About Our Business

ClickNetVenue.com Advertising FZ-LLC, including our affiliates and subsidiaries, (individually and/or collectively, "ClickNetVenue.com," "we," "us" or "our") utilizes its digital advertising technology platforms (our "Technology") to display targeted advertising (our "Services") on behalf of the advertisers and ad partners (collectively "Buyers") on websites and properties (collectively "Seller Sites") owned and/or operated by entities (collectively "Sellers") that participate in our advertising marketplace.

When Does this Privacy Policy Apply?

This Privacy Policy applies:

• When we collect information about consumers and other end users who interact with our Services and Technology on Seller Sites. Buyers and Sellers may be referred to as Partners. Click here to learn more.
• When our Buyers, Sellers, potential Buyers and potential Sellers or other end users interact with our website located at sites (our "Website"). Click here to learn more.

CONSUMERS AND SELLERS IN CALIFORNIA CAN CLICK HERE FOR MORE INFORMATION ABOUT THEIR PRIVACY RIGHTS.

IF YOU ARE SITUATED IN THE EU OR UK, CLICK HERE FOR MORE INFORMATION ABOUT YOUR RIGHTS UNDER EU/UK LAW.

I. Privacy Practices for End Users.

A. Information We Collect.

The Technology we use to provide our Services collects information from end users who visit one or more Seller Sites and/or our Website. While this information does not enable us to directly identify you (e.g., we do not receive your name, email address, etc.) but it may be considered "personal data" or "personal information" under applicable privacy or data protection laws.

The information we may collect includes:

• Online Identifiers. This includes your IP address, device IDs, cookie identifiers, advertising identifiers (IDFA and Google AdID), and other mobile identifiers.
• Seller Site Information. This includes the web page URL or application through which you are viewing content, referrers viewability data, contextual categories, attributes pertaining to ad formats, click data, types of advertisements viewed and other data that the Seller Sites make available to us.
• Device Information. It includes your browser, device model, device operating system, browser language and device type.
• Location Information. It includes non-precise location information (city, country, zip code) but may also include precise location information if you have actively enabled location services on your device or a Seller partner sends it to us in their bid request (only in case of an opt-in).
• Website Usage Data. This includes information about how you use our Website such as web page interactions, time spent on our pages and referral web pages.

Information we receive from third parties: We may also receive information from third parties at the instruction or for the benefit of our Seller Sites that provide user demographics, behaviors or interests, obfuscated user identifiers such as hashed email addresses, user preferences on the ad experience and other information that may help make the ads more relevant.

Cookies. We use cookies, web beacons, mobile SDKs and other web tools ("Tools") to collect information regarding your behavior and usage patterns on our Website and on our Seller Sites. We use these Tools:

• For Frequency Capping. To inform us if an advertisement has been served to the same computer before, and if so, when the advertisement was served.
• For Research and Fraud Prevention. To conduct research and identify fraud and malicious activity.
• For our Services. When you visit one of our Seller Sites, we may assign your computer one or more cookies which enable us and our Buyers to deliver targeted advertisements to you on the Seller Sites. This form of advertising is called "behavioral advertising" or "interest-based advertising". We use cookies (e.g., Google's advertising cookies) for this purpose. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the section titled "Your Choices" below.

Further, while our Technology does not deliver targeted ads based on precise medical conditions or treatments or market prescription drugs, we generate and serve ads for non-sensitive health-related advertising segments that may be of interest to End Users: diet and fitness; doctors; health care professionals; health conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy and in some cases health advertising that is based on the content of the page on which such ads appear (e.g., we may include an ad for a dietary supplement that complements an article regarding weight loss).

B. How Do We Use Your Information?

We use your information in the following ways:

• Click Fraud Monitoring. We collect information related to clicks, views, impressions, robotic mouse movement, non-human clicks, etc. and use it for fraud detection purposes.
• Selecting and Serving Targeted Advertising. We use information about you to select and serve advertising on our Publisher Sites. We present advertisements tailored to interests you have shown; inferring eligibility of users for interest, geographic and demographic-based segments; creating online advertising models through lookalike modelling or similar research methodologies.
• Improving our Services. We combine information we collect from consumers with information we obtain from our Partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our services, conduct internal analysis in order to perform and improve our services.
• Analytics. Providing insights and reporting back to our Partners, including statistical reporting in connection with the activity on a website or mobile application, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application; evaluating the probability and nature of connections between devices.
• Frequency Capping. Determining whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements.
• Data Privacy. We respond to data privacy questionnaires, data subject access requests (DSAR).

C. Who Do We Share Your Information With? Subject to the section titled "Additional EU/UK Disclosures", we may share the information we collect about you with certain third parties in the following ways:

• Service Providers. We may, from time to time, use third party vendors, operational service providers and subcontractors ("Service Providers") to operate and provide our services to Partners and to comply with legal and regulatory requirements. As necessary under this Privacy Policy, our Service Providers are required to protect the information we provide to them in a manner that is consistent with this Privacy Policy. The services provided by Service Providers include attribution, analytics, billing, fraud prevention, management of leads/campaigns, dispute resolution, cloud hosting, and technical support.
• Buyers. We may share your information with Buyers to help them make decisions regarding buying advertising inventory on Publisher Sites or to analyze the effectiveness and performance of advertising campaigns via our Services, explore business opportunities, and perform audits/research.
• Sellers. We share information with our Sellers when we deliver ads on their Seller Sites. Sellers may use your information to make inferences about your preferences in order to serve more relevant advertising to you.
• Legal, Government Contacts. We provide information to third parties for legal process (e.g., in response to a subpoena or civil or criminal investigative demand, court order, or a request from law enforcement or other government agency); to establish or exercise our legal rights; to defend against legal claims; to protect the security and integrity of our assets and business operations; or as otherwise required by law. In addition, we may disclose your information when we believe it is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of ClickNetVenue.com, our Partners, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce the terms of service of our Website or other agreements or policies.
• Acquisitions & Other Corporate Partners. We may also provide information to third parties in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We may aggregate data so that it is no longer identifiable. That data may be shared with third parties for their business purposes. In addition to the foregoing, we may share your information with anyone provided we have your express consent.

II. Privacy Practices for Partners.

A. Information We Collect. You may be asked to provide information to us when you ask for information about our Services, or when you register to participate in ClickNetVenue.com's program for use of ClickNetVenue.com Technology. Information you may be asked to provide includes:

• Contact information, which includes name, email and mailing address, and other information you may provide that allows us to contact you.
• Government Identifiers, which include your driver's license number or other identifiers.
• Financial Information, which includes your bank account and other payment information required to collect or receive payments from you.
• Online Identifiers, which includes your IP address, device IDS, cookie identifiers, and lo-information.
• Device Information, which includes your browser and device type.
• Location information, which you may provide to us or we may generate based on your IP address.
• Usage Data, which includes your browsing or search history, web page interactions, referral web page, as well as information about how you use our Website.

Cookies. We use cookies, web beacons, and other web tools ("Tools") to collect information regarding your behavior and usage patterns on our Website, on our mobile applications (to the extent downloaded to your mobile device). We may use Tools to help our Website function, to analyze your use of our Website and/or reporting of our Services, and to understand our Website visitors and how the Website may be improved.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them.

B. How Do We Use Your Information? We do not sell your personal information. We use your information in the following ways:

• Customer Service. We respond to general customer inquiries, troubleshoot technical challenges, up-sell, cross-sell, and provide payment payout support.
• Marketing. We analyze publisher signups, affiliate signups, webinar signups and support the sales team. We may partner with third parties to collect information on our Website to deliver advertising that we believe may interest you based on your activity on the Websites. These third parties may set and access cookies on your computer or other device and may also use pixel tags, web logs, web beacons, or other similar technologies.
• Providing our Services. We combine information we collect from consumers with information we obtain from our Partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our services, conduct internal analysis in order to perform and improve our services.
• Compliance/Security. We verify signups through searching publisher email addresses through social media, perform website whois lookup to discover the domain name registration details, review IP addresses location. We also review the quality of traffic on publisher websites. We review personal data protection online and offline threats on our infrastructure, network, networking equipment, computer systems, computer software, applications installed on the servers, access management, and mitigate the risks.
• Data Privacy. We respond to data privacy questionnaires, data subject access requests (DSAR).
• Legal Obligations. We may use your information to comply with our legal obligations, including responding to requests from law enforcement; enforcing our terms and conditions and other legal rights; to protect our company and our employees, and to prevent or address suspicious, or potential illegal activity.

C. Who Do We Share Your Information With? Subject to the section titled "Additional EU/UK Disclosures", we may share the information we collect from and about you with certain third parties in the following ways:

• Service Providers. We may, from time to time, use Partners, operational service providers and subcontractors ("Service Providers") to operate and provide our services to Partners and to comply with legal and regulatory requirements. As necessary under this Privacy Policy, our Service Providers are required to protect the information we provide them in a manner that is consistent with this Privacy Policy. Service Providers include fraud prevention service providers and cloud hosting service providers.
• Legal, Government Contacts. We provide information to third parties for legal process (e.g., in response to a subpoena or civil or criminal investigative demand, court order, or a request from law enforcement or other government agency); to establish or exercise our legal rights; to defend against legal claims; to protect the security and integrity of our assets and business operations; or as otherwise required by law. In addition, we may disclose your information when we believe it is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of ClickNetVenue.com, our Partners, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce the terms of service of our Website or other agreements or policies.
• Acquisitions & Other Corporate Partners. We may also provide information to third parties in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We may aggregate data so that it is no longer identifiable. That data may be shared with third parties for their business purposes.

III. Your Choices. Your browser may give you the ability to adjust your settings to delete or disable cookies. Some mobile devices enable you to turn off or reset the mobile ad identifier. To opt out using these mechanisms, consult your device settings ("Opt out of Personalized Ads" on Android devices and "Limit Ad Tracking" on iOS devices).

IV. Rights for California Consumers. The terms "Business Purpose(s)", "Personal Information", "Sell" (or "Sale"), "Service Provider(s)" and "Third Parties" have the meanings given in the California Consumer Privacy Act of 2018 ("CCPA"). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers.

A. Collection of Personal Information.

• Categories of Personal Information Collected. Unique device identifiers such as Cookies, Mobile Ad IDs (IDFAs for iOS and Android Ad IDs), Timestamps, User Agent Strings, IP addresses; General location data that is no more specific than a postal code, and web addresses (also known as "URLs"); Precise Location Information; Internet Activity Information, such as the website URL or mobile app you are browsing, web pages, content, and advertisements you view and links you click on, and whether you open, forward, or click the links in emails we send to you; and your browsing history. For our Partners, we collect: Identifiers such as your name, IP address, email address, and other account information, Unique Device Identifiers, Professional or employment-related information, Internet or other network activity, and Geolocation Information.
• How Do We Use Personal Information. We use personal information to deliver and measure online advertising. For our Partners, we use personal information to market and provide our Services to you.
• Categories of Sources from which Personal Information is Collected. Websites, mobile applications, advertising services, technology platforms. For our Partners, we collect information from you directly and from your use of our Website and mobile applications.

B. Sharing of Personal Information. We share information as described above. This section discusses when we sell information, as that term is used in the CCPA. For our Partners, we do not sell your personal information.

• Categories of Personal Information Sold. Identifiers and inferences about website visitors.
• Purposes for Selling Personal Information. This data is used by our Advertisers and Partners for more tailored advertising, marketing, measurement, analytics, and research.
• Categories of Third Parties to whom Personal Information is Sold. Advertisers, advertising agencies, marketers, technology platforms, and market research firms.
• Categories of Third Parties to whom Personal Information was Shared for a Business Purpose. Advertisers, advertising agencies, marketers, technology platforms, and market research firms.

C. California Consumer Rights & Options. You have the right to access or delete Your Personal Information. You have the right to be free from discrimination as a result of exercising these rights. You can opt out of sales or exercise your "Do Not Sell My Personal Information" right via ClickNetVenue.com's opt-out tool here. We may set a non-unique cookie for the sole purpose of implementing such opt-out request. If you opt-out, you should not delete your cookies. If you delete your cookies after opting out, you will need to opt-out again. Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you need to provide us with some additional information to enable us to identify the information we hold about you, if any, to verify your identity and to ensure that we accurately fulfill your request. If an authorized agent submits a request on your behalf, we may require that the authorized agent provide written proof of their authority and we may separately verify your identity and confirm your request with you. If you have any questions about your rights or our disclosures, please contact our privacy officer per the details listed in the section titled "Contact Us" below.

V. Additional EU/UK Disclosures

A. Data controller. We are a data controller of all Personal Information collected through our Website. If you have a complaint, please contact our privacy officer per the details listed in the section titled "Contact Us" below.

B. Legal Basis for our Processing of Your Personal Information. Below are the types of lawful basis that we will rely on to process your Personal Information:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We also do not use your Personal Information where such interests are overridden by your data-protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your User Information, they include the interests described in the section headed "How Do We Use Your Information. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contact us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation that we are subject.
• Consent means where you have consented to a certain use of your Personal Information.

C. Sharing of Personal Information. We share information as described above.

D. Additional EU/UK Privacy Rights. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. You have the right to request that we correct or erase your personal information. You also have the right to object to processing and to object to automated decision-making with significant or legal effects. You can exercise your rights at any time by contact us.

E. Modifications to this Privacy Policy. We may edit, amend, modify, and update our Privacy Policy at any time and from time to time, by posting updated text on or links to our Website. When we make material changes to our Privacy Policies or our privacy practices, we will notify you by posting a notice on our Website or providing a notice to you. We display the Effective Date at the top of our Privacy Policy so that you will know when there has been a change in its effective date. By using our Website or our Technology or any Publisher Site using our Technology after the effective date, you will have agreed and be deemed to have agreed to comply with and be legally bound by the updated Privacy Policies.

F. Cross border transfers. Our Website and technology infrastructure is primarily maintained in the United States. If you are visiting our Website or Publisher Sites from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this Privacy Policy. If you are situated in the EU/UK, whenever we transfer your Personal Data out of the EU/UK, we ensure appropriate and suitable safeguards are used in such transfer. Where we use certain service providers, we may use specific contracts including data processing agreements based on the EU/EEA Standard Contractual Clauses.

VI. Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (e.g.,social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through our Website, or our Services or otherwise to us.

VII. Third Party Practices. This Privacy Policy applies solely to our privacy practices. We are not responsible for the privacy practices of our Partners, Service Providers or any third parties, even if our ads contain links to third party websites and even if we have a business relationship with that third party. We encourage you to review the privacy statements of each and every website that you visit to be sure you understand the terms and conditions that apply to you from each of them.

VIII. Data Retention. We will only retain information relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for such information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless contrary to applicable laws, except with respect to information about our Partners with whom we have an ongoing relationship, our policy is to retain the non-aggregated information we collect for up to 24 months, after which the data is either anonymized or deleted from our systems. And as permitted by law, we may continue to retain aggregated information. We use commercially reasonable procedures to protect the personal information that we collect. However, we cannot guarantee the security of our databases, nor can we guarantee that personal information you supply won't be intercepted while being transmitted to us over the internet.

IX. Children. Our Website is intended for an audience above the age of 18. Neither our Website nor our Technology / advertising services are developed for, intended for, or directed at, children, and we do not knowingly collect information about children under the age of 16 (or such other age as may be restricted under local law). If you believe your child has provided his or her information to us, please contact us.

X. Contact Us. If you have any questions relating to this Privacy Policy, please contact us or mail us at:

Privacy Officer
ClickNetVenue.com
United States