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CONVERSANT PRIVACY POLICY

Last Modified: July 9, 2021

INTRODUCTION:

Welcome to the Conversant Privacy Policy (“Privacy Policy”). By visiting our
Privacy Policy, you’ve taken the first step in educating yourself about
advertising businesses such as ours that contribute to the Internet’s ability to
remain largely an ecosystem of free content, as well as to provide a better user
experience for consumers.

At Conversant LLC, or any of its subsidiaries, including Commission Junction
LLC, a Conversant Company (“Conversant,” “we,” “us,” or “our”), we provide
online advertising services. To do this, we follow information usage practices
based on two beliefs: first, that protecting user privacy is essential to the
growth and prosperity of the Internet; second, that a personalized web
experience can provide significant benefits to Internet end users if done
properly. In accordance with these beliefs, Conversant creates results for
advertisers and publishers in revolutionary ways without compromising individual
privacy.

If you have questions or concerns regarding this statement, please contact us by
clicking here.

By visiting any Conversant website or mobile application, or any website or
mobile application of one of its subsidiaries or affiliates (collectively,
“Site” or “Sites”) or sharing any information with us, you agree to be bound by
this Privacy Policy.

Please take some time to read about what our business does, learn how we ensure
that data you share with us is collected and used safely, and visit resources
that provide more depth on our industry.

CONTENTS

1. Short Form Privacy Policy
2. Scope
3. What Conversant Does
4. Privacy by Design
5. Information Collection & Use
6. Self-Regulation & Voluntary Compliance
7. Your Choices
8. Use of the Conversant Sites as a Visitor or Client
9. Contact Us
10. Your Representations
11. Modifications to this Privacy Policy
12. California Resident Privacy Rights

SHORT FORM PRIVACY POLICY

We have included a table summarizing our practices solely for your convenience
and reference purposes. This table is not an exhaustive description of our
privacy practices and should not be construed to define, limit, and/or describe
the scope or extent of this Privacy Policy. As a result, we urge you to read the
entire Privacy Policy. This table may not align with the definitions and privacy
rights under California law, so if you are a California resident, then please
click here.

To start, it is important for you to know two definitions that are key to
understanding our programs and privacy practices:

Personally Identifiable Information (“PII”): Information that can be linked to
an identifiable individual person. This type of data includes things like full
name, home address, telephone number, or email address.

Non-Personally Identifiable Information (“Non-PII”): Information that cannot
identify an individual person, such as IP address, browser types, operating
systems, domain names, access dates and times, referring website addresses,
online transactions and browsing and search activity.

Information Collection: PII

We do not collect PII except as expressly provided for herein. For example, PII
may be collected should a consumer contact Conversant on his/her own initiative,
register with a publisher to download a mobile app, or as part of our lead
generation business.

Information Collection: Non-PII

The Non-PII we collect may include, as an example, IP address, browser types,
operating systems, domain names, platform type, language preference, access
dates and times, referring website addresses, online transactions and browsing
and search activity.

How Information is Used

We may use your Non-PII for purposes such as enhancement of our services,
marketing, and to more effectively match advertisements, applications, and
website content to your interests.

Sharing Your Information

We may share your information with third party service providers with whom we
have contracted, our subsidiaries and affiliates, third party marketing
partners, business partners and our clients and publishers, and as expressly
provided for herein.

Your Choices

You may regulate the collection and use of Non-PII via the opt-out options
provided herein or by uninstalling or electing not to install a web browser or
mobile application.

Security

We use reasonable and appropriate security measures to protect your data.

Retention

We retain online Non-PII for IBA for no more than eighteen (18) months.
Aggregate reports generated from such data may be retained for a longer period,
as ad delivery and reporting data.

Changes

We may change this Privacy Policy at any time by posting the revised Privacy
Policy on the Site along with the date such Privacy Policy was last updated.

If you have any questions about this Privacy Policy, or the practices discussed
herein, please contact us by clicking here.

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SCOPE

This Privacy Policy is primarily intended to provide a description of the ways
in which we collect and use information to deliver advertising across the
Internet. For more on how we handle information collected from clients and
publishers or visitors to our Sites, please see “Use of the Conversant Sites as
a Visitor or Client” below. For more information on your privacy rights as a
California resident, please click here.

This Site is not intended for use by those who are not legal residents of the
United States. Neither the Sites, nor our online activities or services for our
clients, are directed toward or intended for children. We do not collect PII
from any person of whom we have actual knowledge is under the age of 13. By
using our website, the website of any of our publishers in our networks or
submitting information to us, you consent to our use and sharing of the
information collected or submitted as described in this Privacy Policy.

Please be aware that in addition to our Sites, the websites of our clients and
publishers, applications on which we place advertisements and any third party
websites linked to one of our Sites, may also collect information from you for
various purposes, including, but not limited to, providing advertisements about
goods and services likely to be of greater interest to you. Such information
collected by such websites and mobile applications and their affiliated or third
party partners may include Non-PII through the use of cookies and other
technologies. It may also include any PII you choose to provide in registering
and transacting with such websites and mobile applications. Although we choose
our business partners and clients carefully, Conversant is not responsible for
the privacy practices of websites and mobile applications operated by such third
parties. You should check the applicable privacy policies of such websites and
mobile applications you visit to determine how they handle any information they
collect from you.

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WHAT CONVERSANT DOES

While you may only visit certain websites and mobile applications, there are
other companies working behind the scenes to help provide you with a great
digital experience. These third party companies provide vital services such as
analytics, advertising and fraud prevention for retailers, publishers, and other
organizations. These services enable these third party companies to, among other
things, provide the advertising that keeps your favorite blogs free, your
favorite stores in business, and your advertising experience more relevant.

We help companies provide digital advertising on browsers, mobile applications
and televisions, and we do it in a variety of ways, from banner and video ads to
coupon codes. To make some of these things possible, we need to utilize
information to provide smarter decision making. Technologies such as cookies and
mobile device IDs enable companies like ours to provide more relevant
advertising while keeping your identity anonymous to Conversant.

In addition to our advertising services, we also utilize our technology to
provide life-saving messages during tornadoes and AMBER Alerts, geotargeted to
individuals in affected areas. To learn more about these
internationally-recognized programs established by Conversant through an
organization called the Federation for Internet Alerts, click here.

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PRIVACY BY DESIGN

Our philosophy on privacy follows the framework of Privacy by Design. We
integrate privacy in strategy, product development, and more. We set the tone
for privacy protection early and often, proactively working to keep PII out of
Conversant’s systems, and building technologies that are effective without the
use of PII. We can protect consumer privacy AND provide relevant advertising,
which benefits everyone involved, especially advertisers, consumers, and small
business websites and mobile applications. Ensuring the protection of privacy
throughout the entire lifecycle of the data is of the utmost importance, and we
are careful to protect privacy as data is collected, used, and destroyed
responsibly.

We constantly strive to maintain unparalleled visibility with consumers. We
provide transparency and choice through our website, encourage the same practice
throughout the Internet, and utilize AdChoices on each banner advertisement
tailored to consumers’ interests.

Conversant has developed a strong privacy foundation and has a company culture
aimed at the prevention of the receipt and use of PII. We respect consumer
privacy and give consumers the ability to opt out of interest-based
advertising (“IBA”).

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INFORMATION COLLECTION AND USE

Information Collected by Conversant

Conversant only collects Non-PII from you (unless PII is provided by you
voluntarily), and may collect this in a variety of ways. We may use technologies
such as cookies, log files, pixel tags or other similar technologies to collect
Non-PII about the browser or device you are using, including browsing activity,
online transactions, and IP addresses. We may also receive similar Non-PII from
third parties, which may additionally include the types of programming you view
on your television. Some clients contribute PII such as your name, address,
email address, and associated transactional information directly to a third
party with whom Conversant has a contractual relationship. This third party
removes the PII data points and provides Conversant only the Non-PII for our use
in providing advertising to you. All Non-PII received and collected by
Conversant from the various sources may be combined and used to provide you
relevant advertising, and for other purposes as determined by Conversant.

We may also conduct surveys by serving interactive ads that ask you to provide
information such as your gender and age range, which information may be
associated with a device ID or a cookie ID. If you decide to respond, your
demographic information will also be associated with a device ID or cookie ID
and used only for the purposes described in this Privacy Policy.

“Cookies” are files that are stored on your web-enabled device and are used to
improve your experience when seeing web and mobile advertisements. We may use
cookies to estimate the total reach of an advertising campaign, as well as
frequency of display, and to serve advertisements which are relevant to you.
This allows advertisers to determine with greater accuracy the composition of
the audience they reach and attempt to reach an audience that is interested in
their products or services. There are many misconceptions about cookies. Cookies
cannot erase your hard drive, install programs, or collect PII from your browser
or device.

“Local Storage Data” are similar to cookies in that they allow data to be
persisted in your browser when you visit a website. Local storage data are used
by website owners in order to make their websites work, or to work more
efficiently, as well as to provide reporting information. Information set in
local storage data are only accessible from the same website domain that set the
local storage data, and can only be set or accessed using JavaScript on pages
from that same website. Local storage data have many of the same restrictions as
cookies – if you delete cookies or your internet cache, local storage data are
also deleted. Similarly, if you block cookies then local storage data are also
blocked. Since local storage data are so similar to cookies and we treat local
storage data with the same privacy and data protection principles as cookies,
when we use the term “cookies” on this page or any other material on our website
or elsewhere, we are including both cookies and local storage data.

“Device IDs” are unique identifiers associated with your mobile device to be
used for advertising. These identifiers are assigned by your mobile device
operating system, such as Apple’s iOS and Google’s Play Services for Android,
and do not reveal your identity. Device IDs can be reset in your mobile device
settings.

“Log files” track actions occurring on Sites and collect data including, as an
example, your IP address, browser type, Internet service provider,
referring/exit pages, operating system, date/time stamp, click data and types of
advertisements viewed.

"Web beacons" are objects that are embedded in a web page or e-mail and are
usually invisible to the user but are used to track a web user’s navigation of a
website or collection of websites or pages, interaction with an e-mail, use of
mobile applications, the completion of transactions, submittal of applications
and browsing behavior.

“Location Data” recognizes a consumer’s location while they are on their device
which is utilized by Conversant to deliver advertisements. As with all data
Conversant collects, this is limited to imprecise location data unless the
consumer has opted in to allow their precise location to be used for IBA.

The Non-PII collected is used for marketing purposes, enables us to determine
which advertisements perform well, allows us to more effectively match ads,
mobile application and website content to your interests, assists us in
improving the operation of our services, helps us to maintain the quality of our
services, enhances our services to our business partners and clients and enables
us to provide general statistics to our business partners and clients regarding
use of Conversant’s services. Conversant may also act as a delivery agent when
its products and services are used directly by a client to facilitate
advertisements and other communications.

When a consumer responds to or views an Internet advertisement served by
Conversant (such as through third-party websites or email solicitations) or
visits a Conversant site, we may assign an anonymous, unique identifier to the
end user's Internet browser or device, often via a cookie. One function of these
technologies is to provide Conversant with information for the purpose of paying
third-parties affiliate commissions when an Internet user clicks on a link,
creates a lead, or makes a purchase on an advertiser's website. If the Internet
user re-visits the advertiser's site directly, Conversant is able to continue to
track the user's activities (excluding PII) on the advertiser's site and credit
the third-party website that referred the user. In other words, if a user reads
a blog about a pair of shoes and decides to visit that advertiser’s website and
purchase that pair of shoes, we would ensure that the blog gets compensated for
referring the user to that advertiser’s website.

We also may use Internet browsing, cross-mobile application browsing and online
purchase data associated with a user, on a Non-PII level, across multiple
devices to develop a predictive statistical user profile of the end user's needs
and interests for the purpose of sending them relevant advertisements on
multiple browsers and devices. This is called cross-device IBA. We may also use
this cross-device functionality for the purpose of more accurately paying
third-parties affiliate commissions, as described in the paragraph directly
above.

To opt out of Conversant IBA, please follow the opt-out instructions below in
the “Your Choices” and “Mobile Device Choices” sections of our Privacy Policy.
Upon opt-out, we will no longer collect behavioral data on your browser and will
also no longer send behavioral data to other browsers or devices associated with
you. However, data that was collected on your browser or device prior to you
opting out may still impact the advertisements you see on other browsers and
devices associated with you. We will attempt to opt you out across all of your
browsers and devices. However, since we don't collect data which directly
identifies you, we cannot guarantee that all of your browsers and devices will
be opted out. To ensure you are opted out across all of your browsers and
devices, we recommend that you opt out of each one individually. If you delete
your cookies, we recommend that you renew your opt out choices. If cookies
aren’t enabled in your browser or if you’re using ad-blocking tools, our opt-out
mechanism may not work. Please note that opting out does not necessarily mean
that you will no longer receive any advertising from Conversant, it means that
you will no longer receive advertising tailored to your interests.

Information Sharing by Conversant

Conversant will only share your information for limited purposes such as those
provided in this Privacy Policy. This may include sharing information (1) to
enable third party service providers to assist or facilitate in the services we
provide to our clients; (2) to comply with applicable laws and regulations or to
respond to a subpoena, search warrant or other lawful request for information
received by us, whether or not a response is required by applicable law; (3) to
enforce our terms of use and other agreements or to protect our rights ; (4) to
protect the safety of members of the public and users of the service; (5) with
Conversant affiliates and clients for marketing purposes; (6) with vendors,
administrative service providers, technology providers, and carefully selected
partners for services including, but not limited to, data validation,
enhancement, information verification and suppression services; or (7) for any
other purpose for which you provide consent. None of this information will
include PII except as provided herein. While Conversant strongly encourages
clients and partners to adopt responsible approaches to online marketing,
Conversant is not responsible for the information practices of such clients and
partners. With respect to IBA, Conversant and other third parties may use
Non-PII collected or shared with respect to your visits to websites with whom we
have relationships for various purposes, including, but not limited to,
providing advertisements about goods and services likely to be of greater
interest to you.

In the event that Conversant is acquired by or merged with a third party, we
reserve the right, in any of these circumstances, to transfer or assign the
information we have collected from you as part of such merger, acquisition,
sale, or other change of control. In the unlikely event of our bankruptcy,
insolvency, reorganization, receivership, or assignment for the benefit of
creditors, or the application of laws or equitable principles affecting
creditors' rights generally, we may not be able to control how your information
is treated, transferred, or used.

Service-specific Provisions for Information Collection and Use:

Some products and services offered by Conversant have privacy considerations
unique to those offerings. These considerations are covered here:

* Lead Generation:

Conversant provides lead generation services to clients where we work with
website publishers who utilize their display, search and email distribution
channels to generate consumer interest or inquiry into advertiser products and
services. The co-registration component refers to the process in which
Conversant facilitates the exchange of consumer information (typically PII held
by website publisher in accordance with their Privacy Policy) from website
publishers to advertisers.

We may receive PII that our clients have collected in connection with our
services for our clients or that clients have collected for access or
transmittal purposes to other clients. We may hold such information and/or
transmit or allow access to such information to the intended recipients or
categories of recipients as requested by our clients.

As part of the Lead Gen services, online forms hosted by us, our clients, or
third parties acting on the behalf of us or our clients may collect PII that a
consumer has voluntarily provided. This information may be used for the same
purposes listed in “Information Sharing by Conversant,” above. This information
may also be used to verify any information submitted to use or any of our
clients, and for any suppression or opt-out purposes.

Conversant may serve advertisements to you based, in part, on the demographic
and geographic information you submitted to our clients during the website
registration process, and lifestyle information about you that we obtain from
them and other Conversant entities and third parties.

Security

The security of your information is important to us. We have implemented
appropriate security measures to protect the information in our care, both
during transmission and once we receive it. We take physical and technical
security measures to protect our data from unauthorized access, as well as
unauthorized disclosure or destruction of data.

No transmission of data over the Internet is guaranteed to be completely secure.
While we strive to protect your data, it may be possible for third parties not
under the control of Conversant to unlawfully intercept or access transmissions
or private communications. Unauthorized entry or use, hardware or software
failure, and other factors may compromise data security. Conversant cannot
ensure or warrant the security of information you transmit to us. You
acknowledge and assume this risk when communicating with Conversant.

Retention

We retain online Non-PII for IBA for no more than eighteen (18) months.
Aggregate reports generated from such data may be retained for a longer period,
as ad delivery and reporting data.

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SELF-REGULATION & VOLUNTARY COMPLIANCE

Our industry has a rigorous voluntary self-regulatory regime, and we are active
members of industry groups such as the Interactive Advertising
Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising
Alliance of Canada (DAAC) who promulgate codes of conduct to which their members
must adhere. These codes impose requirements on participating companies such as
transparency and choice around the use of data for IBA, and require regular
audits of member privacy practices.

Conversant is an active member of these and other groups, and where Conversant
engages in activities regulated by these programs, we support the DAA
Self-Regulatory Principles and the DAAC Self-Regulatory Principles.

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YOUR CHOICES

We hope that after reading through this Privacy Policy that you feel comfortable
we are collecting and using data responsibly, and that the cumulative benefits
of our work are valuable to the Internet as a whole and your individual browsing
experience. As part of our commitment to consumer privacy, we give consumers the
ability to opt out of IBA provided by Conversant. If you would like to opt out
of IBA from Conversant, please click here to learn more and opt out.

As an alternative, you may also visit the DAA AdChoices opt-out page
at: https://optout.aboutads.info.

We will attempt to opt you out across all of your browsers and devices. However,
since we don't collect data which directly identifies you, we cannot guarantee
that all of your browsers and devices will be opted out. To ensure you are opted
out across all of your browsers and devices, we recommend that you opt out of
each one individually. If cookies aren’t enabled in your browser or if you’re
using ad-blocking tools, our opt-out mechanism may not work.

In addition to the browser and device based opt-out above, Conversant may
process your hashed (obfuscated) e-mail address for user authenticated, or
e-mail linked, IBA. You may opt-out of such e-mail linked IBA by visiting our
e-mail opt-out portal here.

Please note that opting out does not necessarily mean that you will no longer
receive any advertising from Conversant, it means that you will no longer
receive advertising tailored to your interests.

Conversant may place ads on websites that are part of the Google Display
Network. Based on your visits to these websites, Google uses an advertising
cookie (from DoubleClick) to associate your browser with interest and
demographic categories. Google then uses these categories for IBA on these
websites. To learn more about this and your choices from Google, please click
here.

Mobile Device Choices

For mobile websites, you can follow the opt-out instructions provided above.

Connected Television Choices

To opt out of relevant advertising on your television or the sharing of viewed
content on your television with Conversant, please log in to your television
service provider account and adjust your settings, or contact your television
service provider.

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USE OF THE CONVERSANT SITES AS A VISITOR OR CLIENT

You can browse the Conversant Sites without providing any PII. You may choose to
provide PII to us voluntarily if you interact with our Site in certain ways,
such as applying for employment with Conversant, responding to an advertisement
for Conversant, or using one of our contact forms. This information is used only
for the reasons it was collected, such as responding to your communication, and
is not shared with third parties other than to fulfill the purpose for which it
was collected.

Conversant may also collect Non-PII, through the use of technologies such as
cookies, including IP address, browser type, operating system, domain name,
language preference, access dates and times, referring website addresses, online
transactions and browsing and search activity. We may use this Non-PII for
purposes including enhancement of our services, marketing, IBA, and to more
effectively match website content to your interests. We may share your
information with our third party service providers, Conversant and its
subsidiaries and affiliates, third party marketing partners, our clients and
publishers, and as expressly provided for herein.

We also use cookies to simplify login and to facilitate secure navigation
through the password protected areas of the Site. Visitors who choose to reject
all cookies may have difficulty navigating the password protected areas of the
Site depending on the nature of their connection (dynamic IP, proxy server,
etc.).

We may also partner with third parties who collect information on our Sites, and
we may maintain links to other websites on our Sites. This Privacy Policy does
not apply to the privacy practices of other websites or of third parties who
collect information on our Sites. We would encourage you to visit the applicable
policies of those third parties, or visit www.AboutAds.info to learn more about
interest-based advertising and to see your opt-out choices from other
participating companies that may be collecting and using data on Conversant’s
websites.

For Clients and Publishers

The Conversant network includes our clients and publishers involved in
advertising campaign transactions. Information collected from clients and
publishers includes PII that is necessary to conduct business, such as name,
phone number, and email address. Payments made to and from Conversant require
the collection of PII that may include credit card numbers and bank account
information. Phone numbers may be used for sales or inventory acquisition
purposes. This information is collected, modified and stored in a password
protected environment and is used for purposes including service, media
delivery, contact, billing and accounts payable. We will not sell or rent this
information to non-Conversant entities. All client and publisher information
collected for these purposes is explicit, voluntary, manually entered, and can
be opted-out.

Security:

See “Security” under Information Collection and Use, above.

Information Sharing:

This client and publisher information is not shared with any third party outside
Conversant and its affiliated companies, except for that necessary to conduct
business, such as clearing a credit card transaction for an advertising campaign
purchase or making an ACH direct deposit to pay a publisher, or as required by
law. The security of this information is crucial to our success in the highly
competitive field of online advertising. Conversant may, from time to time, use
"gallery" pages to identify clients or publishers by business identity ONLY
(e.g. Adcycle.com is a new Publisher in the Conversant Network).

Log Files:

We record the IP address of new clients and publishers at sign-up. This can
assist in administering the Site and client or publisher accounts, including
features designed to enhance the Client experience. This information is part of
the secure member database and is password protected.

Our Communications:

We send all new clients and publishers a welcoming email to verify password and
user name, and may communicate with you about program or other information at
the contact information you provide. We me also email individuals that have
provided us with their contact info so that we can communicate information about
Conversant’s services. You can request to opt out of these emails by filling out
this form.

Site and Service Updates:

We may send Site and service announcement updates by email. Because these
announcements contain important information about services, it is not possible
to unsubscribe. We also communicate with clients and publishers to provide
requested services and in regards to issues relating to their account via email
or phone.

Correction/Updating PII:

If a client’s or publisher’s PII changes (such as email address) or they would
like PII removed from our system, we provide several ways to correct or update
PII. The following options are provided:

Make the changes online by entering the member area.

Fill out a form by clicking here

Contact your account manager.

All requests to remove a client or publisher from our system will be verified
prior to removal to ensure the proper identity of the requester.

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Have a question on something not addressed or have a complaint? Please use the
Feedback form located here.

YOUR REPRESENTATIONS

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS
AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS.
You also agree that you have provided notice to, and obtained consent from, any
third party individuals whose information you supply to us with regard to: (a)
the purposes for which such third party's information has been collected; (b)
the intended recipients or categories of recipients of the third party's
information; (c) which of the third party's data are obligatory and which data,
if any, are voluntary; and (d) how the third party can access and, if necessary,
rectify the data held about them. It is the express wish of the parties that the
Privacy Policy and all related documents have been drawn up in the English
language and that the English version of this Privacy Policy shall be the sole
version used in interpreting and enforcing this Privacy Policy.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE
LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO
THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

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CALIFORNIA PRIVACY RIGHTS

NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA CONSUMER PRIVACY ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to
residents of California. This section of the Privacy Policy applies if you are a
natural person who is a resident of California (“California Consumer”) and uses
our Services. This Addendum supplements the information in our Privacy Policy.
However, this Addendum is intended solely for, and is applicable only as to,
California Consumers: if you are not a California Consumer (or a resident of
California), this does not apply to you and you should not rely on it.

Under the CCPA, “Personal Information” means information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or
household. Personal information includes, but is not limited to, the following
if it identifies, relates to, describes, is reasonably capable of being
associated with, or could be reasonably linked, directly or indirectly, with a
particular consumer or household. Please note that Personal Information is
different from the term Personally Idenfitied Information (“PII”) mentioned in
our Privacy Policy.

In the below tables and sections, we describe (as required by the CCPA):

1. Our Collection of Personal Information – the types of Personal Information
(which the CCPA defines broadly) that we collect, the types of sources we
collect it from,
2. Our Disclosure and Sale of Personal Information – the types of recipients to
whom we disclose or sell Personal Information.
3. Our Business Purposes - our business purposes for (a) collecting and (b)
sharing Personal Information, which are generally the same.
4. Your California Privacy Rights and Choices – what rights you have under the
CCPA, for instance, to request that we “opt out” your information from our
marketing database (also called “do not sell” rights), or to request
categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes
for which we may use California Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories
of information summarized in the table below. The following table also describes
how we collect and use such categories of information.

Category

Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months

Identifiers, e.g., obfuscated name, obfuscated address, obfuscated email
address, obfuscated phone number, online identifiers, and IP address.

Advertising networks, advertisers, and publishers

Characteristics of protected classifications under California or US law

E.g., race; sex/gender; marital status; medical condition; and age.

Advertisers

Commercial or transactions information. E.g., records of personal property,
products or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies

Advertisers and publishers

Advertisers

Internet or other electronic network activity information. E.g., browsing
history; search history; online interests, such as information about categories
of consumer interests derived from online usage; and information on a consumer's
interaction with a website, application, or advertisement.

Advertisers and publishers

Advertisers

Geolocation data

Advertising networks, advertisers, and publishers

Advertisers

Professional or employment-related information

E.g., current or past job history

Advertisers

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes: In addition, we may share personal information with
third parties in order to: (a) comply with legal process or a regulatory
investigation (e.g. a subpoena or court order); (b) enforce our Terms of
Service, this Privacy Policy, or other contracts with you, including
investigation of potential violations thereof; (c) respond to claims that any
content violates the rights of third parties; and/or (d) protect the rights,
property or personal safety of us, our platform, our customers, our agents and
affiliates, its users and/or the public. We likewise may provide nformation to
other companies and organizations (including law enforcement) for fraud
protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction: We may also share personal
information in the event of a major corporate transaction, including for example
a merger, investment, acquisition, reorganization, consolidation, bankruptcy,
liquidation, or sale of some or all of our assets, or for purposes of due
diligence connected with any such transaction.

Sharing With Service Providers: We may aggregate and/or de-identify any
information collected so that such information can no longer be linked to you or
your device (“Aggregate/De-Identified Information”). We may use
Aggregate/De-Identified Information for any purpose, including without
limitation for research and marketing purposes, and may also share such data
with any third parties, including advertisers, promotional partners, and
sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we
collect for the following purposes, as we also have described in our Privacy
Policy, in the section titled “Personal Information That We Collect and Use”:

Our Purposes for collecting, using and sharing Personal Information

Online targeting, for example:

* Helping clients to target ads to online audiences based on common
demographics and/or shared (actual or inferred) interests or preferences
(e.g., consumers interested in winter apparel). When we do this, we handle
information provided by our Clients (for instance, their own customer files)
and “match” their information through pseudonymization techniques (such as
through coded data “hashing”) with online cookies and other identifiers. We
then use these cookies and identifiers to target and measure ad campaigns
online across various display, mobile and other media channels.
* Assisting Clients by creating “identity” graphs, to help locate users across
various channels, such as connecting identities based on common personal,
device-based, or network-based identifiers (e.g., IP address, email address).

Additional marketing and analytics services, for example (which may overlap with
“Online targeting,” above):

* Assisting in targeting and optimizing of direct mail and email campaigns,
display, mobile and social media marketing.
* Measuring the effectiveness of online or offline ad campaigns by determining
which messages are most likely to be seen or opened by which types of
consumers, or which types of ads are most likely to lead to purchases.
* Analyzing and optimizing our Clients’ (or their service providers’)
proprietary databases, or helping Clients to identify and mitigate potential
fraud.
* Providing “verification” or data “hygiene” services, which is how companies
update and/or “clean” their databases by either verifying, updating, removing
or correcting old, incorrect or outdated information.
* In addition, for own our corporate purposes, we sometimes use personal
contact information such as name or email address to contact businesses that
we believe may benefit from using our services.

Operating our Services, for example:

* Improving, testing, updating and verifying our own data and data services.
* Developing new products.
* Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security
incidents, debugging, short-term and transient use, quality control, and legal
compliance. We use the information collected from our own website for the above,
as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California
residents have the right to request that we disclose what personal information
we collect from you, to delete that information, and to opt-out of the sale of
your personal information, subject to certain restrictions. You also have the
right to designate an agent to exercise these rights on your behalf. This
section describes how to exercise those rights and our process for handling
those requests, to the extent as act as a “business” (as opposed to a “service
provider”) for purposes of handling personal information. (To the extent
permitted by applicable law, we may charge a reasonable fee to comply with your
request.)

a. Right to Opt-out of the sale of your personal information.

California residents may opt out of the “sale” of their personal information.
California law broadly defines what constitutes a “sale” – including in the
definition making available a wide variety of information in exchange for
“valuable consideration.” We may act as a “business” or a “service provider”
under the CCPA. When we act as a business under the CCPA, you may “opt out” of
our “sale” of your personal information (as those terms are defined by the CCPA)
by clicking here. Please note that this is not an opt out of interest-based
advertising. To opt out of interest-based advertising, please visit the DAA
AdChoices tool.

b. Right to request deletion of your personal information

You may also request that we delete any personal information that we collected
from you, including data provided to us by our clients. (Note that this is
different from your right to “opt out” of us selling your personal information,
which is described above; also note that we do not generally collect personal
information directly from consumers, in which case “deletion” rights generally
do not apply.) However, we may retain personal information for certain important
purposes, such as (a) to protect our business, systems, and users from
fraudulent activity, (b) to address technical issues that impair existing
functionality (such as de-bugging purposes), (c) as necessary for us, or others,
to exercise their free speech or other rights, (d) to comply with law
enforcement requests pursuant to lawful process, (e) for scientific or
historical research, (f) for our own internal purposes reasonably related to
your relationship with us, or to comply with legal obligations, and (f) as
necessary to comply with client contracts, including allowing advertisers to
properly compensate publishers for driving traffic to their web properties.
California residents can delete your personal information by clicking here or by
contacting us at (866) 267-3891.

c. Right to request access to your personal information

California residents also have the right to request that we disclose what
categories of your personal information we collect, use, or sell. As a
California resident, you may request access to the specific pieces of personal
information that we have collected from you. California residents can access
their personal information by clicking here or by contacting us at (866)
267-3891.

However, we may withhold some personal information where the risk to you or our
business is too great to disclose the information, or where we cannot verify
your identity in relation to such personal information. Thus, for security
purposes (and as required under California law), we will verify your identity –
in part by requesting certain information from you -- when you request to
exercise certain of your California privacy rights.

In addition, please read our privacy policy to learn more about:

* The categories of personal information that we have collected about you.
* The categories of personal information that we have sold.

If we are unable to complete your requests, we will provide you additional
information about the reasons that we could not comply with your request.

d. Right to nondiscrimination. We do not deny, charge different prices for, or
provide a different level of quality of goods or services if you choose to
exercise these rights.

e. Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of
age in California unless we have received legal consent to do so. If we learn
that personal information from such California residents has been collected, we
will take reasonable steps to remove their information from our database (or to
obtain legally required consent).

f. Authorized Agents

You may also designate an agent to make requests to exercise your rights under
CCPA as described above. We will take steps both to verify the identity of the
person seeking to exercise their rights as listed above, and to verify that your
agent has been authorized to make a request on your behalf through providing us
with a signed written authorization or a copy of a power of attorney.

g. Annual Consumer Request Reporting

Requests to know: information linked to your Cookie ID

Request to know: information linked to your name

Requests to delete

Requests to opt-out

Number of requests received

271

712

Number of requests complied with in full

175

712

Number of requests complied with in part

Number of requests denied due to inability to verify consumer

Mean number of days taken to substantively respond to requests

1 day

20 days

2 days

From July 1, 2020 to December 31, 2020, we facilitated requests made pursuant to
CCPA from individuals in the United States that submitted a request through our
online request form or by calling our toll-free number.

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MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will
update the “Last Modified” date above. If we make a material change, such as the
ways in which we use PII, we will notify you via a prominent notice on our Site.

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product development. Precise geolocation and information about device
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You may click to consent to the processing described above or review options and
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