IDENTIFIER	DESCRIPTION	USED BY
Cookie ID	A randomly generated identifier (including those created by Whildey) that is stored on a browser and allows us to understand User browsing behavior, without knowing the exact identity of the individual. Also known as a third-party cookie.	All Services and Site
Device information	Device information can include your browser agent, browser type, operating system, device type, use of ad blocking tools, and information about the possible relationships among different browsers and devices.	All Services and Site
IP address	An Internet Protocol address (IP address) is a numerical label assigned by an Internet Service Provider (ISP) to each device connected to a computer network that allows the device to communicate on the Internet. Most IP addresses are dynamic, meaning they change every time the device is restarted. IP addresses allow us to infer your general location in order to help us understand your data rights.	All Services and Site
Mobile advertising ID	Mobile advertising IDs are provided by the mobile device's operating system, and can be reset by users. Typical advertising IDs are AAID/GAID (Android) and IDFA (Apple). Mobile advertising IDs allow developers and marketers to track activity associated with a specific device for targeted advertising purposes.	Exchange
Personally Identifiable Information ("PII")	Personal Information that directly identifies an individual such as name, surname and email address. PII may be required for some inquiries through the Site. Whildey will only collect PII you voluntarily provide.	Site

How We Collect Information

Whildey uses various technologies to collect both Personal- and Non-Personal Information, such as cookies, web beacons, tracking pixels, or scripts. We also collect information voluntarily provided through our Site. The term 'cookies' is used as an umbrella term for these technologies; for convenience, these technologies are collectively referred to in this Privacy Policy as "cookies."

Both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted or expire) are used to collect viewing and search behaviors by both Whildey Services and the Site.

Through our Site

We collect Personal Information submitted to us voluntarily, such as name and contact information. For example, when signing up to receive our newsletter or to participate in a webinar we collect your email address. When contacting us via email, we will collect the email contents.

Through Whildey Services

The information we gather about browsing preferences and purchasing behaviors using cookies helps us provide Whildey Services to our Publishers, which in turn provides meaningful Interest-based Advertising to Users.

• Users. We set cookies (where allowed) at the first visit to any of the Publisher properties that deploy Whildey Services. If our cookie is already set on a browser, we recognize a returning User and log data using the existing cookie. Users have the option to use tools provided by browsers to decline to receive cookies or to clear cookies, which will result in us treating the User as a new visitor when encountering Whildey Services. However, in order to stop Interest-based Advertising by Whildey, individuals must explicitly opt-out as described in the "How to Opt-Out" section.

  Some of our business partners (for example, Google Analytics) may set or use their own cookies on our Publisher properties or through Whildey Services where Whildey has no access to or control over these cookies. Specific to Google Analytics, opt-out by visiting https://tools.google.com/dlpage/gaoptout/

• Publishers. Publishers provide Personal Information about themselves when registering to use Whildey Services. Personal Information collected at registration may include: a valid email address, username and password, first and last name, telephone number, website(s) URLs, software, mobile applications, log-in IP address(es), physical address, ZIP code, and country of residence for the Publisher contact.

  When using the Whildey Platform to manage your account, we will also set cookies that allow us to remember your preferences, as well as to collect analytics about how our customers are interacting with the service.

  We collect Publisher payment information from those who purchase Whildey Services.

  Publishers may choose not to provide us with certain Personal Information, but this may limit the features of the Whildey Services available for use.

Through Internet-Connected Technology

As Publishers use the Whildey Services or Users access or use digital properties within the Whildey Publisher network (including websites or applications on internet-connected technology, such as computers, mobile devices), we may also collect web viewing and search activities across non-affiliated websites and mobile applications ("apps") over time. This information may be linked to Personal Information that identifies a browser or device, typically through cookies or tracking pixels/web beacons.

Whildey may store cookies on your device in order to:

• For Publishers, to allow you to use and access secure areas of Whildey Services. Without these cookies, it may not be possible to load or offer key functionalities, such as logging in to your account, displaying dynamic elements or uploading information.
• For both Publishers and Users, for statistical purposes and to analyze and improve the use and performance of Whildey and the Site, and to do the same for our Publishers' websites. We also use cookies for a better online experience, as cookies allow us to load or offer key functionalities on our Site, such as displaying dynamic elements or uploading information.
• For Users, to support Whildey Services, such as for our analytics and data services and to provide Users with Interest-based Advertising and the ability to opt out of such advertising, all as further described in this Privacy Policy. We also use cookies for social media and multimedia functionalities, where videos and other media often rely on cookies to function correctly. In addition, social media platforms such as Facebook and X can use cookies to see if you are logged in and enable you to "like" content or send it to your friends. When you use these features, such third-party companies can collect information from you. Depending on your settings, these external parties may also use such information for advertising purposes. If you would like to know more about this, please refer to the respective privacy policies of these third parties.

We may also use web beacons or "pixels" to collect Personal Information, which are electronic images that may be used on website(s) (including Publisher websites and the Site) or in emails sent in Publisher campaigns or from Whildey directly. We use tracking pixels to, for example, collect hashed emails, sync unique online identifiers, deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether an email has been opened and acted upon.

Information from Third-Party Sources

We may receive Personal- and Non-Personal Information about you from other sources and combine it with the information that we collect through Whildey Services or the Site. Sources may include information conveyed to us by telephone, information that we receive from third-party data providers, or information provided to us by third parties through the Whildey Publisher network.

How We Use Information

We use Personal- and Non-Personal Information to support our commercial interests (Interest-based Advertising, affiliate network marketing, and Data), internal business operations (such as improving the Services, fraud prevention and security), and business intelligence.

Commercial Interests

Commercial interests are activities that allow Whildey and/or our customers and business partners (such partners include data services and data resellers) to earn revenue and include, for example:

• Serving Interest-based Advertising to Readers on behalf of our Publishers and supporting third parties' Interest-Based Advertising activities. Options for opting-out of such advertising may be found in the " How to Opt-Out" section of this Privacy Policy.
• Providing Whildey Services, or any other materials requested through the Site (such as electronic newsletters or promotional emails) to Publishers. Options for opting-out of Whildey marketing may be found in the " How to Opt-Out" section of this Privacy Policy.

Internal Business Operations

Internal business operations are activities that allow us to meet obligations to Publishers, Users, and third-party partners (including regulatory bodies). Internal business operations do not directly benefit any one person or entity, and include, for example:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with various data privacy laws and regulations, as well as other standards.
• Debugging to identify and repair errors that impair existing intended functionality of our products, content, services and websites.
• Improve and protect our products, content, services and websites, to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying Publisher information, processing payments, or providing analytic services.
• Monitoring any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
• Compliance with applicable laws and to protect Whildey's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with law enforcement requests, legal process or litigation), protecting our and others' rights, privacy, safety, or property, and enforcing our agreements.
• Responding to comments or complaints or sending service-related communications.

Business Intelligence

Business intelligence allows us to analyze and report on the performance of Whildey Services and the Site, as that performance relates to Publisher or Whildey campaigns, and includes:

• Monitoring the use of Whildey Services to support Publisher analytics and reporting.
• Undertaking internal research for technological development and demonstration.
• Performing Analytical Analysis. We work with third parties that collect data about User use of the Site and other websites or online services over time for non-advertising purposes. For example, we use Google Analytics and other third-party services to improve the performance of Whildey Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data, visit https://policies.google.com/technologies/partner-sites. Opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Our Information Sharing Practices

Whildey shares the Personal Information collected through our Services, procured through our data partners, or our Site with the following third parties and as otherwise described in this Privacy Policy:

• Affiliates: Whildey may share some or all User Personal Information with our Affiliates (i.e. companies which are under common control, such as subsidiaries or joint ventures), in which case we will require our Affiliates to honor this Privacy Policy in all material respects.
• Business Transitions: In the event Whildey goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets including in bankruptcy, Personal Information may be among the assets transferred.
• Law Enforcement, Government Authorities, and Private Parties: We may disclose Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend the rights or property of Whildey, Publishers, or third parties; or (c) for the other compliance, fraud prevention, and safety purposes described in this Privacy Policy.
• Publishers: We may disclose Personal Information that identifies a device or browser to Publishers and their service providers to provide the Whildey Services, such as measuring the effectiveness of advertising, advertising attribution, and preventing advertising fraud, or to indicate User preferences for Interest-Based Advertising.
• Other Third-Party Customers: We may disclose Personal Information that identifies a device or browser to our third-party customers that include, for example, other advertising services and data enrichment services, who will use and disclose the information for their own purposes. We may also share Non-Personal Information such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third-party data to provide an even broader service to our customers. Please see How to Opt-Out for more information on choices related to this practice.
• Service Providers: We may provide Personal Information to third-party service providers (sub-/processors) who work on behalf of or with us to provide the Whildey Services including to help us communicate with you. Examples of such services include our ability to send email, perform data analysis, provide marketing assistance, process payments (including credit card payments, through a third-party service), and provide customer service.
• Advertising Partners: We may share your Personal Information with third parties that we partner with to engage in Interest-Based Advertising, including through the use of cookies and similar technologies. These third party advertising companies may collect information about your activity over time through the Services and across other online services to serve you advertisements.
• Professional Advisors:We may share Personal Information with persons, companies, or professional firms providing Whildey with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

How To Opt Out

Whildey supports various opt-out mechanisms, where each option provides different results related to targeted advertising. While using these mechanisms may prevent Interest-based Advertising or the sale of your Personal Information, there are no mechanisms for preventing advertising altogether.

Opting Out of Whildey's Interest-based Advertising

Just as there are different mechanisms for providing Interest-based Advertising (such as through a web browser, apps on your mobile device), there are multiple ways you can limit the use of your personal information for targeted advertising purposes and the sale or sharing of your personal information.

To simplify the management of Interest-based Advertising preferences, Whildey participates in the Digital Advertising Alliance (DAA) AdChoices program that allows a user to manage their Interest-based Advertising preferences on their browser(s) or device(s) across all participating DAA members.

For more information on how to opt-out of the sale or sharing of personal information, please see the section, "Your California Privacy Rights" located in the "Country and US State Specific Disclosures" section, below.

Cookies and Unique Online Identifiers Used by Web Browsers

Your opt-out choice will apply to the browser or device where you make the choice. This means that Whildey will not deliver Interest-based Advertising to this browser or device and we will not otherwise use or transfer data collected on this browser or device for Interest-based Advertising.

Users who wish to opt out of Whildey's collection, use, or transfer of such data from a browser for Interest-based Advertising purposes can visit https://www.aboutads.info/ to learn more about Interest-based Advertising. There, you may also access the DAA WebChoices tool for managing preferences on web browsers, and to exercise opt-out choice with respect to Whildey and other companies participating in the DAA's self-regulatory program.

Identifiers used by mobile devices / apps

Users who wish to opt-out of Whildey's collection, use, or transfer of such data from apps on a mobile device for Interest-based Advertising purposes can download the DAA's AppChoices application to manage preferences on mobile platforms like Android or Apple iOS devices. More information on your options for opting out of targeted advertising provided through your connected television streaming devices can be found on the Network Advertising Initiative (NAI) site.

When using DAA's opt-out tools, choice will be effective only on the browser or device where choice has been exercised. If using a different device or browser, the opt-out choice(s) will need to be renewed for the new device or browser. Our opt-out tool for browsers is cookie-based, so that an opt-out choice can only be honored if a browser is set to accept third-party cookies. If the opt-out cookie is deleted, then the opt-out choice(s) must be renewed.

Opting out of Interest-based Advertising prevents the collection of Personal Information but does not prevent data collection of Non-Personal Information.  We may continue to collect, use and transfer such Non-Personal Information for other purposes such as contextual advertising based on a current visit to a website, fraud prevention, or improving site performance.

Opting out also will not stop advertising from appearing in a browser. After opting-out, Users may receive advertising from Whildey Services when visiting websites of a Publisher who uses our Services, but that advertising will not be interest-based. After opting out of Whildey's Interest-based Advertising, Users may also continue to receive Interest-based Advertising through other companies.

Children's Privacy

Whildey does not knowingly collect Personal Information from or direct Whildey Services to children under the age of 16.

If you are not 16 years old, please do not use the Site. Do not submit your name, email address, or other personal information using our web forms.

As operators of their own websites and content, our Publishers are solely responsible for compliance with law related to the collection and use of information from children under the age of 16. If, during routine review, Whildey believes children under the age of 16 have submitted their personal information into our web forms or our customer's websites, we will, in our sole discretion, delete the information believed to belong to those under 16 years old.

Retention of Personal Information

We will retain Personal Information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security

Whildey has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect; however, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Country and US State Specific Disclosures

Various data privacy laws require specific disclosures regarding the collection and use of your Personal Information. These disclosures are meant to supplement, and are consistent with, the practices described in this Privacy Policy.

Notice to Residents of the EEA, Switzerland and UK: Data Subject Rights

This section applies only to individuals located in the European Economic Area ("EEA"), Switzerland or the United Kingdom ("Applicable Countries") and supplements the practices described in this Privacy Policy. It describes certain rights and protections under applicable law regarding the processing of Personal Information. For purposes of this section, "Personal Information" has the meaning given to "personal data" governed by the Applicable Countries' data protection legislation.

Role of Whildey as a Controller or Processor

If located in one of the Applicable Countries, Whildey may act as a "controller" as defined under applicable law when processing Personal Information. Whildey may also act as a "processor" as defined under applicable law to the extent that we process Personal Information on behalf of and at the instruction of another party, for example a Whildey customer.

Legal Basis for Processing

Whildey's legal basis for processing Personal Information depends upon the specific context in which it is collected or used. In some cases, we rely on data subject consent (as defined under applicable law) to process Personal Information for Interest-Based Advertising, which we require Publishers using Whildey Services to obtain on our behalf. In other cases, we may rely on our legitimate interests to collect and use Personal Information, except where our interests are overridden by data-protection interests or fundamental rights and freedoms. For example, we will also process Personal Information collected from Interest-Based Advertising in order to improve the Whildey Services for our Publishers where permitted by law. Our legitimate interests are described in greater detail in the "How We Use Information" section of this Privacy Policy. These legitimate interests include the operation of our business and the provision of Whildey Services to our Publishers as required by our agreements with them.

Additionally, we may have a legal obligation to process Personal Information (such as for fraud prevention).

Exercising Data Subject Rights

Use of User Information

Individuals may be entitled to exercise certain data subject rights available under applicable laws. These rights may include the right to request access to Personal Information we hold. Individuals may also have the right to object to, or request that we restrict, processing of Personal Information, such as profiling we perform for the purposes of direct marketing and interest-based advertising. Individuals may also have the right to ask that your Personal Information be corrected, erased, or transferred to another party. Where we have asked for consent to process data, consent may be withdrawn.

Anyone afforded any of these rights may exercise them by contacting privacy@whildey[.]com.

These rights may be limited in some situations-for example, where we can demonstrate that we have a legal requirement to process data. In some instances, this may mean that we are able to retain data even if consent is withdrawn. In other instances, we may provide the requested information with some portions redacted in order to adhere to obligations of confidentiality to others.

Where we require Personal Information to comply with legal or contractual obligations, provision of Personal Information is mandatory; in all other cases, provision of requested Personal Information is optional.

Data Transfers

Whildey is a global company headquartered in Singapore, with data centers located in the United States, Singapore and Europe. By visiting Publisher's properties who are using Whildey Services, Personal Information may be transferred to, stored, and processed by us, our affiliates, and by those third parties with whom we may share your information, some of which are located outside of the Applicable Countries.

These countries (including the United States) may have data protection or other laws that differ from those in the Applicable Countries. We ensure that where Whildey or third-party service providers receive Personal Information outside of the Applicable Countries, appropriate safeguards are in place under the Applicable Countries' data protection legislation.

Whildey may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Questions or Complaints

Individuals located in one of the Applicable Countries who have questions or concerns about how we process Personal Information may contact our Data Protection Officer at dpo@whildey.com. If we are not able to resolve the issue, individuals have the right to lodge a complaint with their local data privacy authority. For contact details of local Data Protection Authorities, please visit the European Data Protection Board member list or the UK data protection regulator.

Notice to California Residents: Your Privacy Choices

This section applies only to California residents and supplements the practices described in this Privacy Policy. It describes how we collect, use, sell, share, and retain Personal Information of California residents, and their rights with respect to that Personal Information. For purposes of this section, "Personal Information" has the meaning given in the California privacy laws but does not include information exempted from the scope of those laws.

Personal Information We Collect and Purposes of Collection and Use

Personal Information we collect (or have collected in the 12 months preceding the "Effective Date" of this Privacy Policy) about California residents are listed below by reference to the categories specified under California privacy law. Examples in the list refer to the types of Personal Information described above in this Privacy Policy.

• Identifiers, such as cookie ID, unique online identifiers, device information, hashed email, IP address, connected television ID, and mobile advertising ID.
• Customer Records, such as Publisher PII and payment information.
• Commercial information, such as records of products or services purchased, obtained or considered.
• Internet or Network Activity, such as browsing history, search history, and interactions with a website, email, application, or advertisement.
• Inferences drawn from the Personal Information identified above to create a profile reflecting preferences, characteristics or behavior.

We may collect these categories of Personal Information directly from you and from your device as you visit our Site or Publisher sites in our network subscribing to Whildey Services, or from other third parties as further described in this Privacy Policy under the section titled "How We Collect Information."

The purposes, including the specific business and commercial purposes, for which we collect and use these categories of Personal Information are described in this Privacy Policy under the section titled "How We Use Personal Information."

To the extent that we may collect any sensitive Personal Information (as defined under California privacy law), such as to provide account management for our Publishers, we only use or disclose it for purposes permitted under California law (i.e., to perform the Whildey Services, process customer transactions, detect security incidents and prevent fraud, or to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

We retain each of the categories of Personal Information listed above as described in this Privacy Policy under the section titled "Retention of Personal Data."

Personal Information "Sold," "Shared" or Disclosed for Business Purposes

"Sale" is defined under California privacy law as disclosing a California resident's Personal Information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as "sharing" under California privacy law.

The following table describes the categories of Personal Information "sold" or "shared" for our commercial purposes to each of the categories of third parties listed, and includes our practices in the 12 months preceding the "Effective Date" of this Privacy Policy.

Each category of Personal Information listed in the following table may also have been disclosed for our business purposes (such as for internal use and business intelligence), and have in the preceding 12 months been disclosed, to each of the categories of third parties listed.

The categories of third parties listed, along with our business and commercial purposes for which we "sold," "shared" or disclosed Personal Information, are described in this Privacy Policy under "Our Information Sharing Practices" within the section titled, "How We Use Information."