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Last Updated: April 3, 2024

This Privacy Policy applies to Particle Media, Inc. (“NewsBreak”, “We,” “Us,” or
“Our”) and describes the collection, use, disclosure, and protection of
information gathered through the NewsBreak network of Websites, including
newsbreak.com, newsbreakapp.com, email newsletters distributed by us
(hereinafter “Web sites” or “Sites”), NewsBreak mobile applications (hereinafter
“Apps”), and other products or services owned or operated by NewsBreak (together
hereinafter “Services”). NewsBreak is committed to protecting the
confidentiality and security of information it collects through its Services.
Please read the following carefully. Your use of our Services is governed by
this Privacy Policy and NewsBreak’s Terms of Use (available here:
https://www.newsbreak.com/terms). Our Privacy Policy and Terms of Use do not
apply to any third-party websites, services or applications, even if they are
accessible through our Services.

By using our Services, you are accepting the practices described in our Privacy
Policy. If you do not agree to the terms of this Privacy Policy, please do not
use the Services.

* Revisions to this Privacy Policy. Any information that is collected via our
Services is covered by the Privacy Policy in effect at the time such
information is collected. We may revise this Privacy Policy from time to
time. If we make any material changes to this Privacy Policy, we’ll notify
you of these changes, for example by posting them on the Services or
providing email or other notice, and we’ll update the “Last Updated” date at
the top of the Privacy Policy to indicate when those changes will become
effective. You understand and agree that you will be deemed to have accepted
the updated Privacy Policy if you use the Services after the updated Privacy
Policy is posted on the Services.
* Information We Collect.

* Device Related Information. We collect information about the devices you
access to our Services, such as IP address, device ID, cookies, user settings
and preferences, operating system, app and file names and types, app version
and other information permitted by Android or iOS based on their policies and
your settings.

* Location Information. We may collect general location information about your
device that you volunteer or enable through the App or your device. We do not
collect precise location information.
* Usage Information. We collect information about how you use our Services,
such as the type of content you view, and the time, frequency and duration of
your activities, advertisement interactions and other usage information and
performance data related to the Services and usage of them.

* Information You Provide When Sign-In. If you register for an account with us,
you provide us your account name, email address, password. You might choose
to provide your birth year or gender. You may also be able to register using
your user credentials to certain social media sites, such as Facebook, Google
or Apple (“Social Networks”), and when you do, Social Networks might share
with us your account name, email address, profile image or other information
based on their policies and your settings. We may collect your contact list
upon obtaining your consent.

* Information You Provide as a One-Time Request. You may provide us with
certain information when you submit a request or claim on our Apps or to us.

* Surveys. We may contact you to participate in surveys. If you decide to
participate, you may be asked to provide certain information about you.

* Information You Provide When Posting Content. You may provide us with the
content you create, like posts, comments, audio, or video, and the content
you provide through our camera feature or your camera roll settings with your
permission.

* Information You Provide When You are Our Business Partners. You may provide
your business name, legal name, email, phone number and other business
contact information.
* Information You Provide When you are Content Provider. You may provide
publication name, legal name, email phone number, occupation, publication
description, publication profile picture, publication coverage area, blog
website, and social media links.

* Cookies. Like most websites, we use cookies and similar technology to collect
information about Site usage by all of our visitors and to help us remember
you and your preferences when you revisit the Site. These cookies may stay on
your browser into the future until they expire or you delete them. Further
general information about cookies and how they work is available at
www.allaboutcookies.org. We may allow selected third parties to place cookies
or tracking pixels through the Site for analytics or advertising purposes on
our or other sites, apps, or social media and they may collect information
about your online activities or device related information over time and
across different websites when you use our Sites. We do not use technology
that recognizes a “do-not-track” signal from your web browser.

3. How We Use Your Information. Our primary purposes for the collection and
processing of information are to provide our Services (to perform our
contract with you), to improve our Services, to administer your use of the
Services, to market the Services to you, and to enable you to enjoy and
easily navigate our Services. Also, we may process your information where we
have a legitimate interest (e.g., fraud prevention, network and information
security, research (including marketing research), and direct marketing),
and as you otherwise consent.

We will use your information in one or more of the following ways:

Performing Services for You:

3. As necessary for the Web sites or Apps to function or provide you with
Services properly;

4. Improve user experience;

5. Perform statistical, demographic, and marketing analyses of users of the
App;

6. Communicate with you about your questions, claims or technical support; and

7. Communicate with you about changes to our policies, and send you information
about features and enhancements on our Sites and Apps.

Advertising Customization and Measurement; Marketing:

* Personalize content and experiences on our Services, including providing you
reports, recommendations, ads and feedback based on your preferences, and
measuring and analyzing that advertising (e.g., which advertising is more
effective or engaging);
* Marketing to you regarding products and services we believe might interest
you; and

* Send invitation to the connections in your contact list.

Internal Research and Development; Quality Control:

* In the aggregate to help us evaluate and modify existing Services and to help
us develop additional services that are likely to be of interest to our
users;
* Optimize or improve our products, services and operations; and

* To monitor quality control and ensure compliance with our legal obligations,
codes and ordinances, policies and procedures.

Security Detection, Protection and Enforcement; Functionality Debugging, Error
Repair:

* Detect, investigate, and prevent activities that may violate our policies,
including our content policies and all applicable terms for our Services, or
be illegal;
* Recognize repeat visitors and facilitate ongoing access to the Services; and

* Verify your or your authorized agent’s identity.

Other uses about which we notify you.

4. Information We Share with Third Parties. We will not share any information
that we have collected from or regarding you without your consent except
for the purposes described in “How We Use Your Information” and as
described below:
5. Advertising and Marketing Partners. We may use our advertising partners’
software development kits (“SDKs”). Our Advertising Partners can access
your information through the SDKs so that they can decide whether to bid on
ad inventory or serve an advertisement and choose the best ad for you on
the Services. We may provide your online activities or device related
information to our marketing partners to promote our products and services
to you.

6. Affiliates and Service Providers. Our affiliates and service providers are
necessary to provide our Services. We may share the information we collect
with our affiliates or service providers who may process the information in
their facilities subject to obligations consistent with this Privacy Policy
and any other appropriate confidentiality and security measures.

7. Content Providers. When you follow a content provider, the content provider
can access your account name, general location, profile picture if you
sign-in through a Social Network.

8. Content You Create/General Location. Your username, general location, the
content you like, and the content you create, such as your posts, comments,
or video, are available to the public. You can exclude your general
location from the public comments in your settings.

9. Legal Obligations. We cooperate with government and law enforcement
officials or private parties to enforce and comply with applicable laws and
regulations.

10. Third-Party Video Player. We provide the capability for content publishers
to integrate their video players on our Services, allowing you to access
their video content. Additionally, we may embed third-party video players,
such as YouTube, for certain videos. When you activate a video through a
third-party video player, they may collect your user information. Their use
of your information will be governed by their privacy policy. We do not
receive this information.

5. Your Choices. You may have the right to opt out of certain uses of your
information:
6. Opt-out of Email Communications. We may periodically send you free
newsletters and emails that directly promote our Services. When you receive
such promotional communications from us, you will have the opportunity to
“opt-out” (either through the App (if applicable) or by following the
unsubscribe instructions provided in the email you receive). We do need to
send you certain important communications regarding the Services, and you
will not be able to opt out of those communications.

7. Opt-out of Ad Tracking. You may opt-out of certain targeted advertising
from participating entities by visiting http://optout.aboutads.info/#/ or
http://optout.networkadvertising.org/# on each of your devices and
browsers. If you change or upgrade your browser or device, or delete your
cookies, you may need to use these opt-out tools again. Some
Cookie-management solutions also rely on Cookies, so please adjust your
browser Cookie settings carefully. We do not maintain or control the
opt-out mechanisms and settings below and are not responsible for their
operation. Your mobile device may also include settings that allow you to
manage the use of cookies, such as Limit Ad Tracking or Tracking settings
in iOS and Opt out of Ads Personalization in Android. You may also visit or
download and use the AppChoices app at http://www.aboutads.info/appchoices
on each of your devices.

Please note that, if you change or upgrade your device you may need to use
these opt-out tools again. Please review the instructions and information
at the links above carefully for more information about how these tools
work. We do not maintain or control the opt-out mechanisms and settings and
are not responsible for their operation.

8. More Opt-out on Mobile Apps. You have choices when it comes to how Apps
function on your mobile device. Access to or availability of controls may
vary depending on your device. You may be able to:

9. Manage push notifications by using your built-in mobile device settings and
controls;

10. Manage location information by using your built-in mobile device settings
and controls;

11. Manage/restrict in-app purchases by using your built-in mobile device
settings and controls; or

12. Block navigation to the web by turning off network access on the device or
turning off the browser.

13. Reject Cookies. You may Reject Cookies by selecting that option on the
banner that appears when you visit the Site. This will tell us not to set
any cookies on your browser except for cookies that are strictly necessary
to operate our Site and a single preference cookie that tells us you do not
want cookies to be set. When you make this selection some Site features
may not be available or may not function.

6. Notice to California Residents Regarding “Shine the Light” Rights.
California’s “Shine the Light” law (Cal. Civil Code section 1798.83) gives
residents of California the right under certain circumstances to request
information from us regarding the manner in which we share certain
categories of personal information (as defined by applicable California
law) with third parties for their direct marketing purposes, or to permit
such residents to “opt out” of such sharing. We do not share your personal
information with third parties for their own direct marketing purposes.
7. NOTICE TO RESIDENTS OF CALIFORNIA, COLORADO, VIRGINIA AND UTAH

If you are a California, Colorado, Connecticut, Virginia or Utah Consumer,
laws in those states require us to provide you with some additional
information regarding how we collect, use, and share your “personal
information” as defined in the California Consumer Privacy Act of 2018/
Privacy Rights Act, the Colorado Privacy Act, the Connecticut Personal Data
Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data
Protection Act (collectively the Privacy Laws).

California defines a ‘Consumer’ as any resident of the state regardless of
the capacity in which they interact with us.

Our California employees (current, former or applicants) can learn about
our information collection and disclosure practices and how to exercise
their CPRA rights by contacting the Director of Human Resources. This
Privacy Policy does not include disclosures about employee information that
we collect, use, retain and disclose.
‍
Colorado, Connecticut, Virginia and Utah define a ‘Consumer’ as a resident
of the state who is acting in an individual or household capacity, but this
excludes state residents who are acting in an employment capacity (as one
of our current, former or prospective employees) or in a commercial
capacity (as an employee, owner, director, officer, etc. of an entity
communicating with us in that context). As a result, if you reside in one
of these states and have interacted with us in an employment or commercial
capacity you are not provided the rights described below by the Privacy
Laws.

Categories of personal information we collect. Throughout this Privacy
Policy, we discuss in detail the specific pieces of personal information we
collect from and about users. Under the Privacy Laws, we are also required
to provide you with the “categories” of personal information we collect.
The categories we collect are: identifiers (such as contact information
(your name, address, phone number, email or postal address) and unique
personal identifiers (that may include but are not limited to your legal
name or preferred alias and online identifiers like user account names);
commercial information (such as transaction data and billing information);
internet or other network or device activity (such as browsing history or
Services usage); geolocation information; employment, education and
professional related information(collected about vendors and business
partners); sensitive personal information (collected about vendors and
business partners); or geolocation (of consenting users); inferences we
make about you or your interests based on analysis of other information we
have collected; and other information that identifies or can be reasonably
associated with you.

How we use these categories of personal information. We and our service
providers may use and disclose the categories of personal information we
collect from and about you for the following business and commercial
purposes (as those terms are defined in applicable law:
8. Performing services for you;
9. Advertising customization and measurement;
10. Marketing to you regarding products and services we believe might interest
you;
11. Research and development;
12. Improving our Services;
13. Detecting, protecting against, and prosecuting violations of our terms and
policies, security incidents, and fraudulent or illegal activity;
14. Managing and overseeing our staffing needs (current, former and applicants)
and our vendors;
15. Other uses about which we notify you.

Examples of these types of uses are discussed in the “How We Use Your
Information” section in our main Privacy Policy above. We may also use the
categories of personal information for compliance with applicable laws and
regulations, and we may combine the information we collect (“aggregate”) or
remove pieces of information (“de-identify”) to limit or prevent
identification of any particular user or device.

Processing Sensitive Personal Information. Sensitive Personal Information
includes Social Security, driver’s license, or passport numbers; account
log-in; financial account information with required access codes or
passwords; racial, ethnicity, religious or philosophical beliefs; precise
location (within 1850 feet); union membership; genetic or biometric
information; gender or sexual orientation; and health information. We
collect limited information in this category and process and disclose
Sensitive Personal Information for the purposes permitted by Privacy Laws
and as disclosed above or at the time we collect this information unless
otherwise required by law. The following are permitted purposes under the
Privacy Laws:

Processing Precise Geolocation. When you consent, we process this
information to provide relevant content and advertisement based on your
location. You can always withdraw your consent.
16. To perform the services or provide the goods reasonably expected by an
average consumer who requests those goods or services.
17. To prevent, detect, and investigate security incidents that compromise the
availability, authenticity, integrity, or confidentiality of stored or
transmitted personal information.
18. To resist malicious, deceptive, fraudulent, or illegal actions directed at
the business and to prosecute those responsible for those actions.
19. To ensure the physical safety of natural persons.
20. For short-term, transient use, including, but not limited to,
nonpersonalized advertising shown as part of a consumer’s current
interaction with the business, provided that the personal information is
not disclosed to another third party and is not used to build a profile
about the consumer or otherwise alter the consumer’s experience outside the
current interaction with the business.
21. To perform services on behalf of our business.
22. To verify or maintain the quality or safety of products or services that we
own or control, and to improve, upgrade, or enhance such products or
services.
23. To collect or process sensitive personal information where such collection
or processing is not for the purpose of inferring characteristics about a
consumer.
24. Processing Precise Geolocation. When you consent, we process this
information to provide relevant content and advertisement based on your
location. You can always withdraw your consent.

California, Colorado, Connecticut, Virginia and Utah Privacy Rights

If you are a California, Colorado, Connecticut, Virginia or Utah Consumer, you
have the following rights:

1. Access Rights. The right to request and receive up to twice in as 12 month
period disclosure of:
2. our information collection practices - the categories of personal
information we collect, the categories of sources of such information, our
business purpose for collecting or sharing such information, the categories
of third parties with whom we share such information;

3. our information sharing practices - a list of the categories of personal
information sold with the category of third party recipients and a list of
the categories of personal information that we disclosed for a business
purpose;

4. the personal information we have collected about them during the prior 12
months, or at their option, since January 1, 2022.

2. Deletion Rights. The right to request that we delete (and direct our service
providers to delete) their personal information subject to certain
exceptions.
3. Correction Rights. The right to request that we correct information that we
hold which is inaccurate.
4. Opt-Out Rights. Do Not Sell My Personal
5. Do Not Sell My Personal Information. The right to request that we not sell
personal information about them;

6. Do Not Share My Personal Information. The right to request that we not share
personal information for cross-context or behavioral marketing purposes;

7. Limit Processing of Sensitive Personal Information. The right to request
that we do not process Sensitive Personal Information for any purpose other
than the purpose for which we originally collected it as disclosed in this
Privacy Policy or before it is collected.

Colorado, Connecticut, Virginia, and Utah Consumers also have the right to
direct us not to engage in profiling using their personal information. Profiling
is any automated processing of personal information that is used to evaluate,
analyze or predict personal aspects related to your economic situation, health,
personal preferences, interest, etc.
‍
We will not discriminate against you as a result of your exercise of any of
these rights.
To exercise these rights, you can choose to:

To exercise your Access, Deletion or Correction rights, please send an email to
privacy@newsbreak.com with a subject of “Privacy Law Request”.

In order to protect your information, we may need to verify your identity (that
you are the person about whom we collected personal information) before
processing your request. In some cases we may need to collect additional
information to verify your identity, such as a government issued ID. We will
acknowledge receipt of your request within 10 days and respond within 45 days;
if we need additional time (up to 45 additional days) we will notify you.

We cannot respond to your request or provide you with personal information if we
cannot verify your identity and confirm that the personal information relates to
you. Please understand due to very limited personal information we received, we
might not be able to verify your identity and process your request.

To exercise your rights to Opt Out of having your personal information “sold” or
shared for cross-context behavioral marketing purposes you can follow the
instructions on our Do Not Sell or Share My Personal Information form, or email
us at privacy@newsbreak.com with a subject of “Privacy Law Request”.

You do not need to opt out or tell us to limit processing of Sensitive Personal
Information. We only process and disclose Sensitive Personal Information for the
purposes permitted by Privacy Laws and for which we originally collected it as
disclosed in this Privacy Policy or at the time we collect it unless otherwise
required by law.
‍
You may also opt out by activating a user-enabled global privacy control, such
as a browser plug-in or privacy setting, device setting, or other mechanism,
that communicates or signals your choice to opt-out of the sale and sharing of
personal information. When we receive such a signal we will stop setting third
party, analytics, or advertising partner cookies on your browser. This will
prevent the sale or sharing of information relating to that specific device
through cookies to our advertising or analytics partners. This option does not
stop all sales or sharing of your information because we cannot match your
device’s identification or internet protocol address with your personally
identifiable information like your name, phone number, email address or ZIP
Code. If you delete cookies on your browser, any prior do not sell or do not
share signal is also deleted and you should make sure that your user-enabled
setting is always activated.

Under the Privacy Laws you can also designate an authorized agent to exercise
your rights on your behalf. We may request that your authorized agent have
written permission from you to make requests on your behalf and may need to
verify your authorized agent’s identity.

If we have denied your Consumer request you have the ability to file an appeal
with us. To file an appeal with us, please send an email to
privacy@newsbreak.com with a subject of “CPRA/VCDPA Request”.

We will respond to you in writing within 45 days explaining the reasons for our
decisions. If we deny your appeal Colorado, Connecticut. Virginia, and Utah
Consumers can contact your state Attorney General at:

Colorado residents:
Office of the Attorney General
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000

Connecticut residents:
Office of the Attorney General
165 Capitol Avenue
Hartford, CT 06106
860-808-5318
‍
Virginia residents:
Office of the Attorney General
202 North Ninth Street
Richmond, Virginia 23219
(804)786-2071

Utah residents:
Utah State Capitol Office Mailing Address
Office of the Attorney General
PO Box 142320
Salt Lake City, UT 84114-2320
General Office Number:
1-801-366-0260

California Residents (Not Applicable)

Information Collected, Sources, Business Purposes for Collection, Disclosures

During the past 12 months we may have collected the following categories of
personal information. This includes information that you provide to us directly,
information we collect from you automatically, information that we collect when
you interact with us such as through your online postings, and information that
we may collect from third parties such as service providers, affiliated
companies, marketing or data partners, or other third parties with whom you
interact. It also includes information that we collect about business partners
and vendors from those individuals directly or from references or referrals. Not
all information is collected from everyone who interacts with us. We use the
information collected for our general commercial use as detailed above.

* Site user information: Identifier information (profile name, device
identification information) and electronic network activity information (IP
Address and interactions with our Site) are collected directly from Site
users.
* Content Provider Information (Individuals): Identifier information (name,
profile name, device identification information, email address), content
posted (comments, audio, video), general location information, and electronic
network activity information IP address and interactions with our Site) are
collected directly from individuals posting content to the Site. We also
collect inferences based on content posted.
* Content Provider Information (Business): Identifier information, electronic
network activity information, commercial information (transactions with us),
content posted (audio, video), professional related information, sensitive
information (taxpayer identification, anti-discrimination information used
for legal compliance) are collected from companies that provide content to
us.
* Business Partner Information (Service providers): Identifier information,
commercial information (transactions with us), business address),
professional related information, sensitive information (taxpayer
identification, anti-discrimination information used for legal compliance)
are collected from companies that provide services or products to us.

During the past 12 months we have disclosed the following categories of personal
information to the following types of third parties for a business purpose as
further described in “Information We Share with Third Parties” above.

* Affiliated companies: We may have disclosed identifiers and commercial
information with affiliates for purposes of decision making, reporting,
management, analysis and other business purposes.
* Service providers, publishers and marketing partners: We may have disclosed
information such as identifiers, commercial information, geolocation,
internet or other electronic network activity, and inferences with service
providers, content provider, and marketing partners for purposes of providing
the Services to you, processing payments, legal and accounting services,
advertising and analytics services.
* Other third parties: We may have disclosed any or all categories of
information with governmental authorities, law enforcement or others to
comply with our legal obligations, to enforce our agreements, or to protect
or defend the rights and property of our company or others.

Selling and Sharing Personal Information

We do not sell personal information for monetary consideration but we may
transfer your information to a third party that provides us with services such
as helping us with advertising, data analysis and analytics, and security, which
may fall under the definition of for “other valuable consideration” and which
may therefore be considered a “sale” under the CPRA. During the past 12 months
leading up to the effective date of this Privacy Policy, we “sold” (as that term
is defined under the CPRA), identifiers, commercial information, geolocation,
and internet or other electronic network activity (like a record of a browser’s
visit to our website) to marketing and advertising services to assist with such
activities. We do not “sell” personal information if we have actual knowledge
that the consumer is less than 16 years of age.

“Sharing” your personal information means making it available to a third party
so that they can use it to display targeted or cross-context behavioral
advertisement to you. Cross-context behavioral or targeted advertising means
that we display an advertisement to you that is selected based on personal
information about you that we obtained or inferred over time from your
activities across other companies’ websites, applications or online services
that we use to predict your preferences or interests. Targeted advertising does
not include using your interactions with us or information that you provide to
us to select advertisements to show you. In the preceding twelve (12) months, We
may have shared identifiers, commercial information, geolocation, and internet
or other electronic network activity (like a record of a browser’s visit to our
website) of non-minors for behavioral or cross context or targeted advertising
purposes.

8. Nevada Residents Only. We do not transfer personal information for monetary
consideration. If you would like to tell us not to sell your information in
the future please email us at privacy@newsbreak.com with your name, postal
address, telephone number and email address with “Nevada do not sell” in
the subject line.
9. The Security of Your Information. We take reasonable administrative,
physical and electronic measures designed to protect the information that
we collect from or about you from unauthorized access, use or disclosure.
Please be aware, however, that no method of transmitting information over
the Internet or storing information is completely secure. Accordingly, we
cannot guarantee the security of any information.
10. Data Retention. We retain the information we collect for as long as your
use of our Services or as necessary to fulfill the purpose(s) for which it
was collected, provide our Services, resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes, enforce our
agreements, and comply with applicable laws.
11. Links to Other Sites. Our Services may contain links to websites and
services that are owned or operated by third parties (each, a “Third-party
Service”). Any information that you provide on or to a Third-party Service
or that is collected by a Third-party Service is provided directly to the
owner or operator of the Third-party Service and is subject to the owner’s
or operator’s privacy policy. We’re not responsible for the content,
privacy or security practices and policies of any Third-party Service. To
protect your information we recommend that you carefully review the privacy
policies of all Third-party Services that you access.
12. Data Processing. Our Sites are maintained on AWS servers located in the
U.S., and your information submitted is processed and stored in the U.S..
If you are visiting our Sites from outside the U.S., please be advised that
your information is transferred to the U.S..
13. Our Policy toward People under 13. Our Services are not directed to people
under 13 and we do not knowingly collect information from individuals under
the age of 13. If you are between 13 and 18, you must have permission from
your legal guardian before you are permitted to use the Services. If you
are a parent or legal guardian and think your child under 13 has given us
information, you can email us at privacy@newsbreak.com. You can also write
to us at the address listed at the end of this Privacy Policy.
14. Questions? Please contact us at privacy@newsbreak.com, or 800 W El Camino
Real, Suite 300, Mountain View, CA 94040.

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