Our Privacy Commitment

VideoAmp (the “Company,” “we,” “us,” or “our”) is committed to respecting the privacy rights and concerns of individuals in connection with the Company’s www.videoamp.com website, where this Privacy Policy is posted (the “Site”), and the services and the software made available by the Company that enable advertisers and media owners to display targeted advertising across websites, apps, game consoles, Internet-connected TVs, and other devices (the “Company Features”). As such, we have established and implemented this Privacy Policy to inform end users of the websites, apps, and devices on which the Company Features are used (“Users”) and visitors to our Site (our “Customers”) how we collect, use, disclose, and protect the information we collect through the Company Features and/or the Site.

This Privacy Policy answers the following questions:

• How do we collect and use information through the Company Features?
• How do we collect and use information through our Site?
• Will we share information with third parties?
• What choices do you have about the collection, use, and disclosure of information by VideoAmp?
• What security measures do we take to safeguard the information that we collect?
• What other important information should you know?

If you would like to opt out of targeted advertising provided through the Company Features, please see “What Choices Do You Have about the Collection, Use, and Disclosure of Information by VideoAmp?” below.

By visiting the Site or using any of the Company Features, you consent to the Company’s collection, use, storage, deletion, and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Site and the Company Features and not to any other website that you may be able to access from the Site or the Company Features, which may have its own data collection and use practices and policies.

Residents of California should review the privacy notice for the California Consumer Privacy Act of 2018 (CCPA) HERE.

How Do We Collect and Use Information through the Company Features?

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Information We Collect Directly through the Company Features

We collect information directly through the Company Features when Users visit or use websites, apps, and online services, or view our targeted ads from our Customers and partners. The types of information that we collect about Users directly through the Company Features include:

• Internet Protocol (IP) host address;
• Pages viewed;
• Information about apps used;
• Browser type;
• Internet browsing and usage habits;
• Gender;
• Year of birth;
• Internet Service Provider;
• Domain name;
• Time/date of visit to a website, app, or online service where the Company Features are used to deliver ads;
• Whether the individual has responded to one of our Customers’ ads;
• The referring URL;
• Clickstream data;
• Operating system of the User’s computer or device;
• Location information, including from exchanges, which may or may not be precise;
• Platform or operating system device identifiers, such as IDFA for iOS and Advertising ID for Android;
• Device-specific IDs, such as for Internet-connected TVs or online streaming devices;
• Features used or activities engaged in within an app or online service; and
• General location inferred from IP address.

We collect information about Users through cookies and pixel tags when a User visits a website or views an advertisement where the Company Features are used. We also may collect information about Users through application software development kits, server-to-server connections with our Customers or business partners, and batch file transfers, as follows:

• Cookies. “Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. We may place or recognize a cookie on your computer if you visit a website or view an advertisement where the Company Features are used. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the websites you visit may not operate correctly.
• Pixel Tags. “Pixel tags” (also known as “web beacons” or “clear gifs”) are electronic files that usually consist of a single-pixel image and can be embedded in a web page or in an email to transmit information. VideoAmp may use pixel tags to place or recognize a cookie on your computer if you visit a website or view an advertisement where the Company Features are used.
• Application Software Development Kits (SDKs). An application SDK is a set of code that can be embedded directly within an application on a mobile phone, computer, or other device. We may collect information through an SDK that is embedded in our Customers’ apps that use the Company Features.
• Server-to-Server Connections. We may send or receive information from our Customers or business partners through a server-to-server connection. Server-to-server connections allow companies to transfer information directly between each other when it is not feasible or practical to integrate an SDK into an application. In this context, we may send or receive information using a third-party or our own first-party Application Programming Interface “API.”
• Batch File Transfers. We also may use a batch file transfer to send and receive information directly with our business partners.

VideoAmp may receive location information through the Company Features if a third party provides us with such information. We limit the precision of location information used for Interest-Based Advertising, defined below, to two or fewer decimal places in latitude-longitude data (approximately equivalent to the area of a circle with a radius of greater than 500m) or to the city level or a general descriptor of the location (e.g., “Central Park”). VideoAmp does not share location information with unaffiliated third parties.

Information We Receive from Third Parties

We receive additional information about Users from third parties, which we may combine with the information that we collect about Users directly through the Company Features, to enable targeted advertising through the Company Features and/or on our Customers’ websites. For example, we receive information from our TV partners, including comScore Rentrak, that includes aggregated and non-aggregated viewing information for TV customers. Such information can include the identity of your broadcast, cable, or satellite television provider, the television programs and commercials viewed by the aggregated group or a specific device (including time, duration, date, channel, and whether the content was viewed live or at a later time), device identifiers of your TV (such as OEID), and general location information

such as zip code and location information derived from IP address. Information received from other third parties also may include information about Users’ demographics, inferred interests, purchases, and information regarding the probability and nature of connections between Users’ devices (such as smartphones, tablets, computers, game consoles, and Internet-connected TVs). The collection and use of that information is governed by the privacy policies and legal terms of the third parties that collect such information and by our Customers; it is not governed by VideoAmp Inc. We encourage you to review the privacy policies of the third-party websites, mobile applications, TV viewing systems and operating systems, and other online services that you visit.

VideoAmp partners with Oracle/Blue Kai, eXelate, Neustar, LiveRamp/Acxiom, Experian, Lotame, Adobe Audience Manager, and other companies to receive information about non-sensitive health and wellness categories.

How We Use Information Collected through the Company Features

We use information that we collect about Users through the Company Features to provide targeted advertising, analytics, and reporting services. This advertising may be customized based on a User’s activities across unaffiliated websites, apps, Internet-connected TVs, and other online services (advertising based on such information is known as “Interest-Based Advertising”) and inferences that we make based on information about you or other Users like you. In particular, we use information about Users:

• To establish connections among related web browsers and devices (such as smartphones, tablets, computers, game consoles, and Internet-connected TVs) for targeted advertising, analytics, and reporting purposes (“Cross-Device Linking”). For example, we may match a User’s browsers or devices if the User’s devices share similar attributes that support an inference that they are used by the same person or household. This means that information about a User’s activity on websites, apps, or online services on the User’s current browser or device may be combined and used with information collected from the User’s other browsers or devices. We may share device identifiers (such as cookie IDs, IDFA for iOS, Advertising ID for Android, and OEID for other online platforms and Internet-connected TVs) with our third-party service providers to help establish such connections;
• To infer a particular User’s interests based on the User’s online activities over time and across unaffiliated websites, apps, Internet-connected TVs and other online services, including a User’s viewing behavior on Internet-connected TVs. For example, we may use information about the shows or commercials you may have watched on your TV, based on your device ID, to deliver more relevant advertisements to you in web browsers on your computer or mobile devices or in apps on your mobile devices;
• To deliver Interest-Based Advertising using established device connections and inferred interests, such as to deliver an ad to a User on a site, app, Internet-connected TV, or other online service based on the User’s activities on an unaffiliated website, app, Internet-connected TV, or other online service, either on the User’s current device or on other devices that are linked to a User’s current device;
• To provide ad delivery and reporting services to our Customers, such as logging of page views or the collection of other data about a computer or device for the purpose of delivering ads or providing advertising-related services, including, but not limited to: providing a specific advertisement based on a particular type of browser or time of day, statistical reporting in connection with the activity on a website, app, or online service, analytics and analysis, optimization of location of ad placement, ad performance, reach and frequency metrics (e.g., frequency capping), security and fraud prevention, billing, and logging the number and type of ads served on a particular day to a particular website, app, or online service;
• To engage in operations and system management, including intellectual property protection, compliance, public purposes and consumer safety, authentication, verification, fraud prevention and security, and billing or product or service fulfillment, including improving Customer experience or ensuring a high quality of service; and
• To engage in market research (such as the analysis of market segmentation or trends, consumer preferences and behaviors, research about consumers, products, or services, or the effectiveness of marketing or advertising) or product development (such as the analysis of the characteristics of a market or group of consumers or the performance of a product, service, or feature, in order to improve existing products or services or to develop new products or services).

How Do We Collect and Use Information through Our Site?

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Information We Collect through Our Site

Through our website, we collect information about our Customers that can be used to identify and contact them (“Personal Information”). Customers need to submit Personal Information to access certain areas of the Site and the Company Features. We collect Personal Information when Customers:

• Create an account through the Company Features. For example, we require Customers to provide certain information to create their profiles, including the Customer’s name, email address, phone number, and any password that the Customer creates;
• Provide billing address and credit card or other payment information when registering for certain services that require this type of information;
• Receive customer or technical support;
• Submit links to video or other content with respect to the Customer’s use of the Company Features; and
• Use our services. For example, we will record information about your use of our Site and Company Features, including how and where you use our Site and Company Features.

We and our third-party service providers also collect information that is not Personal Information (“Other Information”) automatically when Customers visit the Site or use the Company Features. This information may include the Customer’s IP address, the browser type and version, the search engine the Customer used to find the Site or Company Features, if any, which Company Features the Customer uses, and when and how long it uses them. We use this information to monitor and analyze how our Customers use the Company Features, to provide customer service, and to maintain and improve the Company Features.

We and our third-party service providers may collect such Other Information using cookies and pixel tags, which are described above. Like many websites, we may employ cookies in certain areas of the Site to allow us to provide information to make our Customers’ online experience more convenient. We also may include pixel tags on the Site or in the emails that we send to Customers to determine whether a Customer has opened a particular email or used a particular area of the Site or Company Features. In addition, our servers automatically record information that a Customer’s browser sends whenever a Customer visits the Site, including the Other Information listed above.

How We Use Information Collected through Our Website

We use information that we collect through our website:

• To fulfill the terms of any agreement a Customer has with us and complete transactions that a Customer initiates;
• To send administrative messages about the Company Features and other general announcements, to respond to Customer requests to perform an activity in connection with a Customer’s use of any of the Company Features, or otherwise to contact Customers when necessary;
• To send promotional emails that will alert Customers of new services, features, or enhancements to the Company Features. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by following the “unsubscribe” instructions included at the bottom of each commercial email message;
• To request feedback and handle customer service questions or issues;
• To keep track of our Customers’ interactions with us, including but not limited to their activity within the Company Features, and to improve our Customers’ user experience and the quality of the Company Features;
• To analyze information in aggregate form or where the data has or will within a reasonable period of time from collection go through a de-identification process involving reasonable steps to ensure that the data cannot reasonably be re-associated or connected to an individual or be connected to or associated with a particular computer or device (“De-Identified Data”). For example, we may use Personal Information with Other Information that we have collected in a manner such that the end-product does not personally identify any Customer. We may alter Personal Information to make it Other Information by either combining it with information about other Customers (aggregating Personal Information with information about other Customers), or by removing characteristics (such as a Customer’s name or email address) that make the information personally identifiable; and
• For internal purposes such as administering the Site and Company Features, improving and customizing the Site and Company Features, helping us understand and analyze how the Site and Company Features are being used, tracking aggregate usage of the Site and Company Features, and creating new products and services or improving existing products or services.
• To perform analytics on our Site. For example, we use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
• We may use information collected to reach site visitors elsewhere on the internet with targeted advertising (IBA), such as retargeting. To opt-out please visit www.aboutads.info/choices.

Will We Share Information with Third Parties?

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Sharing of Information

We may share the information that we collect with third parties under the following circumstances:

• Service Providers and business partners. We may share Personal and Other Information with carefully selected service providers and business partners, including companies that perform marketing services and other business operations for us. We engage these companies for the purpose of processing information on our and our Customers’ behalf. For example, we may partner with other companies to process payments for the Company Features. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, De-Identified Data. While providing services for us, these companies may access Personal Information about our Customers.
• Aggregate information. We may also use Personal and Other Information to provide analysis of our Customers or Users in the aggregate (including the De-Identified Data subject to the terms of this Privacy Policy), which we may disclose to prospective partners and other third parties.
• Video content. We share the links to video content uploaded by our Customers with our publisher network.
• Protection of rights and other legal purposes. We will use and share Personal and Other Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the Company Features, including any investigation of potential violations thereof, or defend against legal claims, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Company Features, or (iv) such action is appropriate to protect the rights, property or safety of the Company, its employees, Customers, or others.
• Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of the Company’s assets, information that we collect, including Personal Information collected from our Customers through their use of the Company Features, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify our Customers through email and/or a prominent notice on the Site.

Additional Information You Should Know About Third Parties

This Privacy Policy does not cover the information practices of third-party websites linked to the Site or accessible through the Company Features. This Privacy Policy also does not cover the websites of our publisher network where our Customers’ links to video content will be posted. We are not responsible for their collection and use of our Customers’ Personal Information. Customers should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use, and disclosure policies.

When you have clicked on a third-party logo or URL displayed on our Site or accessible through the Company Features which links you to a different website, our Privacy Policy no longer applies and you must read the privacy policy of the third party to see how your Personal Information will be handled on their website.

What Choices Do You Have about the Collection, Use, and Disclosure of Information by VideoAmp?

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User Opt-Out

Users may “opt out” ofVideoAmp’s targeted advertising, including the use of information for Interest-Based Advertising and Cross-Device Linking, by following the instructions below for opting out in web browsers, mobile applications, and other online services. Please note the following when opting out:

• VideoAmp uses a third party service provider to deliver certain data collection     functionalities on VideoAmp’s behalf. An opt out that is separate and in addition to the opt out for VideoAmp’s own data collection applies to this third party service provider data collection as further described below,
• The opt-outs will apply to the specific browser or device from which you opt out, and     therefore you will need to opt out separately for each hardware device and web browser software you use and on which you want to be opted out.
• Opting out of Interest-Based Advertising does not block advertisements from displaying on websites, apps, or online services you visit; opting out will only stop advertisements tailored to your interests.
• Opting out in web browsers requires a cookie to be placed in your browser so that we     know that you have chosen to opt out of this service. This cookie must exist for the entire duration in which you wish to be opted out. Clearing this cookie from your browser or preventing the ability for the cookie to be created will opt you in for Interest-Based Advertising. For a more persistent opt-out, please use the DAA’s “Protect My Choices” tool available at http://www.aboutads.info/PMC.

Opt Out in Web Browsers

If you would like to opt out in web browsers, please click one or both of the “Opt Out” options below. Note that opting out to one will not opt you out to the other:‍