and enforce our legal agreements andpolicies.
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.
7. Transfer of DataYour 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 United States and choose to provide information to us, please
note that we transfer the data, including Personal Data, to United States and process it
there.
Your consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.
Schaad Consulting 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 organisation or a country unless there are adequate controls inplace 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.
(c) Other cases. We may disclose your information also:(i) to our subsidiaries and affiliates;(ii) to contractors, service providers, and other third parties we use to support ourbusiness;(iii) to fulfill the purpose for which you provide it;(iv) for the purpose of including your company’s logo on our website;(v) for any other purpose disclosed by us when you provide the information;(vi) with your consent in any other cases;(vii)if we believe disclosure is necessary or appropriate to protect the rights, property, or
safety of the Company, our customers, or others.
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.
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), youhave certain data protection rights, covered by GDPR. – See more athttps://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 ofyour 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 hello@raphaelschaad.com.

5In certain circumstances, you have the following data protection rights:(a) the right to access, update or to delete the information we have on you;(b) the right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete;(c) the right to object. You have the right to object to our processing of your Personal Data;(d) the right of restriction. You have the right to request that we restrict the processing ofyour personal information;(e) 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;(f) 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 able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use ofyour Personal Data. For more information, please contact your local data protection
authority in the European Economic Area (EEA).
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 requirea person or company in the United States (and conceivable the world) that operates
websites collecting personally identifiable information from California consumers to post aconspicuous privacy policy on its website stating exactly the information being collected andthose individuals with whom it is being shared, and to comply with this policy. – See more at:https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protecti
on-act-caloppa-3/
According to CalOPPA we agree to the following:(a) users can visit our site anonymously;(b) 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;(c) users will be notified of any privacy policy changes on our Privacy Policy Page;(d) users are able to change
hello@raphaelschaad.com.

theirpersonal

informationbyemailing

us

at

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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 inyour 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 yourweb browser.
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 canmake certain requests and ask us:(a) What personal information we have about you. If you make this request, we will
return to you:(i) The categories of personal information we have collected about you.
(ii) The categories of sources from which we collect your personal information.
(iii) The business or commercial purpose for collecting or selling your personal
information.
(iv) The categories of third parties with whom we share personal information.
(v) The specific pieces of personal information we have collected about you.
(vi) A list of categories of personal information that we have sold, along with the categoryof any other company we sold it to. If we have not sold your personal information, we
will inform you of that fact.
(vii)A list of categories of personal information that we have disclosed for a businesspurpose, 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 twotimes 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 theprevious 12 months.
(b) To delete your personal information. If you make this request, we will delete thepersonal 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 yourpersonal information, you may not be able to use certain functions that require yourpersonal information to operate.
(c) To stop selling your personal information. If you submit a request to stop selling yourpersonal information, we will stop selling it. If you are a California resident, to opt-out of7

the sale of your personal information, click “Do Not Sell My Personal Information” at thebottom of our home page to submit your request.
Please note, if you ask us to delete or stop selling your data, it may impact yourexperience 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 yourrequest(s) by one of the following means:
By email: hello@raphaelschaad.com
By visiting this page on our website: raphaelschaad.com
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.
13. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service
Providers”), provide Service on our behalf, perform Service-related services or assist us inanalysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on ourbehalf and are obligated not to disclose or use it for any other purpose.
14. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
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 tocontextualise and personalise 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 the Google's policy for safeguarding your data:
https://support.google.com/analytics/answer/6004245.
Segment.io
Segment.io is a web traffic analysis tool. You can read the Privacy Policy for Segment.io
here: https://segment.com/legal/privacy/.

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15. CI/CD tools
We may use third-party Service Providers to automate the development process of ourService.
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 for what purpose and how the protection
of
the
data
is
ensured,pleasevisit
GitHub
Privacy
Policypage:
https://help.github.com/en/articles/github-privacy-statement.
16. Advertising
We may use third-party Service Providers to show advertisements to you to help supportand maintain our Service.
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 theirvisit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising byvisiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
Bing Ads
Bing Ads is an advertising service provided by Microsoft Inc.
You can opt-out from Bing Ads by following the instructions on Bing Ads Opt-out page:https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
For more information about Bing Ads, please
https://privacy.microsoft.com/en-us/PrivacyStatement

visit

their

Privacy

Policy:AdMob by Google
AdMob by Google is provided by Google Inc.
You can opt-out from the AdMob by Google service by following the instructions described
by Google: https://support.google.com/ads/answer/2662922?hl=en
For more information on how Google uses the collected information, please visit the “How
Google uses data when you use our partners' sites or app” page:
http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google:
http://www.google.com/policies/privacy/
AdButler
AdButler is an advertising service provided by Sparklit Networks Inc.
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For more information about AdButler, please visit
https://www.sparklit.com/agreements.spark?agreement=privacy

their

Privacy

Policy:Unity Ads
Unity Ads is provided by Unity Technologies.
You can opt-out from Unity Ads service by following the instructions as described by Unity
Technologies on their Privacy Policy page: https://unity3d.com/legal/privacy-policy
For more information about Unity Technologies, please visit Unity Technologies Privacy
Policy: https://unity3d.com/legal/privacy-policy
17. Behavioral Remarketing
Schaad Consulting 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, optimiseand serve ads based on your past visits to our Service.
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
Networkads
byvisitingtheGoogleAds
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
Bing Ads Remarketing
Bing Ads remarketing service is provided by Microsoft Inc.
You can opt-out of Bing Ads interest-based ads by following their instructions:
https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
You can learn more about the privacy practices and policies of Microsoft by visiting their
Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement
Twitter
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions:
https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their
Privacy Policy page: https://twitter.com/privacy
10Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page:https://www.facebook.com/help/164968693837950
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 Advertisingestablished by the Digital Advertising Alliance. You can also opt-out from Facebook andother 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
Pinterest
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the “Do Not Track”
functionality of your web browser or by following Pinterest instructions:
http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about the privacy practices and policies of Pinterest by visiting their
Privacy Policy page: https://about.pinterest.com/en/privacy-policy
18. Payments
We may provide paid products and/or services within 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 bytheir 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:
PayPal or Braintree:
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-fullApple Store In-App Payments:
Their Privacy Policy can be viewed at: https://www.apple.com/legal/privacy/en-ww/ /https://support.apple.com/en-us/HT203027

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Google Play In-App Payments:
Their Privacy Policy can be viewed at: https://policies.google.com/privacy?hl=en&gl=us /https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=priv
acynotice&ldl=en
Stripe:Their Privacy Policy can be viewed at: https://stripe.com/us/privacy
19. Links to Other 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 thePrivacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies orpractices of any third party sites or services.
20. Children's Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or“Children”).
We do not knowingly collect personally identifiable information from Children under 18. 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 ofparental consent, we take steps to remove that information from our servers.
21. 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 our Service, prior to the change
becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to thisPrivacy Policy are effective when they are posted on this page.
22. Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: hello@raphaelschaad.com.
By visiting this page on our website: raphaelschaad.com.

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