HOME SOLUTIONS COMPANY RESOURCES PLATFORM LOGIN CONTACT US Privacy Policy Last Updated: November 24, 2021 Introduction Welcome to MediaMath’s Privacy Policy (“Policy”). In this Policy, we use the terms “MediaMath“, “our“, “us” and “we” to refer to MediaMath, Inc. and our affiliates. MediaMath is committed to protecting the privacy of individuals (“users”, “you“, “your“) when we process data about you via our proprietary “Future Proofed Platform”™ (the “Platform“), when you visit our website at www.mediamath.com (the “Website“) and when we engage in marketing activities based on contact information you provide to MediaMath through other means described in this Policy. This Policy is provided in a layered format, so you can click through to the specific sections that may interest you. 1. Important information and who we are Purposes of this Policy This Policy sets out how MediaMath collects and processes personal data, personal information or the equivalent terminology in your jurisdiction (“personal data” or “personal information“) about you via the Platform, when you visit the Website, and when we engage in marketing activities based on contact information you provide to MediaMath through other means described in this Policy. It also sets out how we use personal data, the steps we take to protect it, the parties we disclose it to, and the choices and rights that you have regarding personal data we process about you. The date of the last update can be found at the top of the Policy, and this Policy describes how we have handled personal data in the twelve months prior to the date indicated. You should read this Policy carefully so that you are fully aware of how and why we are using your personal data. Who we are MediaMath is a global provider of digital advertising media and data management technology. We provide a technology platform and services, which help our advertiser clients (including agencies of such advertisers) do a more effective job of reaching their desired audiences. Our Platform has several aspects. The demand-side aspect enables our advertiser clients to purchase advertising space (or “inventory“) from publishers (e.g. websites that display ads) in an automated fashion. This inventory includes display, video, audio, social, native, digital out-of-home (e.g., billboards or ads you may see in taxis or buses) and mobile ads. The data management aspect of our Platform provides our advertiser clients with tools to onboard, segment, activate, and understand the data they upload to the Platform. When MediaMath processes your personal data as a controller in the context of operating the Platform, the Website and our marketing activities, the controller of your personal data is MediaMath, Inc., MediaMath GmbH, MediaMath UK Limited and/or MediaMath Publicidade Digital Ltda depending on which MediaMath entity has contracted with the advertiser client. MediaMath is an active member of the industry associations that govern user privacy in the context of digital advertising. As of the last update of this Policy, MediaMath is an active member in and complies with various industry frameworks, including: the Network Advertising Initiative (“NAI“) and its NAI Code of Conduct; the Digital Advertising Alliance (“DAA“) and its “Self-Regulatory Principles for Online Behavioral Advertising”; Digital Advertising Alliance of Canada (“DAAC“); the European Interactive DAA (“EDAA“); the Interactive Advertising Bureau in the US, Europe and various countries around the world (“IAB“); including the IAB Europe Transparency & Consent Framework as Vendor ID 79 and its Specifications and Policies; and the Association of National Advertisers (“ANA“). Tailored advertising Advertising which has been delivered to be relevant to individuals or groups of individuals is referred to by MediaMath as “tailored” advertising. MediaMath also facilitates the display of advertising which is not specifically relevant to individuals or group of individuals, which is referred to as “basic” advertising. There are many terms such as interest-based, targeted, personalized and behavioral used to describe advertising which is intended for individuals, groups of individuals, or categories of individuals. In this Policy, we refer to such advertising as “tailored” in that it is tailored to the types of products or services individuals may be interested in. In this Policy we describe how you can opt out of tailored advertising delivered via our Platform. Personal data pertaining to children MediaMath’s products and services are not designed to deliver tailored ads to children. The definition of “child” varies by location. We do not knowingly collect personal data from or about children under age 13 or any higher age where not permitted to do so under applicable law. To the extent permitted by applicable legislation, we decline any responsibility regarding any activities that may be conducted by children without the permission of their parents or legal guardians. If we are made aware that we may have received personal data from or about a child in respect of whom we are not permitted to process personal data under applicable law, we will use reasonable efforts to investigate and remove that data from our records as soon as practicable. If you have a reason to believe that we might have any information from or about a child under the permitted age in the relevant location, please contact us at privacy@mediamath.com. Links, other websites and other third parties This Policy relates solely to the personal data we collect and process about you in relation to our Platform, our Website, and other interactions you may have with MediaMath that are described in this Policy. MediaMath’s Website contains links to other sites, and the ads delivered by the Platform may run on a variety of other sites. Clicking on those links, accessing other sites, or enabling those connections may allow third parties to collect or share data about you. MediaMath does not control these third-party sites and is not responsible for the privacy practices of such sites. You should refer to the privacy statements of such third-party sites to find out how they collect and use your personal data. Also, as explained below in Section 5, third parties may process personal data from you when you visit the Website. Such processing is governed by the privacy statements of such third parties. 2. The personal data we collect via the Platform MediaMath collects certain personal data while delivering ads via the Platform. We do not intentionally collect directly identifiable data such as your name, home address, phone number, or any government identifiers such as your Social Security Number unless you provide such personal data in connection with any request that you make directly to MediaMath. MediaMath identifies you by means of personal data related to your computer or device using cookies and other similar technologies, as explained below. We assign a unique identifier called a “MediaMath ID” to your browser, to your devices (such as your mobile device, connected television, or over-the-top television devices (“OTT TV Device“)), or to other screens through which we serve an ad to you on behalf of our advertiser clients. We also assign a MediaMath ID when you access an advertiser client’s digital properties such as their websites, emails, or apps (“Digital Properties“). The MediaMath ID enables the Platform to determine within a reasonable level of confidence that a browser or device is the same one with which the Platform has previously interacted. In some cases, based on data we receive from our advertiser clients or data partners (e.g. audience partners from whom we receive Third Party Segment Data as defined below), we infer within a reasonable probability that another browser or device should be associated with the same MediaMath ID. Where we are able to associate more than one browser or device with the same MediaMath ID, we use this information on behalf of our advertiser clients to deliver tailored ads to you across multiple browsers or devices (known as “Cross-Device Advertising“). The MediaMath ID can be a cookie ID (a unique ID assigned randomly by MediaMath to an unrecognized browser), a mobile advertising ID (a unique ID assigned by the mobile operating system, e.g., Apple ID for Advertising or Android Advertising ID), or an OTT TV Device Identifier for Advertising (a unique ID assigned by an OTT TV provider, e.g., Roku ID for Advertising). Your MediaMath ID is personal data and is associated with other categories of personal data that we collect about you including the following: Bid Request Data and Impression Data: MediaMath receives personal data about you when we have the opportunity to show you an ad on Digital Properties, (“Bid Request Data“). We collect additional data when we deliver an ad on behalf of our advertiser clients (“Impression Data“). Bid Request Data includes your Internet Protocol (“IP”) address, imprecise location (e.g., country, region, postal or zip code), browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); and Internet Service Provider. It also may include IDs that our partners assign to your browser or device, including Google advertising identifiers associated with your browser or device and used by MediaMath as part of its syncing processes. See Google’s Privacy Policy to learn more about its use of the personal data which it receives from partner sites and your ability to control the information which Google collects on these sites. Impression Data includes elements from (and derived from) Bid Request Data, campaign information and bidding information (e.g., site category, number of pages browsed, click event, Application ID, video metrics, page URL, connected device ID, timestamp and connection speed). The sources of Bid Request Data and Impression Data are your browser or device and media supply sources, such as publishers (i.e. organizations who operate Digital Properties) and exchanges or supply-side platforms (i.e. organizations who display ads on publishers’ Digital Properties). Pixel Data and Other Client Data: MediaMath advertiser clients import personal data to the Platform regarding your interactions with them via their Digital Properties. This data falls into two main categories: Pixel Data and Other Client Data. Pixel Data is collected by the use of MediaMath and/or third party pixels (described below). Pixel Data includes the time you visited the site, the page URL, your IP address, your browser type (e.g., Chrome or Internet Explorer), the operating system (e.g., Mac OS or Windows), the type of device you used (e.g. laptop or desktop), and data regarding your activities on the Digital Properties. For example, if you are shopping on an advertiser client’s website for a product, and you place a product in your online shopping cart, or make an online purchase, the advertiser client can import that data to the Platform . MediaMath uses this personal data later to help the advertiser client show you an ad on a different website or app. MediaMath advertiser clients may use the Platform to collect personal data in a form that does not reveal your direct identity, such as “hashed” email addresses that cannot be read in their directly identifiable form (i.e. each email address is converted to a code that is unique to that email address). Other Client Data is personal data that advertiser clients obtain outside of the Platform and import into the Platform. This includes “Segments” that advertiser clients create or obtain independently from third-party sources. A Segment is a grouping of individuals who share one or more attributes (e.g., “car enthusiast”). Individuals are identified in these Segments by online identifiers and not by names or anything that reveals their names. Other Client Data also includes personal data that advertiser clients collect or independently obtain offline, such as purchases made in the advertiser client’s store. Before advertiser clients transmit this offline data to MediaMath, names and other directly identifying information are removed and replaced with a MediaMath ID. Third-Party Segment Data and Other Third-Party Data: Third Party Segment Data is personal data we receive from third party audience partners who create and provide us with Segments for us and our advertiser clients to use for advertising purposes. These Third- Party Segments are similar to the Segments described above. Other Third Party Data we receive includes personal data from third-party partners that allows them and/or us to associate or match the MediaMath ID with those partners’ identifiers (through a process called “Cookie Syncing”), personal data that associates your different devices with each other, and personal data regarding video content that you view on television. We may use an online identification code, generated by one of our first party identity partners, for the purpose of delivering an ad to your device. This code does not contain any of your identifiable personal data and cannot be used to re-identify you. We use this code to enable our delivery and management of tailored advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc), as well as for data linking and the measurement of ad performance. You have the right to express a choice regarding the use of your data for these purposes. For more information about our partner LiveRamp and to opt out of the use of your data in this manner, visit https://liveramp.com/opt_out/ . Special or Sensitive Categories of Personal Data: We do not knowingly collect any special categories of personal data about individuals in the EEA or the UK, including: personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your health, sex life, or sexual orientation; and genetic or biometric data. MediaMath also does not knowingly collect any data about other sensitive categories such as personal data about financial account numbers, insurance plan numbers, and criminal convictions or offenses. Where not considered sensitive in accordance with applicable law outside the EEA or the UK we use personal data to create Segments for our clients to use in the following ways: Our advertiser clients may use health-related Segments about non-sensitive conditions such as an inferred interest in health and wellness or cough medicine and allergy medications. Click here for a list of the standard health-related Segments and a sample of custom health segments provided for use by clients in our Platform. Our advertiser clients may use Segments based on political information or interests. Click here for a list of the standard political interest Segments and a sample of custom political Segments provided for use by advertiser clients in our Platform. When creating Segments MediaMath does not knowingly process personal data that would be considered sensitive under applicable law (for example, we do not create Segments of users based on personal data considered to be sensitive under applicable laws, such as personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal data concerning your health, sex life or sexual orientation, or genetic or biometric data). MediaMath may process Segments based on demographic information such as race, gender and income range where such is information is not considered sensitive pursuant to applicable law. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our advertiser clients and partners. Our advertiser clients are responsible for this processing, and you should direct any queries you have about this use of Segments to them. Categories of information collected pursuant to the California Consumer Privacy Act (CCPA): For the purposes of the CCPA, the above-described personal information collected can be classified as follows: Identifiers (such as an online identifier or an Internet Protocol (IP) address); Internet or other electronic network activity information (such as the browsing history, search history, and information regarding to interaction with the Website or with advertiser clients’ Digital Properties) Geolocation data inferences 3. How we collect personal data into the Platform We use various technologies to collect your personal data into the Platform. Like most digital marketing platforms, MediaMath collects personal data using cookies and other technologies that recognize browsers and devices. We use these technologies to collect the categories of personal data described above in Section 2. The technologies we use include: Cookies – Cookies are small text files. MediaMath uses cookies to uniquely identify an Internet browser. Certain browsers or browser settings sometimes block cookies or prevent them from working effectively. Pixels – Pixels are transparent images, iFrames, JavaScript or mobile SDKs that we, our advertiser clients, and our partners use to understand how users interact with their Digital Properties. We collect personal data into the Platform through other methods as well. The Platform contains Pixel Data, Other Client Data, Third-Party Segment Data, and Other Third Party Data that we receive through server- to-server transfers, Cookie Syncing (defined in Section 2) and other advertiser client and partner calls to MediaMath originating from the browser. 4. How we use personal data in the Platform We use personal data in the Platform for the commercial purposes of delivering tailored ads to you on behalf of our advertiser clients. We use personal data for our business purposes to improve our Platform, our products and our services that we provide to our advertiser clients and partners, as well as to create new products and services. Below, we have set out a description of specific ways we use various combinations of your personal data in the Platform to fulfil our commercial interests to serve our advertiser clients, as well as to improve our products. Purpose/Activity Personal Data Type Enabling MediaMath advertiser clients to create marketing campaigns; Creating Segments; Facilitating MediaMath advertiser clients’ creation of segments; Making decisions related to the opportunity to display an ad (e.g., deciding which advertiser clients’ campaigns are a good match for a bid opportunity and what price to bid in each case) and placing the bid on behalf of our advertiser clients; Setting, reading and modifying a MediaMath cookie or reading a mobile advertising identifier or OTT TV Device Identifier for Advertising; Collecting information about a browser or device; Facilitating our partners’ collection of personal data, including by placing partners’ pixels or tags on our advertiser clients’ Digital Properties; Delivering ads, including ads based on your inferred interests or activities on Digital Properties; Measuring the effectiveness of those ads and attributing your activities to our advertiser clients’ campaigns; Generating and providing to advertiser clients reports and user-level data related to their advertising campaigns in the Platform; Automated decision- making and profiling based on personal preferences, interests, behavior, or location; Transferring data to a third party where advertiser clients have elected to use its services or where MediaMath has engaged a subcontractor to provide certain functionality or capabilities as a part of the Platform or to improve our Platform and the products and services that we provide to our advertiser clients and partners; and Fraud detection and prevention. MediaMath ID Inserted Cells Bid Request and Impression Data Pixel Data and Other Client Data Third-Party Segment Data and Other Third-Party Data Synchronizing MediaMath cookie ID with third- party partners (Cookie Syncing). MediaMath ID Impression Data Pixel Data Other Third-Party Data Associating multiple browsers and devices with each other; Development, maintenance, and commercialization of MediaMath’s cross- device graph that associates your different devices with each other; Append audience membership to Client’s advertiser client’s first-party data. MediaMath ID Impression Data Third-Party Segment Data and Other Third-Party Data Pixel Data and Other Client Data Mapping data pixels to third-party segments. MediaMath ID Pixel Data and Other Client Data Third-Party Segment Data and Other Third- Party Data Honoring opt-out requests for users who have opted out. MediaMath ID Enabling hyperlocal targeting of devices within a defined location. Bid Request Data We also publish or otherwise make public anonymous, aggregate, or summary information regarding campaigns run in the Platform on behalf of our advertiser clients. For example, we may publish a report that reflects aggregated statistics regarding seasonal trends in shopping patterns or geographic differences in advertising impression opportunities. These reports do not contain personal data. Automated decision-making and profiling Our Platform uses proprietary algorithms to make automated decisions about whether or not to bid on opportunities to serve you ads on behalf of our advertiser clients and, if so, how much to bid. The ads you see are the result of advertiser client campaigns that specify how much to spend and on what basis to spend combined with the use of our algorithms. The ways in which we use algorithms to determine bid prices may be considered automated decision-making in certain jurisdictions. Additionally, these processes, in combination with advertiser client campaigns described below, may constitute profiling in certain jurisdictions. These automated decisions use the MediaMath ID we assign to your browser or device. Using proprietary technology, we associate data that we collect from third parties with this MediaMath ID. We create Segments using inferred details about certain of your preferences, behaviors, and demographic information, and use those Segments to serve ads on behalf of our advertiser clients. For example, if you are browsing a shoe retailer’s website on your mobile device, we may infer that you are interested in buying sneakers and associate that mobile device with a sneaker-buyer Segment. If an advertiser client subsequently wants to advertise sneakers, the advertiser client may choose to target that Segment across your devices. If MediaMath then receives an opportunity to show you an ad, provided by an advertiser client, on your computer browser, which computer browser has been associated with your mobile device by our algorithm, MediaMath’s bidding technology will automatically decide whether to bid and if so what price to bid on behalf of our advertiser clients, based on the data and algorithms outlined above. Legal basis for processing (EEA and UK) Our legal basis under the General Data Protection Regulation (“GDPR“) for processing the personal data in the Platform depends on the personal data concerned and the specific context in which we process it. However, we will normally collect personal data about you only where we have your consent or the processing is in our (or a third party’s, such as our advertiser clients’) legitimate interests and not overridden by your fundamental rights and freedoms. If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to deliver you with ads through our technology (where we do not rely on your consent for such purposes), to measure ad performance, to develop and improve our products, to ensure appropriate security and to prevent and detect fraud in connection with our services. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in Section 12 below. CCPA sale of personal information For the purposes of the CCPA, MediaMath may disclose all of the categories of personal information collected on the Platform to the categories of third parties as described in Section 7 below, for purposes that may be considered a “sale” under the CCPA. We do not sell the personal information of minors under 16 years of age without affirmative authorization. Some web browsers have options that may be characterized as “do not track” settings, which may or may not affect your settings related to our Website. We do not understand them to operate in that manner or to signify a “do not sell” request made by a consumer under the CCPA. We are aware that various parties are developing “do not sell” signals, and we may recognize certain such signals if we conclude that such a program is appropriate and in accordance with the requirements of the CCPA. If you are a California resident and want to exercise your right to opt out of the sale of your personal information, please see complete the Access Request Form available. If you opt out of the sale of your personal information, MediaMath may still process your personal data to show you ads that are not personalised or otherwise provide certain services to advertiser clients that do not involve the sale of personal information under the CCPA. Opt-out and choice mechanisms Opt out of tailored advertising You may opt out from tailored advertising at any time through one of the ways described below. If you opt out of tailored advertising, you will still see ads, but those ads are less likely to have anything to do with products or services you care about. With tailored advertising, you receive ads and offers that are more likely to be useful to you. Your opt-out is only applicable to the Platform and does not opt you out from platforms provided by third-party companies. However, you can opt out from both MediaMath and many third-party companies at once; to do so, please see “Other ways to opt out of tailored advertising” below. When you opt out, MediaMath will collect data from your browser, app, or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, MediaMath also stops sending tailored advertising to the opted-out browser, app, or device. If you use multiple browsers or devices and wish to limit the data that MediaMath collects and do not wish to receive MediaMath tailored advertising on any of them, you must opt out from each browser and device individually. Opt out of tailored advertising in a browser You may opt out if you are using a browser by clicking the “Click here to opt out” link below. Please note that if cookies are not enabled in your browser, including if third-party cookies are disabled, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. If you clear your cookies, or if you use a different browser or device, you will need to renew your opt-out choice. Opt this browser out of tailored advertising (if using a browser) Your current opt-out status with MediaMath in this web browser is: Opt out of tailored advertising in the mobile application environment You may opt out in mobile app environments using the “AppChoices” mobile application, where applicable, which you can download to your mobile device from your App Store or via the DAA AppChoices page here. Other ways to opt out of tailored advertising You may learn more about tailored advertising and opt out of tailored advertising from MediaMath and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links: NAI (browser) – http://optout.networkadvertising.org/ DAA (browser) – http://optout.aboutads.info/ DAA Canada (browser) – http://youradchoices.ca/choices EDAA (browser) – http://www.youronlinechoices.com/ DAA AppChoices page (mobile) – http://www.aboutads.info/appchoices Other ways to limit ad tracking in the mobile and OTT TV device application environment You also may limit ad tracking in mobile app environments on your mobile device as well as on your OTT TV Device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. The NAI provides additional information regarding opting out on mobile available here and TV streaming devices available here. Where MediaMath receives a signal to limit ad tracking, we will collect data from your device only as needed to honor your choice and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your choice. Where MediaMath receives a signal to limit ad tracking, MediaMath also will not serve tailored advertising in the apps on your mobile device or OTT TV Device. 5. The personal data we collect via the Website or offline If you visit our Website or certain third-party marketing applications used by MediaMath or if you interact with MediaMath in other ways described below, MediaMath collects certain personal data from you. This will include personal data you choose to provide to us, and personal data we automatically collect. Third parties may collect personal data from you if you use certain features on the Website. Personal data you provide When you visit the Website, you may choose to provide certain personal data to set up an account, request information such as a demonstration of our products, or send us questions. You also may choose to provide us with your personal data through sources other than the Website, including, for example when you register for or attend an event hosted by MediaMath. The personal data may include your name, email address, company, title, region, and information about your business such as industry, size, revenue, and address. You have the ability to provide additional information at your discretion. You provide us with personal data when you participate in the publicly accessible blogs on our Website. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We do not link the personal data described in this section with personal data that we may have about you in the Platform. Personal data we collect automatically We automatically collect personal data in the form of certain technical information from you when you visit the Website, such as IP address, browser type, Internet Service Provider, referring and exit pages, operating system, date and time stamp, and/or clickstream data. This information is obtained automatically using various technologies including cookies and pixels, and includes the types of personal data described above as Pixel Data. Our partners and subcontractors may also collect personal data, may sync with additional third parties, and may allow third parties with whom they partner to set cookies on the Website. Please note, MediaMath only has control over these partners’ and subcontractors’ use of cookie and Pixel Data to the extent that it allows the cookies and pixels to be set on the Website (which may result in personal data being transmitted to these parties). However, you should refer to the privacy statements of such parties to find out more about their processing of personal data , how they use cookies and how they interact with other third parties. For further information on the cookies and pixels we use on the Website, including a list of the partners and subcontractors described above, and how you can opt out, please see our Cookie Notice. Social media features and widgets The Website includes social media features that allow you to share news, events, and blog posts from the Website on platforms such as Facebook, Twitter, and LinkedIn or by email. If you interact with these features, doing so will result in certain personal data being provided to the relevant third party such as IP address and your browser’s technical information, as well as the URL of the content which you are seeking to share. These social media features are hosted by the third parties providing them, and your interactions with these features are governed by the privacy policies of the company providing them, which you should read and ensure you understand. Testimonials We may display testimonials from satisfied clients on the Website in addition to other endorsements. We will obtain our client’s permission before we place these testimonials on the Website. If you are a client who wishes to update or delete your testimonial, please contact us at privacy@mediamath.com. Legal basis for processing Our legal basis under the GDPR for processing the personal data described in this Section 5 depends on the personal data concerned and the specific context in which we collect it. However, we will normally collect your personal data only where the processing is in our legitimate interests and not overridden by your fundamental rights and freedoms, or where we have your consent to do so. If we collect and use your personal data in reliance on our legitimate interests, this interest will normally be to operate the Website, to communicate with you, to send you marketing communications (unless we are required to obtain your permission in accordance with applicable law), to show you ads on Digital Properties. (where we do not rely on your consent for such purposes) and in general to promote MediaMath goods and services. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are. Our legal basis for processing Pixel Data is as described in Section 4. In some cases, we also may have a legal obligation to collect personal data from you. If we ask you to provide personal data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Where we are required by applicable law to obtain your consent, for instance (in some cases) in order to send you marketing communications, we will do so. In such cases the legal basis for our processing of personal data will be your consent. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading above. 6. How we use personal data collected via our Website or offline Personal data you provide When you provide your personal data to MediaMath on the Website or through other means described in this section, we use the data for the following business and commercial purposes: To respond to your inquiry; To understand your business and offer you potential business opportunities; To know or infer your interest in marketing products and services; To enrich certain personal data you provide, for example your company information with information obtained from third parties; To segment (group) you with similar individuals; To provide you with information and offers about MediaMath products and services, information resources (e.g. whitepapers, reports and webinars), industry news and opinions, and announcements about MediaMath; To inform you about and invite you to events, educational opportunities, or training opportunities; To ask you to share MediaMath information, offers, and invitations with other people; To attribute your responses or actions to specific marketing campaigns, activities, and channels; To troubleshoot and for security purposes You may choose to stop receiving marketing communications at any time by following the unsubscribe instructions included in any marketing communications we send you or by completing an opt out request using the form available. Personal data we collect automatically We use the Pixel Data that we collect from you on the Website for the purposes described in Section 4 as well as to determine how you found out about us, what your interests are regarding our services, how to further improve the functionality of the Website and our service towards you, and to analyze trends and administer the Website. For example, we may use Pixel Data that we collect from you on the Website to deliver ads to you when you visit other Digital Properties, and we may collect additional personal data from you on those Digital Properties, such as Bid Request Data or Impression Data. For further information on the cookies and pixels we use on the Website and how you can opt out, please see our Cookie Notice. 7. Our disclosure of personal data from the Platform or Website We disclose the following categories of personal data to the following categories of third parties for the business and commercial purposes set out above in Section 4 and Section 6: To our affiliates in connection with our business operations that are based in our regional offices in the UK, Spain, France, Germany, Singapore, Brazil, Japan, Mexico and Australia: MediaMath ID; Pixel Data and Other Client Data; Bid Request and Impression Data; and Third-Party Segment Data and Other Third-Party Data. To our clients and resellers in connection with providing them with our digital advertising media and data management services and products: MediaMath ID; Pixel Data and Other Client Data; Bid Request and Impression Data; and Third-Party Segment Data and Other Third-Party Data. At our clients’ direction, we disclose client Pixel Data and Other Client Data to the third parties that they designate. To our audience partners in connection with creating custom advertiser client Segments based on advertiser client-supplied seed data (i.e. data about the advertiser client’s existing customers) or other data: MediaMath ID; Pixel Data and Other Client Data; Third-Party Segments; and Impression Data. To a limited number of audience partners in connection with audience creation or modelling: Bid Request Data To our Cookie Sync partners in connection with synchronizing MediaMath cookie IDs with third-party partners’ IDs: MediaMath IDs; Pixel Data; Impression Data; and Other Third-Party Data (specifically third-party IDs), To a number of parties (referred to in this Policy as subcontractors) that help us provide the services requested by our clients. These subcontractors provide the following services: measurement; viewability; location-based attribution and location-based targeting providers; dynamic creative optimization; attribution; fraud detection and prevention; providing mechanisms to honor user choices; infrastructure; storage; computing delivering content; and analyzing supply inventory and reporting; operation of our Website, including services provided in connection with the Website including email services, event management, maintenance of our marketing database, web analytics, recruitment, management of marketing and customer relationship and social media. We disclose personal data to third parties such as competent law enforcement bodies, regulatory authorities, government agency, court, advisor or other such third parties, where we consider this to be necessary or where we are under a duty to do so: (i) to establish or protect the legal rights of MediaMath or its employees, agents and contractors, as well as the legal rights of its advertiser clients, partners or other third parties; (ii) to protect the safety and security of users and visitors to our Website; to protect against fraud; or (iii) to comply with the law or legal process. We disclose personal data to an actual or potential buyer (and its agents and advisors) in connection with any actual or proposed purchase, merger or acquisition of all or any part of MediaMath’s business. 8. International transfers of personal data The personal data that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the United States, which may not offer the same level of protection of personal data as your country of residence. However, we will take contractual and/or other measures to ensure your personal data is protected. For individuals in the EEA, UK and Switzerland MediaMath has its headquarters in the United States and many of our partners or vendors are based outside of the EEA, UK and Switzerland. Whenever we transfer your personal data out of the EEA, UK and/or Switzerland, we ensure that it receives a similar degree of protection by entering into the Standard Contractual Clauses approved by the European Commission (and/or the applicable UK and/or Swiss authority) with our group companies and applicable partners or vendors. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Notwithstanding the invalidation of the Privacy Shield Frameworks as mechanisms for the lawful transfer of data out of the EU and Switzerland (as applicable), MediaMath, Inc., in addition to entering into the Standard Contractual Clauses referred to above, continues to comply with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU, the United Kingdom and Switzerland to the United States, respectively. MediaMath, Inc. has certified to the Department of Commerce that for all personal data it receives from the EU, the United Kingdom and Switzerland, it will adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To find out more about the Privacy Shield, access the Privacy Shield List, and find details of our certification, please visit: https://www.privacyshield.gov/list. Under the Privacy Shield, MediaMath, Inc. may remain liable if its subcontractors process your personal data in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. Individuals in the EU, UK or Switzerland who believe that their personal data has not been processed in compliance with the Privacy Shield Principles may raise their complaint in the following ways: You can contact MediaMath, Inc. directly using the details in the “How to contact us” section above. We will respond to your complaint within 45 days of receipt. We have further committed to refer unresolved privacy complaints under the Privacy Shield via the Better Business Bureau (“BBB”), an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint directly with the BBB. Further, your complaint can be made or referred to the U.S. Department of Commerce or the Federal Trade Commission for further investigation. For residual disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield. 9. Personal data security and integrity MediaMath implements appropriate technical and organizational measures to safeguard personal data in our possession against being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of MediaMath to intercept or access transmissions or communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any data you transmit to us or that we collect about you. We have procedures in place to address any suspected personal data breach, and if we are required by law, we will notify you of any such breach. MediaMath processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the Website or through the Platform, you can contact us at privacy@mediamath.com. 10. Personal data retention Retention of data collected on the platform As described above, we process your personal data for different purposes, and the length of time that we retain your personal data varies depending on the processing purpose, the category of personal data and certain external factors. We will retain the MediaMath ID and, where applicable, its association with other devices for no longer than thirteen months from the last time we encountered that MediaMath ID on your browser or device. We will retain all other categories of personal data that we collect or receive on the Platform, including Bid Request Data and Impression Data, Pixel Data and Other Client Data, and Third-Party Segment Data and Other Third-Party Data, for no longer than thirteen months. We retain much of this personal data for shorter periods of time. Furthermore, we may delete personal data in response to a request from a user under applicable law, when requested to do so by our clients or when contracts with our clients end. Also, most cookies set via the Platform expire within thirteen months, while certain cookies that are not used for tracking are refreshed for as long as such cookies are necessary for our legitimate business purposes (subject to obtaining any necessary consents). Retention of data collected on the Website and for marketing If you provide us with your personal data on our Website or through other means described above in Section 5, we will retain your information for as long as it is necessary for our legitimate business purposes. For example, if you sign up for an account or request information on the Website, we will retain the data you provide for as long as we think you may have an interest in receiving information from us. Similarly, we retain log files for as long as it is necessary for our legitimate business purposes. We retain the Pixel Data that we collect as described above in the section “Retention of data collected on the Platform”. 11. Your rights MediaMath acknowledges that in some circumstances, you have certain rights under data protection laws in relation to your personal data. Depending on where you are located, which MediaMath entity is the data controller of your data, and where you reside, these may include the right to access your personal data, correct certain personal data, erase your personal data, object to certain processing of your personal data, withdraw your consent to any processing of your personal data carried out on the basis of consent, restrict certain processing of your personal data, receive personal data in portable format, and not be subject to decisions based solely on automated processing. that have legal or similarly significant effects. To the extent required and permitted by applicable law, we will provide you access to the personal data we hold about you and also allow you to correct inaccurate information in certain situations (e.g., if you submit your email address on the Website), honor the withdrawal of your consent to any processing of your personal data carried out on the basis of consent, delete your personal data, honor your objection to processing, restrict certain processing of your personal data, or port your personal data and ensure that you are not subject to decisions based solely on automated processing that have legal or similarly significant effects. If you would like to exercise any of these rights, please complete the Access Request form available. California Privacy Rights California residents have the following CCPA rights, which can be exercised as follows: Right to know about your personal information which we collect, use, disclose and/or sell for the 12-month period prior to the request date. You may ask for information about: the categories of personal information we have collected about you in the prior 12 months, the categories of sources from which your personal information has been collected in the prior 12 months, the business or commercial purpose for collecting or selling your personal information in the prior 12 months, the categories of third parties with whom we share or to whom we have shared or sold your personal information in the prior 12 months the categories of personal information that have been provided to such third parties in the prior 12 months. You may also ask us for a copy of the specific pieces of personal information we have collected about you in the prior 12 months in a machine-readable format. Complete the Access Request form available Call us toll-free at 1-844-966-4636 Right to request deletion of the personal information which we have collected from you, except to the extent we have a basis for retention under the CCPA, Complete the Access Request form available Call us toll-free at 1-844-966-4636 Right to opt out of the sale of your personal information Complete the Access Request form available Call us toll-free at 1-844-966-4636 Right not to receive discriminatory treatment for exercise of CCPA rights MediaMath does not discriminate against you if you choose to exercise your CCPA rights. In order to process your request, we may verify your identity by collecting information from your device (where you submit your request online). You may need to provide additional information about your device to allow us to confirm your identity and the type of personal information we may hold about you. Our Access Request form available has step by step guidance as to how you can make your request, and the information we are required to seek from you. You can designate an authorized agent to submit a request to exercise your above rights by providing such agent with a power of attorney in accordance with California law. If you submit your request through an authorized agent, we may ask for verification that you have authorized the agent to act on your behalf. The information that we may ask to verify your identity (and the identity of the authorized agent) will depend on your prior interactions with us and the sensitivity of the personal information at issue. We do this as a security precaution and to ensure that we do not disclose personal data to or delete the personal data of the wrong person. California Civil Code Section 1798.83 (“Shine the Light“) permits California customers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact details provided below. Please note that “Shine the Light” rights and CCPA rights are established under different legal regimes and must be exercised separately. 12. How to contact us If you have any questions about this Policy, including any request to exercise your legal rights, and/or you have a disability which prevents you from electronically accessing this Policy and require it to be provided in alternative format, please contact us as follows. If you are located in the United States or any other country outside of the EEA or UK: By email to privacy@mediamath.com By post to MediaMath, Inc., Attn: Chief Privacy Officer, 4 World Trade Center, 46th Floor, New York, NY 10007. If you are a California resident inquiring about the CCPA, you can also call our CCPA Helpline, toll free at 1-844-966-4636. If you are located in the EEA or the UK, you can contact our data protection officer who is responsible for overseeing questions in relation to this Policy: By email to privacy@mediamath.com By post to MediaMath UK Ltd, Attn: Data Protection Officer (DPO), 230 Blackfriars Road, London, SE1 8NW If you would like to exercise any of your rights in respect to your personal data, please submit a request using the Access Request form available. We will guide you through that process. You have the right to lodge any complaints you have regarding our processing of your personal data with a regulatory authority. We care about your privacy, and we appreciate the chance to address your concerns before you do so. 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