KEYNES DIGITAL, INC. PRIVACY NOTICE

Effective Date: March 18, 2025

This Privacy Notice (“Privacy Notice”) describes how Keynes Digital, Inc. (“Keynes,” “we,” “us,” or “our”) collects, uses, and discloses personal data obtained through our corporate website at www.keynesdigital.com (the “Site”).

In the course of providing our services, we may process certain personal data on behalf of our customers (“Customers”). For information about how your personal data is processed when you are served advertisements by a Customer, please refer to the Customer’s privacy policy. We are not responsible or liable for the content or privacy policies of Customers’ websites or services, which may be different than the privacy practices disclosed in this Privacy Notice.

 

Personal Data Collection

We may collect personal data when you visit the Site, including directly from you, automatically through the Site, and from our vendors and other third parties. Depending on the nature of your interactions with us and the Site, we may collect the following types of personal data about you:

  • Identifiers, including your name, email address, unique personal identifier, online identifier, IP address, and any similar identifiers you provide to us.
  • Internet or Other Electronic Network Activity Information, including device data, browser type, operating system, areas you visit on the Site, time and date of your visit, websites you visit before and after visiting the Site, browsing history, search history, and other information regarding your interactions with the Site.
  • Geolocation Data, including your country and city inferred from your IP address.
  • Professional or Employment-Related Information, including your job title and affiliated company.

We may combine your personal data with other information we obtain through the Site, our services, and from other parties. Your personal data may be converted into deidentified, anonymized, or aggregated data, so that it can no longer be reasonably associated with you, is not considered personal data under applicable law, and is not subject to this Privacy Notice.

 

Personal Data Use

We may use any of the personal data we obtain through the Site for the following purposes:

  • Services and Communications, including to respond to your inquiries and requests, contact you with information about our products and services, and provide you with services you request.
  • Business Operations, including to perform system administration and technology management; identify potential customers, vendors, and partners; manage our relationship with you; carry out internal administration, including auditing and recordkeeping; and otherwise operate our business.
  • Site Operations and Improvement, including to perform analytics and research; maintain, operate, optimize, and provide access to the Site; identify Site visitors; monitor and evaluate Site usage, performance, and trends; improve Site accessibility, performance, and quality; and track and respond to quality and security matters.
  • Advertising and Marketing, including to send marketing and promotional materials relating to our products, offerings, and promotions; measure the effectiveness of our advertising and marketing; develop insights to improve our Site and services; and provide targeted advertising.
  • Security and Integrity, including to maintain the functionality and security of the Site and our information technology systems, authenticate Site users, and otherwise safeguard our Site from cyber risks.
  • Legal and Compliance, including to enforce our company policies and terms; protect our rights; manage risks, investigations, reporting, and other compliance activities; respond to court orders or other government and law enforcement mandates or requests; identify or manage legal actions related to our or others’ rights or property; support actual or threatened claims, defenses, or declarations in a case or before any jurisdictional or administrative authority, arbitrator, or mediation panel; enforce compliance with applicable laws, regulations, or legal processes as well as industry standards; and prevent, identify, investigate, and respond to potential and actual fraud, illegal or malicious activities, and other activity that violates or may violate applicable laws or regulations, our policies, or our terms.
  • Corporate Transactions, including to evaluate or execute a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, as part of regular business operations or pursuant to a bankruptcy, liquidation, or similar proceeding.

 

Personal Data Disclosure

We may disclose the personal data we obtain to the following parties:

  • Corporate Affiliates, including our affiliates and other related entities that may process your personal data as described in this Privacy Notice.
  • Service Providers, Vendors, Business Partners, Agents, and Other Parties that perform services on our behalf, including Site administration, communications, technical support, and other services that help us operate our business.
  • Ad Tech Companies and Other Providers, including to provide personalized advertising, perform analytics, and as otherwise described below in the Cookies and Tracking Technologies section.
  • Parties to Corporate Transactions as part of, or in anticipation of, a corporate sale, merger, or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding.
  • Law Enforcement Agencies, Courts, Government Entities, Professional Advisors, Affected Parties, and Other External Parties in connection with a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law; to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies or terms; to comply with laws, regulations, or other legal obligations; to protect our rights or property or the rights or property of other parties; to enforce this Privacy Notice, our terms, our policies, or agreements with third parties; and to prevent or assist in the prevention of crime.
  • With Your Consent or as Otherwise Disclosed at the time of data collection or sharing.

 

Cookies and Tracking Technologies

We and our vendors use cookies and other online tracking technologies (collectively “Cookies”) to collect and analyze information about your interactions with the Site, including by collecting information about which pages on our Site you viewed or links you clicked and how you interacted with our content during your visit or over multiple visits; store information to improve Site functionality; help you access and navigate the Site more efficiently; and deliver and customize advertisements and track advertising campaign effectiveness.

We and our vendors may collect personal data about your online activities over time and across different devices and websites when you visit the Site, and link information collected by Cookies to other information collected about you.

We engage advertising technology platforms, including the Trade Desk, to support our management of digital advertising campaigns. We use web analytics providers, such as Google Analytics, to administer and improve the performance of the Site, for analytics and marketing purposes, and to serve ads on our behalf across the internet.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like most websites, our Site does not respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit allaboutdnt.com.

You may set your browser settings to manage Cookies; however, certain features of the Site may not function properly or be available if your browser is configured to disable Cookies.

Some of our vendors offer tools you can use to limit or opt out of their Cookies, such as:

  • The Trade Desk: To limit how the Trade Desk uses personal data for targeted advertising, sales, or sharing, visit adsrvr.org/.

Some vendors may participate in the Digital Advertising Alliance (“DAA”) and its AdChoices opt-out program or the Network Advertising Initiative (“NAI”):

  • DAA Opt-Out Tool: com/.
  • NAI Opt-Out Tool: org/choices/.

We are not responsible for the accuracy or effectiveness of other parties’ notices or opt-out mechanisms.

Your Choices

We may use your personal data to send you promotions, special offers, marketing materials, and other information that may interest you. You may opt out of receiving these types of communications from us by following the unsubscribe link or instructions provided in any promotional email we send.

You can limit marketing via Cookies as described in the Cookies and Tracking Technologies section above.

Depending on your location, you may have additional rights and choices regarding your personal data. You may contact us at [email protected] with any inquiries regarding such rights.

California Resident Additional Notice

This section provides additional disclosures for California residents, including pursuant to the California Consumer Privacy Act (the “CCPA”). The disclosures in this section apply to personal data we collect from California residents through this Site and in other contexts, including offline. For California residents, personal data, as used in this Privacy Notice, has the same meaning as “personal information” under the CCPA.

Unless otherwise noted, the disclosures in this California Privacy Notice apply to our current practices, as well as our activities in the twelve (12) months preceding the Effective Date.

Personal Data Collection, Use, and Disclosure

We may obtain the personal data listed in the “Personal Data Collection” section above from sources other than the Site, including offline sources. In addition, we may collect the following personal data from online and offline sources:

  • Personal Data described in Cal. Civ. Code § 1798.80(e), including name; signature; address; and employment information.
  • Commercial Information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Audio, Electronic, Visual, or Similar Information, including audio recordings of customer service calls or video recordings of online meetings.

We may use and disclose the above types of personal data as described in the “Personal Data Use” and “Personal Data Disclosure” sections above.

If you apply for a job with us, we also use your personal data to facilitate our recruitment and hiring process, including opening and maintaining your applicant record; assessing your eligibility for employment; communicating with you regarding your application and the recruitment process; confirming your right to work; and making any accommodations. In addition to the parties identified above, we may share personal data we process for recruiting with your references and our verification providers.

Personal Data Processing

Under the CCPA, we sell and share personal data for cross-context behavioral advertising and other marketing and advertising services that we utilize on our Site. We sell and share the following categories of personal data: Identifiers, Personal Data described in Cal. Civ. Code § 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, and Inferences. We have sold and shared personal data to our vendors, including ad tech providers and other third parties. We do not have actual knowledge that we sell or share the personal data of consumers under 16 years of age.

“Sell,” “share,” “cross-context behavioral advertising,” “third parties,” and “consumers” have the meanings given to them under the CCPA.

We do not collect sensitive personal data from California residents.

CCPA Privacy Rights

California residents have the following rights related to their personal data:

  • Right to Know: You have the right to know what personal data we have collected about you, including: the categories of personal data we have collected about you; the categories of sources from which the personal data was collected and the categories of recipients to which we disclose personal data; our business or commercial purposes for collecting, selling, sharing, or disclosing personal data; the categories of personal data that we sold, shared, or disclosed for a business purpose, and for each category identified, the categories of recipients to which we sold, shared, or disclosed; and the specific pieces of personal data we have collected about you.
  • Right to Correct: You have the right to request that we correct personal data we maintain about you that you believe is inaccurate.
  • Right to Delete: You have the right to request that we delete personal data we collected from you, subject to certain exceptions.
  • Right to Opt Out of Sales and Sharing: You have the right to opt out of the sale of your personal data, and to request that we do not share your personal data for cross-context behavioral advertising. To opt out of the sale or sharing of your personal data, use the opt-out tools in the Cookies and Tracking Technologies section above.

To submit a request related to your privacy rights, please email us at [email protected].

Please note that when submitting a request, you may be asked to provide information so we can verify your identity before action is taken. You may designate an authorized agent to make the request on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you may still need to verify your identity directly with us before we can process the request.

We will not discriminate against you for choosing to exercise any of your CCPA privacy rights.

Personal Data Retention

We maintain personal data for as long as is necessary for the purposes described in this Privacy Notice, or as otherwise authorized or permitted by applicable laws or regulations, including where retention of your personal data is reasonably necessary to: manage your relationship with us, carry out our operations, or satisfy another purpose for which we collected the personal data; carry out a disclosed purpose that is reasonably compatible with the context in which the personal data was collected; or protect or defend our rights or property.

Where personal data is used for more than one purpose, we will retain it until the purpose with the latest period expires.

Data Security

We implement reasonable technical, organizational, and administrative measures to help safeguard the personal data we collect through the Site against unauthorized or unlawful processing and against accidental loss, destruction, or damage. However, because transmission via the internet is not completely secure, we cannot guarantee the security of any information we may have collected from or about you through our Site.

Links to Other Websites

The Site may contain links to other websites or online services that we do not control. We are not responsible or liable for the content or privacy policies of websites or services that we do not control, and the inclusion of a link to another website or online service does not imply our endorsement. We encourage you to review the terms, privacy notices, policies, and settings of websites you may visit.

Information for Visitors Outside the United States

By accessing the Site, you acknowledge that your personal data may be processed in and transferred to jurisdictions other than your own, including the United States, as described in this Privacy Notice. Please be aware that the data protection laws that apply to personal data transferred to the United States or other countries may be different from the laws in your country of residence.

Changes to This Notice

We may occasionally update this Privacy Notice. If we make changes to this Privacy Notice, we will post the new notice here and update the Effective Date at the beginning of this Privacy Notice. We encourage you to periodically check back to remain up to date on our privacy practices. Your continued use of the Site after any update to this Privacy Notice will constitute your acceptance of the changes.

Contact Us

If you have questions, comments, or concerns about this Privacy Notice, please contact us at [email protected].