KEYNES DIGITAL, INC. PRIVACY NOTICE

Effective Date: September 1, 2019

Keynes Digital, Inc. (“we,” “us,” or “our” “Keynes”) provides marketing services (collectively, the “Services”). This privacy policy (“Privacy Policy”) describes how we collect, use, and share information through: (i) our Services, and (ii) our corporate website at http://www.keynesdigital.com [or any Keynes-owned or Keynes-licensed website] (collectively the “Site”) and applies to individuals in the European Economic Area who use the Site or whose personal data is otherwise provided to or collected by us in connection with the Services.

For the purposes of users of the site located in the EU, we are the controller of any information we may collect when you visit our Site. Daniel Larkman, with the contact email address dan@keynesdigital.com is our representative in the EU for the purposes of the GDPR. Our data protection officer can be contacted at dan@keynesdigital.com

Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data.

SECTION 1: OUR CORPORATE WEBSITE

This section of the Privacy Policy describes how we may collect, use, and share information collected on our Site.

Information Collection

We may collect a variety of information when you visit our Site. We collect certain personal information when you contact us, request services, or otherwise provide it to us. This personal information will be any of your name, email address, phone number, and any other such information you provide to us.

We may also collect certain technical information when you visit the Site. This type of information is your country, city, browser type, operating system, service provider, the areas you visit on the Site, time and date of your visit, and Google Analytics client ID. We may collect this technical information through cookies, web beacons, or other similar technologies. We may combine personal and technical information together.

HOW WE USE INFORMATION

As it is in our legitimate interests to be responsive to you and to ensure and improve the proper functioning of our Site, we may use any of the information we collect for the following purposes:

• To respond to your inquiries and requests;
• To provide you with any services you request;
• For internal purposes, such as recordkeeping, and to operate our business;
• To operate and improve the Site;
• To perform analytics and research;
• To comply with law and to maintain the security of the Site; and
• As otherwise disclosed at the time of collection or use.

INFORMATION SHARING

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

• Service providers or agents that perform services on our behalf including: Facebook, Salesforce, Linkedin, and Google Analytics;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
• Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or when we believe it is necessary to protect our rights or the rights of third parties; and
• With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information with third parties that has been anonymized and aggregated.

Social Media Tools and Links to Other Websites

The Site may provide links to other websites that we do not control. We encourage you to review the privacy policy of those websites you may visit.

The Site may include social media tools or “plug-ins”, such as social networking and blogging tools offered by third parties. These social media companies may collect information about you and may use and share such information in accordance with your social media account settings, including by sharing such information with the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the social media companies that provide those features. We encourage you to carefully read the privacy policies of any social media accounts you create and use.

Your Choices: Analytics

We use Google Analytics to improve the performance of the Site and our Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you visit our Site or use our Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

How long do we store your personal data?

If you contact us we will add your information to our data base so we can communicate with you. You can request deletion of your information by following the process set out in Section 3 below.

SECTION 2: MARKETING SERVICES

This section of our Privacy Policy describes how we collect, use, and share information through our Services.

Where we use any of your information that includes personal data in order to provide the Services of serving to you advertisements that may interest you, we are acting as joint controllers with our customers and the companies assisting us to serve the advertisements, including the publisher (i.e. the owner of the applications and websites on which advertisements are displayed).

In our contracts with these partners, they are allocated the responsibility under the GDPR for providing the required notices, obtaining any necessary consents and facilitating the exercise of your data subject rights. Our inventory partners work with the IAB UK to ensure that the data we collect from our affiliates and adtechnology partners (as further described in The Information We Collect) is processed with your consent.

The Information We Collect

Through the provision of our Services we collect various types of information from our customers, affiliates and adtechnology partners, including from:

• Our Customers, who may provide advertising IDs, IP addresses and hashed email addresses.
• Our Affiliates, who may provide information about your device, such as device identifier, model, network provider, browser type, language, MAC Address, IP Address, Information about mobile application usage, how you interact with applications you use and advertising you see, precise location information (only with your consent), device type, information about the app, such as the version, information about your mobile advertising identifiers such as your advertising ID and other information about you, including interests, age, gender.
• Mobile Measurement Partners (MMPs), which measure how you interact with an advertisement and may provide us with impressions, clicks, timezone, city, language, conversion duration, connection type, application version, and level of interaction and your advertising ID.
• Publishers (i.e. the owners of the applications and websites you use), Ad exchanges, Ad Networks, Supply Side Platforms, Direct Marketing Platforms and other ad technology companies, who assist with providing targeted advertisements, including information about your device, such as device identifier, model, network provider, browser type, language, MAC Address, IP Address, Information about mobile application usage, how you interact with applications you use and advertising you see, precise location information (only with your consent), device type, information about the app, such as the version, information about your mobile advertising identifiers such as your advertising ID and other information about you, including interests, age, gender.

How We Use the Information We Collect

We use the information we collect through the Services on the basis of our legitimate interest in running and improving our adtechnology business to select and deliver targeted advertisements to you in your mobile apps and other uses such as:

• Analytics and research;
• Providing and improving the Services, including to build segment profiles for marketing purposes;
• To prevent fraud and enforce our terms of service;
• For our own marketing and advertising purposes; and
• Reporting, attribution and frequency capping.

In order to be able to serve advertisements to you that you may wish to see, we may combine data and link your activities across devices and websites.

Information Sharing

We may share the information we collect through the Services with the following categories of third parties for the following purposes:

• Service providers that perform services on our behalf, including analytics and research;
• To our customers to provide the Services to our clients, including customizing advertising and reporting on the performance of that advertising;
• With our affiliates in order to provide and enhance the Services and the affiliates services;
• In response to a legal process, such as a subpoena or court order, or as otherwise required by law, or to protect our rights or the rights of a third party;
• To investigate, prevent, or take action regarding alleged or actual illegal activities, violations of the applicable terms, or as otherwise required by law;
• Publishers (i.e. the owners of the applications and websites you use), Ad exchanges, Ad Networks, Supply Side Platforms, Direct Marketing Platforms and other ad technology companies, who assist with providing targeted advertisements for the purpose of serving you with contextual and/or targeted ads that are relevant to you and may interest you;
• To help them understand how Users are engaging with ads, what kind of Users are most engaging with certain types of ads on their Property, and what kind of ads are published on their Property;
• With other third parties to receive additional data on you from sources other than the publisher’s application or website in order to help analyze and enrich the information collected on you, as well as serve you with more relevant and targeted ads;
• Any other purposes disclosed to you at the time we collect your information or with your consent; and
• As part of a corporate sale, merger, acquisition, or other business transaction, including as part of a bankruptcy proceeding.

Where do we store your personal data?

As we are United States company, any information provided to us, will be stored, processed, and transferred within, or to, the United States. Please be aware that the US and jurisdictions other than the one in which you are located will not have the same data protection laws as your own jurisdiction.

Your personal data is also processed by staff or service providers operating outside the EEA in the United States, who work for us.

Where we receive your information from publishers, advertisers or other adtechnology partners, and they are located in the EEA, we enter the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2010/87/EU (Controller-to-Processor Model Clauses).

Your Choices

As part of our Services we collect information across non-affiliated websites over time. We collect this information to make inferences about your interests in order to provide advertising relevant to you based on those interests. This practice is known as interest-based advertising.

You can use your device settings, such as “Limit Ad Tracking,” to exercise choice regarding our collection and use of information for interest-based advertising from websites and mobile applications on your device. You can also limit our collection of precise location data through your device settings. For more information on your choices, including to opt out of receiving interest-based ads from many third parties, please go to: http://optout.aboutads.info/. For more information about opting out on mobile devices, please go to: https://www.networkadvertising.org/mobile-choice.

Many browsers (including Internet Explorer, Firefox, and Safari) allow you to set a Do Not Track (DNT) signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. We follow DNT settings. You can usually access your browser’s DNT option in your browser’s preferences.

Note that if you exercise choice regarding interest-based advertising you will still see advertising in websites and mobile apps, but those ads may be less relevant to your interests. Data may still be collected from your device with your consent for purposes other than interest-based advertising after you make your choices. If you use different devices, or reset your device identifier, you may need to make your choices again.

California Residents

California law permits California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To make such a request, please contact us at privacy@keynesdigital.com.

Retention of data

Targeting data is stored in a rolling 30 days and up to 90 days upon request, by Keynes or customer directly. Reporting data is stored for the duration of the contract. Reporting data maybe be deleted at the advertiser’s request.

SECTION 3: OTHER GENERAL PRIVACY PRACTICES FOR THE SERVICES AND SITE

Data Security

We implement reasonable security measures to help protect the security of information we collect through the Site.

Your rights

In certain circumstances you have rights in relation to the personal data we hold about you. We set out below an outline of, and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email privacy@keynesdigital.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

• Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
• Portability: in certain circumstances, you have the right to receive or ask us to provide your personal data to a third party in a structured, commonly used and machine-readable format, although we will not provide you with certain personal data if to do so would interfere with another’s individual’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies (we can only do so where it is technically feasible; we are not responsible for the security of the personal data or its processing once received by the third party).
• Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.
• Erasure: You may request that we erase the personal data we hold about you in certain circumstances e.g. where you believe it is no longer necessary for us to hold the personal data or object to our processing.
• Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances.
• Objection or restriction of processing: You have a right to require us to stop processing the personal data we hold about you in certain circumstances (and require us to delete it or continue to store it). Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process or retain such data or if we need to retain it in relation with any legal claims.

Withdrawal of Consent

• Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by http://www.adsrvr.org

Objection to Marketing

• At any time you have the right to object to our processing of data about you in order to send you promotions, special offers and marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@keynesdigital.com and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Changes to This Notice

If we make changes to this Privacy Policy, we will post the new policy here. We encourage you to periodically check back to remain up to date on our privacy practices.

Contact Us

If you have questions, comments, or concerns about this Privacy Policy, please contact us at privacy@keynesdigital.com.