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PRIVACY POLICY

Last updated: March 27, 2023

Table of contents:

Definitions
Personal Data We Collect
Your Permission Account
Wallet Information
Permission Ads Users and ASK Rewards-related Information
Financial Data
Our browser extension
Permission Ads Opt-in Campaigns
Your Personal Data and the Blockchain
Your communications with us
General device data
Automated website tracking and cookies
Tracking pixels
How long do we keep your data?
How do we use your information?
When do we share your information?
• To obey the law or protect rights
• With Service Providers to support necessary business activities
• With our Advertising Partners
• If you choose to share it with other users
In the event of a merger or acquisition
Third-party Sites
• What are My Rights with Respect To My Personal Data?
• Exercising your rights
• Opting out of emails
• Do-Not-Track signals
How does Permission protect my information?
Policy for Minors
Supplemental State Privacy Notice
Supplemental Notice for Nevada Residents
Notice to All Non-US Residents
Changes to This Policy
How Can You Contact Us About This Policy

Permission.io, Inc. (“Permission”, “we”, “us” or “our”) enables advertisers and
other marketplace participants to incentivize users with cryptocurrency rewards
to grant permission and engage in various data sharing activities.

Permission respects the privacy of our users (“user”, “you”, or “your”). Our
belief is that any personal information provided to us by you is just that:
personal and private. This Privacy Policy (“Privacy Policy”, “Policy”) explains
how we collect, use, disclose, and safeguard your information when you use our
Services, and describes certain of your rights under applicable law. Please read
this Privacy Policy carefully.

This Policy applies to information Permission collects when you use Permission’s
platform, various mobile and web applications, websites (including
https://permission.io and all subdomains of https://permission.io), blogs,
forums, and any other media channels or products, such as the Permission Browser
Extension and the Permission Ads’ digital properties, including, but not limited
to, a landing page hosted by Permission that contains an advertisement served by
or on behalf of Permission, a page on the Permission domain, or in the
Permission mobile app, or any other Permission products, including those that
may be introduced from time to time in the future (collectively referred to
herein as the “Services”).

This Privacy Policy does not apply to any of the personal information that
Permission Ads’ advertising customers (“Customers”) may collect and process
using our Services (“Customer Data”). Our Customers’ respective privacy policies
govern their collection and use of Customer Data. Our processing of Customer
Data is governed by the contracts that we have in place with our Customers, not
this Privacy Policy. Any questions or requests relating to the processing of
Customer Data should be directed to our Customers.


1. DEFINITIONS

We believe that our policies should be legible and easy to understand for the
general public, as well as our Customers and business partners. All terms used
below have the definitions provided under applicable laws, such as the EU
General Data Protection Regulation (GDPR).


2. PERSONAL DATA WE COLLECT

Our goal is to make it possible for you to be rewarded for your engagement and
data-sharing activities. We collect and use your information in order to provide
and improve our Services and your experience, protect the security and integrity
of our platform, and meet our legal obligations. If you do not wish for your
personal information to be collected, used, or disclosed as described in this
Privacy Policy, or you are under 13 years of age, you should stop accessing our
Services.

The following section describes the personal data we collect. For residents of
certain states, more information on what we collect is available in our
supplemental disclosure below.


YOUR PERMISSION ACCOUNT

When you access or register with the Services, you may be required to provide an
email address and password. You may also choose to provide additional
information to us, including but not limited to:

 * your first and last name,
 * your postal address,
 * email address, phone number, and other similar contact data,
 * your age,
 * your gender,
 * your nationality,
 * your occupation,
 * your annual household income,
 * your marital status,
 * your number of children,
 * your hometown, place of employment, and interests


WALLET INFORMATION

Once you have created an account, you have the option to create a Permission.io
cryptocurrency wallet address or to submit a third-party cryptocurrency wallet
address. In order to set up your Permission.io wallet, you will need to provide
a photo of yourself, as well as a photo of your government-issued
identification, and any other information required under applicable law to
verify your identity. When you create or connect to Permission.io or a
third-party wallet, you may be entitled to receive certain rewards (as defined
in our Terms of Use). Note that your use of any third-party wallet services is
subject to each wallet’s respective privacy policy, not this Privacy Policy.


PERMISSION ADS USERS AND ASK REWARDS-RELATED INFORMATION

As you use the Services, we may also collect personal information and details
associated with your wallet transfers, such as the earned rewards deposited in
your Permission wallet or in any third-party cryptocurrency wallet you choose to
link to your Permission account.

You are free to change or completely remove any information shared with us at
any time. However, refusing to provide requested personal data might prevent you
from using certain features of the Services. If you use our Services to withdraw
and/or transfer your ASK tokens to another ASK-compatible wallet, we or our
service providers may collect additional information to verify your identity in
accordance with our legal obligations.

We may provide you with the option to register for Permission using your
existing social media account, like Facebook, LinkedIn, Twitter or other social
media providers. Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information
we receive may vary depending on the social media provider concerned, but will
often include your name, email address, friends’ list, profile picture as well
as other information you choose to share with us. We will use the information we
receive only for the purposes that are described in this privacy policy or that
are otherwise made clear to you via the Services. Please note that we do not
control, and are not responsible for, other uses of your personal information by
your third-party social media provider. We recommend that you review each social
media provider’s privacy policy to understand how they collect, use and share
your personal information, and how you can set your privacy preferences on their
sites and apps.

If you consent to our collection of biometric information, you agree that we may
collect your facial geometry from your photograph in order to verify that it
matches your government-issued ID. We use a third-party verification service to
verify your identity, which includes use of your facial geometry. After
verification, your facial geometry is deleted.


FINANCIAL DATA

When you purchase, order, return, exchange or request information about our
services from the Services, you may be asked to share financial data with us
related to your payment method. This information may include your valid credit
card number, card brand, expiration date, as well as other details necessary to
process your payment information. This financial information is processed and
stored by our various payment processors. We encourage you to review their
privacy policies and contact them directly for responses to your questions.


OUR BROWSER EXTENSION

If you use our browser extension, we will collect time-stamped information about
what websites you visit (including the URLs, page titles, and metadata
descriptions of each page). This information may also include search history and
queries, as contained within site URLs. We use the data we have collected about
you associated with your Permission account to show you personalized offers and
advertisements within the browser extension. We use the information above to
measure your interactions with these ads (for example, whether you click on the
ad to visit the marketer’s website) in order to reward you with ASK tokens.


PERMISSION ADS OPT-IN CAMPAIGNS

If you click on a Permission Ads advertisement and visit any Permission.io
digital property, you may voluntarily provide us with certain personal
information in response to a Permission Ads Customer questionnaire. In instances
where you have interacted with a Permission Ads advertisement, but have not yet
created a Permission account, Permission will retain your email address so that
you may be rewarded with ASK tokens in accordance with the Terms of Use. In
instances where a Permission Customer has collected your information, that
collection is governed by such Customer’s privacy policy; however, once you
create a Permission account, we will process any additional account data that we
collect in accordance with this Privacy Policy.

As part of Permission Ads Opt-in campaigns, Permission may collect behavioral
data and preference data as you engage with the campaign. For example,
Permission may be able to identify how you interface with the site, such as how
long you stay on each page.


YOUR PERSONAL DATA AND THE BLOCKCHAIN

Blockchain technology may be used as part of the Services. Blockchains are
decentralized and made up of digitally recorded data in a chain of packages
called “blocks.” The manner in which these blocks are linked is chronological,
meaning that the data is very difficult to alter once recorded. Since the ledger
may be distributed all over the world, this means there is no single person
making decisions or otherwise administering the system (such as an operator of a
cloud computing system), and that there is no centralized place where it is
located either.

Accordingly, by design, a blockchain’s data cannot be changed or deleted and is
said to be “immutable.” This may affect your ability to exercise your rights
such as your right to erase (“right to be forgotten”), or your rights to object
or restrict processing of your Personal Data. Data on the blockchain cannot be
erased and cannot be changed. Although smart contracts may be used to revoke
certain access rights, and some content may be made invisible to others, it is
not deleted.

In certain circumstances, in order to effect delivery of digital assets or
provision of other services, it will be necessary to collect certain Personal
Data, such as your wallet address, onto the blockchain; this is done through a
smart contract and requires you to execute such transactions using your wallet’s
private key.

The ultimate decision to (a) transact on the blockchain using your wallet
address, as well as (b) share the public key relating to your wallet address
with anyone (including us) rests with you. IF YOU WANT TO ENSURE YOUR PRIVACY
RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS
CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US DUE TO THE
TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IN PARTICULAR, THE BLOCKCHAIN IS
AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL
BECOME PUBLICLY AVAILABLE.

By using any of our Services that involve blockchain technology, you give us
your consent to process the given data in order to perform the requested
activity.


YOUR COMMUNICATIONS WITH US

You may choose to contact us by email or through our Services for a variety of
purposes such as product or company inquiries, customer support inquiries and
sales requests. When you do this, we collect any information you voluntarily
submit to us, such as your first and last name, email address, phone number, job
title and company name. We may also provide the opportunity to register for
events, order or request whitepapers, or participate in online surveys. It is
completely up to you to choose whether or not you want to provide it.


GENERAL DEVICE DATA

Whenever you access or interact with our Services, we collect some general data
and information about the request and store the relevant details in server or
system log files. This data includes location data and details like your IP
address, your browser type and version used, mobile identifiers, MAC address,
your device type and operating system, the time and date you accessed the
Services, and the pages you viewed directly before and after accessing our
Services. Additional detail may be collected or derived from this information
for use in the event of an attack on our information technology systems.

To support these efforts, we analyze de-identified or aggregated collected data
and information statistically, with the aim of increasing the data protection
and security of our company, and to maintain an optimal level of protection for
the personal data we process.


AUTOMATED WEBSITE TRACKING AND COOKIES

We partner with selected third-party vendors, described below, which may allow
tracking technologies and remarketing services on our Services through the use
of cookies, web beacons, tracking pixels, and other tracking technologies
(“Technologies”). Our use of Technologies fall into the following categories:

 * Strictly Necessary. These cookies are necessary for the website to function
   and cannot be switched off in our systems. They are usually only set in
   response to actions made by you which amount to a request for services, such
   as setting your privacy preferences, logging in or filling in forms. You can
   set your browser to block or alert you about these cookies, but some parts of
   the site will not then work. These cookies do not store any personally
   identifiable information.
 * Functional. These cookies enable the website to provide enhanced
   functionality and personalization. They may be set by us or by third party
   providers whose services we have added to our pages. If you do not allow
   these cookies, then some or all of these services may not function properly.
 * Targeting. We may use first party or third-party Technologies to deliver
   content, including ads relevant to your interests, on our Services or on
   third-party websites.

You are encouraged to review each cookie vendor’s privacy policies and contact
them directly for responses to your questions.

Permission’s use of cookies may change at our sole discretion. For example,
Permission may use the following “cookies” to track your visit:

 1. 1. * Google Analytics. For more information about how Google uses your
         personal information (including for its own purposes, e.g., for
         profiling or linking it to other data), please visit Google Analytics’
         Privacy Policy. To learn more about how to opt-out of Google Analytics’
         use of your information, please click here.
       * LinkedIn Analytics. For more information about how LinkedIn uses your
         personal information, please visit LinkedIn Analytics’ Privacy Policy.
         To learn more about how to opt-out of LinkedIn’s use of your
         information, please click here.

We may also use other third-party cookies for personalized advertising: see
“Cookies and Personalized Advertising” in the section “What Are My Rights with
Respect To My Personal Data?” below for more information on how to opt out of
some of this collection.

Note: You should be aware that getting a new computer, installing a new Internet
browser, upgrading an existing browser, or erasing or otherwise altering your
Internet browser’s cookies may also clear certain opt-out cookies, plugins or
settings.


TRACKING PIXELS

Our newsletter and emails sent from or on behalf of Permission may contain
tracking pixels, or a transparent image embedded in emails to enable log file
recording and analysis. We use information collected in this manner to perform
statistical analysis of the success or failure of online marketing and customer
outreach efforts. Based on the embedded tracking pixel, we may be able to
determine if and when an email was opened, and which links in the email were
accessed.

Personal data collected using tracking pixels is stored and analyzed by us to
optimize the delivery of our newsletters and emails, and to improve the
relevance of the distributed content. Many email clients and web browsers
support functionality to opt out or prevent the use of these tracking
mechanisms. You may also revoke your consent to receiving our newsletter at any
time.


3. HOW LONG DO WE KEEP YOUR DATA?

We only process and keep personal data that you share with us for as long as
needed to achieve the purpose of storage, as long as consent is maintained, or
as long as is granted by laws or regulations we are subject to. The exact length
of time we keep personal data depends on the respective statutory retention
period for that type of information. While retention requirements vary by
country, we maintain internal retention policies on the basis of how information
needs to be used. This includes considerations such as when the information was
collected or created, whether it is necessary in order to continue offering you
our Services, whether we are required to hold the information to comply with our
legal obligations, including AML/KYC compliance, or whether it is necessary to
protect the safety, security, and integrity of our Services, Customers, and
Users.

Upon the expiration of any retention period, or if storage of personal data is
not applicable, personal data is routinely blocked, deleted or erased in
accordance with our retention schedule and applicable law. Additionally, in line
with these considerations, we delete information that is no longer needed for
the above purposes when you close your account, or when you request deletion of
your information.

Keep in mind that, while our systems are designed to carry out our deletion
practices automatically, we cannot promise that deletion will occur within a
specific timeframe. There may be legal requirements to store your data, and we
may need to suspend those deletion practices if we receive valid legal process
asking us to preserve data, if we receive reports of abuse or other Terms of
Service violations, or if your account is flagged by our systems for abuse or
other Terms of Service violations. Finally, we may also retain certain
information in backup for a limited period of time or as required by law.


4. HOW DO WE USE YOUR INFORMATION?

Having accurate information about you helps us provide a smooth, efficient, and
customized experience. Generally speaking, we use any information we collect to
provide services to you, keep our Services running smoothly, and protect us
legally. More specifically, we may use information collected about you,
including but not limited to, in the following instances:

 1. 1. * Create and manage your account
       * Provide our Services to you
       * Contact you about your account or orders
       * Send you a newsletter once you successfully subscribe
       * Respond to your comments, questions, and requests and provide customer
         service
       * Send you technical notices, updates, security alerts, and support and
         administrative messages
       * Compile aggregated or de-identified statistical data for use internally
         or with third parties
       * Maintain and improve the efficiency and operation of our Services and
         products
       * Assist with the development of our products and other purposes related
         to Permission’s business
       * Monitor and analyze usage and trends to improve your experience with
         our Services and products
       * Pursuing our legitimate interests such as direct marketing
       * Process and deliver contest entries and rewards
       * Process information about your wallet to facilitate ASK reward
         transfers via the Services
       * To maintain legal and regulatory compliance: For services related to
         cryptocurrency rewards, we are required to collect, use, and store your
         personal information such as verifying your identity in order to comply
         with anti-money laundering laws across jurisdictions
       * Assist law enforcement and respond to subpoenas, and to resolve
         disputes and troubleshoot problems
       * To prevent account fraud and for security purposes

In accordance with applicable law, information covered by this Policy may be
transferred to, and processed in, the United States or any other country in
which Permission or its affiliates, subsidiaries or service providers maintain
facilities, even if the level of data privacy required in that country is less
than that required by the European Union or other jurisdictions. We endeavor to
protect your data in compliance with all applicable laws. We may engage in
automated decision making, including profiling. Our processing of your personal
information will not result in a decision based solely on automated processing
that significantly affects you unless such a decision is necessary as part of a
contract we have with you, we have your consent, or we are permitted by law to
engage in such automated decision making. If you have questions about our
automated decision making, you may contact us as set forth below.


5. WHEN DO WE SHARE YOUR INFORMATION?


TO OBEY THE LAW OR PROTECT RIGHTS

If we believe the release of information about you is necessary under any
applicable law, rule or regulation to respond to legal process, to investigate
or remedy potential violations of our policies or fraudulent activities, or when
we believe in good faith that disclosure is necessary to protect our rights,
property, and safety, we may share your information, including exchanging
information with other entities for fraud protection and credit risk reduction.


WITH SERVICE PROVIDERS TO SUPPORT NECESSARY BUSINESS ACTIVITIES

We may share your personal information with third parties necessary to provide
you with services you have requested, such as our hosting services, identity
verification services (including Know Your Consumer (KYC) verification
information), email service, analytics, customer service, parcel delivery
service, event or campaign management providers. These parties are authorized to
use your personal data only as necessary to provide these services to us or on
our behalf.


WITH OUR ADVERTISING PARTNERS

We may also share your personal information with third-party advertising
partners. These third-party advertising partners may set Technologies and other
tracking tools on our Services to collect information regarding your activities
and your device (e.g., your IP address, cookie identifiers, page(s) visited,
location, time of day). These advertising partners may use this information (and
similar information collected from other services) for purposes of delivering
personalized advertisements to you when you visit digital properties within
their networks. This practice is commonly referred to as “interest-based
advertising” or “personalized advertising.”

We may also partner with other companies that offer products or services related
to ours or that host or sponsor related events. In such instances, we may share
your information with these business partners if you provide your personal
information to event sponsors at their booths or presentations.


WITH THIRD PARTY PROCESSORS

Our carefully selected partners and service providers may process personal
information about you on our behalf. We periodically appoint digital marketing
agents to conduct marketing activity on our behalf, such activity may result in
the compliant processing of personal information.

Our appointed data processors include:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact
Sopro and view their privacy policy here: http://sopro.io. Sopro are registered
with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:
dpo@sopro.io.”


IF YOU CHOOSE TO SHARE IT WITH OTHER USERS

Our Services offer publicly accessible blogs or community forums. You should be
aware that any information you provide in these areas may be read, collected,
and used by others who access them. To request removal of your personal
information from our blog or community forum, contact us at dpo@permission.io.

We also provide certain social media features on our Services, such as the
Facebook Like button and widgets, such as the “Share This” button or other
interactive mini-programs that run on our Services. These features may collect
your IP address, which page you are visiting on our websites, and may set a
cookie to enable the feature to function properly. Social media features and
widgets are either hosted by a third party or hosted directly on our Services.
Your interactions with these features are governed by the privacy policy of the
company providing the feature.

Additionally, for certain features on our websites, specifically those for
applying to a job opening at Permission, you may use sign-in services such as
LinkedIn or other OpenID providers.

Services like LinkedIn may give you the option to post information about your
activities on our Services to your profile page to share with others within your
network.

Note: Permission does not endorse or make any representations about third-party
websites. We encourage you to carefully read the privacy policy of any website
you visit.


IN THE EVENT OF A MERGER OR ACQUISITION

If Permission is involved in a merger, acquisition, financing due diligence,
reorganization, bankruptcy, receivership, purchase or sale of assets, or
transition of service to another provider, your information may be shared with
the successor entity or third party. Where required by law, you will be notified
by email and/or a prominent notice on our Services of any change in ownership or
uses of your personal data, as well as any choices you may have regarding your
personal data.


6. THIRD-PARTY SITES

Our Services may contain links to third-party websites and applications of
interest, including advertisements, affiliate links and external services, that
may or may not be connected with us. Additionally, some of our Services may use
framing techniques to serve content to or from our partners while preserving the
look and feel of our Services. Once you have used these links, any information
you provide to these third parties is not covered by this Privacy Policy, and we
cannot guarantee the safety and privacy of your information. Before visiting and
providing any information to any third-party websites, we encourage you to
inform yourself of the privacy policies and practices (if any) of the third
party responsible for that website. You should take those steps necessary to
protect the privacy of your information as you see fit. We are not responsible
for the content or privacy and security practices and policies of any third
parties, including other websites, services or applications that may be linked
to or from the Services.


7. WHAT ARE MY RIGHTS WITH RESPECT TO MY PERSONAL DATA?

We recognize that you have certain rights related to your personal data. We feel
that your privacy and ability to preserve and exercise your rights is very
important. You are encouraged to review and understand these rights as they
pertain to you and your personal data.


EXERCISING YOUR RIGHTS

Depending on where you live and the law of your jurisdiction, you may be able to
exercise certain of the following privacy rights related to your personal
information. You can make privacy rights requests relating to your personal
information by logging into your account and going to the Privacy section or by
contacting us as provided in “How Can You Contact Us About This Policy.”

 * * * Right to Access and Portability: You may request personal information
       about you, including: (i) confirming whether we are processing your
       personal information; (ii) obtaining access to or a copy of your personal
       information; and (iii) receiving an electronic copy of personal
       information that you have provided to us, or asking us to send that
       information to another company;
     * Right to Rectification: You may request correction of your personal
       information where it is inaccurate or incomplete. In some cases, we may
       provide self-service tools that enable you to update your personal
       information;
     * Right to Deletion/Erasure: You may request to erase your personal
       information, subject to applicable law. If you close your account, we
       will retain or delete information associated with your account as
       described in the section, “How Long Do We Keep Your Data”;
     * Right to Restrict or Object to Processing of your Personal Information:
       You may have the right to restrict or object to us using or transferring
       your personal information based on our legitimate interests, in the
       public interest, or for direct marketing, including the processing (a) of
       your sensitive personal information for certain purposes; (a) for
       cross-contextual or targeted advertising in some circumstances, and (c)
       profiling in furtherance of decisions that produce legal or similarly
       significant effects concerning you. We may continue to process your
       personal information where permitted or required by applicable law. You
       can opt-out of receiving marketing communications from through your
       account settings or by submitting a request by contacting us at
       support@permission.io;
     * Right to Withdraw your Consent to our processing of your personal
       information;
     * Right to Non-Discrimination: We will not discriminate against you for
       exercising any of your rights provided to you under law;
     * Right to Lodge a Complaint:
       * If you reside in the EEA, Switzerland, or the UK, you have the right to
         lodge a complaint about our practices with respect to your personal
         information with the supervisory authority of your country or state. In
         the UK, the relevant data protection authority is the Information
         Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,
         SK9 5AF, +44 (0303) 123 1113, email: casework@ico.org.uk. In Ireland,
         the relevant data protection authority is the Data Protection
         Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353
         017650100 / + 353 1800437737, email: info@dataprotection.ie or by using
         the following online form: Forms for Data Protection.
       * If you reside in Australia or the Philippines, you may lodge a
         complaint about our practices with respect to your personal information
         with the supervisory authority of your country. In Australia, the
         relevant data protection authority is the Office of the Australian
         Information Commissioner, and complaints may be made through their
         website at www.oaic.gov.au. In the Philippines, the relevant data
         protection authority is the National Privacy Commission, email:
         complaints@privacy.gov.ph.

In support of these rights, upon request and subject to applicable law,
Permission will provide you with information about whether we hold any of your
personal data if you contact us as provided below in “How Can You Contact Us
About This Policy.” You may update, correct, or delete information about you at
any time by logging into your account and updating your preferences. By updating
your preferences, you may opt-out of Permission’s collection of your personal
data. To opt-out of the sharing of your personal information with LiveRamp,
please click here.

Note that to protect your privacy and security, we may take steps to verify your
identity before complying with your request and we may decline your request if
we are unable to verify your identity.


LIMIT MARKETING

If you have any questions about our marketing practices or if you would like to
opt out of the use of your personal information for marketing purposes, you may
contact us at any time as set forth in “Contact Us” below.


COOKIES AND PERSONALIZED ADVERTISING

You may stop or restrict the placement of cookies on your device or remove them
by adjusting your preferences as your browser or device permits, click Manage
Settings to manage your preferences. However, if you adjust your preferences,
our Services may not work properly. You may manage your cookie preferences for
our Services by visiting the Cookie Preference Manager here. Please note that
cookie-based opt-outs are not effective on mobile applications. However, you may
opt-out of personalized advertisements on some mobile applications by following
the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt
out of receiving targeted ads from data partners and other advertising partners
that participate in self-regulatory programs. You can access these and learn
more about targeted advertising and consumer choice and privacy by visiting the
Network Advertising Initiative, the Digital Advertising Alliance, the European
Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.


CHANGING YOUR ACCOUNT INFORMATION

If you would at any time like to review or change the information in your
account or terminate your account, you can do so by logging into your account
settings and updating your user account. Upon your request to terminate your
account, we will deactivate or delete your account and information from our
active databases. However, some information may be retained in our files to
prevent fraud, troubleshoot problems, assist with any investigations, comply
with legal requirements and/or enforce our Terms of Use. Note: We will retain
and use your information, including cached or archived copies, as necessary to
comply with our legal obligations, resolve disputes, and enforce our agreements.
If you have become aware that an account has been created about you without your
knowledge or consent, you may contact us at dpo@permission.io to request
deletion of that account.

For your protection, we may only implement requests with respect to the personal
information associated with the particular email address that you use to send us
your request, and we may need to verify your identity before implementing your
request, such as by asking you to provide information you used to create your
account, or by asking you questions about your use of our Services. We will
process all requests in accordance with applicable law.


OPTING OUT OF EMAILS

To opt out of newsletters and/or email marketing from us, you may indicate your
preference by following the unsubscribe instructions provided in the newsletter,
or by changing your preferences within your account settings. Please note that
we may still send you notices of any updates to our Terms of Use or Privacy
Policy where permitted by law.


DO-NOT TRACK SIGNALS

Many web browsers and some mobile operating systems include a Do-Not-Track
(“DNT”) feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected.
We do not currently respond to DNT browser signals.


8. HOW DOES PERMISSION PROTECT MY INFORMATION?

Permission takes reasonable administrative, technical and physical security
measures to help protect your personal data from loss, theft, misuse and
unauthorized access, disclosure, alteration and destruction. We follow generally
accepted standards to protect the personal data submitted to us, both during
transmission and once it is received, taking into account the nature of such
data and the risks involved in processing, and comply with applicable laws and
regulations.

While we have taken reasonable steps to secure the personal data you provide to
us, please be aware that no security measures are perfect or impenetrable, and
no method of data transmission can be guaranteed against any interception or
other type of misuse. Any information disclosed online is vulnerable to
interception and misuse by unauthorized parties. Therefore, we cannot guarantee
complete security if you provide personal data via our Services.

If you have any questions about security or any reason to believe that your
interaction with us is no longer secure (for example, if you feel that the
security of your account has been compromised), please contact us at
security@permission.io.


9. POLICY FOR MINORS

We do not knowingly solicit information from or market to children under the age
of thirteen (13). By using the Services, you represent that you are at least 13
or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from
users less than 13 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from our
records, except where we are required to retain it under applicable law. If you
are a parent or guardian and believe we have collected from your child under age
13, please contact us with the information below.

Our Services and products are not intended for, nor designed to attract
individuals under the age of thirteen (13). Permission does not knowingly
collect personally identifiable information from any person under the age of
thirteen (13).


10. SUPPLEMENTAL STATE PRIVACY NOTICE

This Supplemental State Privacy Notice only applies to our processing of
personal information under applicable laws in certain states. The following
table describes what categories of personal information Permission has collected
and whether Permission disclosed that personal information for a business
purpose (e.g., to a service provider) in the preceding 12 months.

Category of Personal Information Collected for a Business Purpose Category of
Third Parties that Personal Information is Disclosed to for a Business Purpose
Identifiers



A real name, alias, postal address, unique personal identifier, age, marital
status, sex (including gender), national origin, online identifier, device
model, device type, device vendor, OS Version, browser, browser version,
Internet Protocol address, email address, account name, or other similar
identifiers.

• Advertising networks
• Data analytics providers
• Consumer data resellers
• Third-party websites or applications (e.g., wallet providers; third-party
identity verification services)
• Service providers Sensitive Personal Information



Driver’s license numbers, state identification card numbers, passport numbers,
account access credentials such as usernames, account numbers, or card numbers
combined with the access/security code or password, precise geolocation, racial
or ethnic origin, religious or philosophical belief, mail, email, or text
message contents, unique identifying biometric information, health, sex life, or
sexual orientation information.

• Third-party websites or applications (e.g., wallet providers; third-party
identity verification services) Personal Information Categories Listed in the
California Customer Records Statute
A name, signature, physical characteristics or description, address, telephone
number, driver’s license or state identification card number, credit card
number, debit card number, or any other financial information. • Advertising
networks
• Data analytics providers
• Consumer data resellers (not including SSN)
• Third-party websites or applications (e.g., wallet providers; third-party
identity verification services)
• Service providers Protected Classification Characteristics Under Applicable
State or Federal Law
Age, national origin, marital status, sex (including gender). • Advertising
networks
• Data analytics providers
• Consumer data resellers
• Service providers Commercial Information
Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. •
Advertising networks
• Data analytics providers
• Consumer data resellers
• Service providers Biometric Information
Physiological or biological characteristics that can be used to establish
individual identity, such as the user’s face, from which an identifier template
such as a faceprint, can be extracted. Third-party websites or applications
(e.g., wallet providers; third-party identity verification services)
Internet or other electronic network activity Internet or Other Electronic
Network Activity
Browsing history, search history, information on a consumer’s interaction with
an internet website, application, or advertisement. • Advertising networks
• Data analytics providers
• Consumer data resellers
• Service providers Inferences Drawn from Other Personal Information to Create a
Profile About a Consumer



Profile reflecting a consumer’s preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes.

• Advertising networks
• Data analytics providers
• Consumer data resellers
• Service providers

The categories of sources from which we collect personal information and our
business and commercial purposes for using personal information are set forth in
“Personal Data We Collect” and “How do we use your Information?” above,
respectively.

Although we may allow other third-party advertising partners to use cookies and
similar Technologies to collect your information for interest-based advertising
purposes (as described above in “When do we share your information?”),
Permission only shares the personal information you provide to us for valuable
consideration when you affirmatively authorize us to do so by opting into the
Services, in order to obtain ASK tokens. Therefore, Permission does not “sell”
personal information for purposes of state law, nor do we have actual knowledge
of any “sale” of personal information of minors under 16 years of age. To the
extent that such sharing is considered a “sale” or “sharing” under California
law or “targeted advertising” under state laws that provide the right to opt-out
of such sharing, you may limit such sharing by following the instructions found
above in the section titled “What are My Rights with Respect To My Personal
Data?” or by contacting us as set forth in “Contact Us” below.

California Civil Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California
resident and would like to make such a request, please submit your request in
writing to us using the contact information provided below.

California Notice of Financial Incentive: Our program provides you with ASK
tokens when you agree to use our Services in a way that allows us to directly
identify you and use information about your preferences to provide advertising
and other Services to you. The personal information we collect is as described
above in the section titled, “Personal Data We Collect.” We have established the
financial incentive amount, in part, based on the value to a Permission Ads
Customer when initiating an ad campaign. You can determine the number of ASK
tokens earned for a specific activity by reviewing the offer associated with an
activity or by reviewing the transaction history in your wallet. The number of
ASK tokens, and therefore the value of the incentive for certain activities,
including sharing personal information, varies based on the type of activity and
a variety of factors. These factors include token velocity, the specific
ASK-rewarded campaign you interact with, and advertiser participation. These
factors are subject to change at Permission’s sole discretion.

You will have the opportunity to “opt in” to the program and will always be
provided an opportunity to revoke consent or to “opt out” of further collection,
use, or dissemination of personal information. You may opt-out of the program or
update, correct, or delete information about you at any time by logging into
your account and updating your preferences or by contacting us as set forth in
“How Can You Contact Us About This Policy” below.


SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you can exercise your right to opt-out of the
sale of certain Personal Information to third parties who intend to license or
sell that Personal Information by contacting us at dpo@permission.io with the
subject line “Nevada Do Not Sell Request” and providing us with your name and
the email address associated with your account. Please note that we do not
currently sell your Personal Information as sales are defined in Nevada Revised
Statutes Chapter 603A. To the extent that you receive monetary consideration for
disclosing your data, it is only in the context in which you provide the
information to the operator for the purpose of receiving ASK token rewards. If
you have any questions, please contact us as set forth below.

Residents of certain states have the right not to receive discriminatory
treatment by us for the exercise of their rights conferred by applicable law.
Only you, or someone legally authorized to act on your behalf, may make a
verifiable consumer request related to your personal information. You may also
make a verifiable consumer request on behalf of your minor child. To designate
an authorized agent, please contact us as set forth in “How Can You Contact Us
About This Policy” below and provide written authorization signed by you and
your designated agent. To protect your privacy, we will take commercially
reasonable steps to verify your identity before fulfilling your request. When
you make a request, we will ask you to provide sufficient information that
allows us to reasonably verify you are the person about whom we collected
personal information or an authorized representative, which may include asking
you to answer questions regarding your account and use of our Services. We are
not obligated to effectuate a consumer request if we cannot verify that the
consumer making the request is the consumer about whom Permission has collected
information or is a person authorized by the consumer to act on such consumer’s
behalf.

This Privacy Policy uses industry-standard technologies and was developed in
line with the World Wide Web Consortium’s Web Content Accessibility Guidelines,
version 2.1. If you wish to print this policy, please do so from your web
browser or by saving the page as a PDF.


11. NOTICE TO ALL NON-US RESIDENTS

Our servers are located in the US. If you are located outside of the US, please
be aware that any information provided to us, including personal information,
may be transferred from your country of origin to the US. We endeavor to protect
all personal information consistent with the requirements of applicable laws.


12. CHANGES TO THIS POLICY

If we make material changes, we will notify you by revising the date at the top
of the Policy, and where required by law, we may provide you with more prominent
notice (such as adding a statement to our homepage or sending you an email
notification).

We encourage you to review the Policy whenever you access the Services to stay
informed about our information practices and the ways you can help protect your
privacy.


13. HOW CAN YOU CONTACT US ABOUT THIS POLICY

If you have questions or comments about this policy, you may contact our Data
Protection Officer (DPO) at dpo@permission.io or via mail at 888 Prospect
Street, Suite 200, La Jolla, CA 92037.

 

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which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

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These cookies allow us to count visits and traffic sources so we can measure and
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information these cookies collect is aggregated and therefore anonymous. If you
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These cookies may be set through our site by our advertising partners. They may
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These cookies enable the website to provide enhanced functionality and
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