This Privacy Policy (“Privacy Policy”) informs about Personal Information processed
through adMarketplace, Inc.’s ("adMarketplace’s") products and services (“Service(s)”)
which is for the purpose of providing certain advertising related services for our
Customers.

This Privacy Policy also informs about information collected from this website,
www.admarketplace.com, which serves two basic functions. First, it has
information about our Services as well as online advertising generally. Second, it is a portal for adMarketplace publishers and advertisers ("Customer(s)") to access certain restricted, Customer-only materials through secure log-in.

This Privacy Policy does not relate to Customer business information shared with us (e.g.,
billing or contact details). As well, it does not relate to information shared by employees or other staff, or by applicants for positions with our company. You may reach your business or HR contact for inquiries related to such information).

1. Our Commitment to Data Privacy

It is of critical importance to us to keep the information we collect secure. adMarketplace is also committed to protecting the privacy of consumers and observes compliance with
applicable laws, including the EU’s and United Kingdom’s Data Protection Regulation
("GDPR") and various state privacy laws in the United States including CCPA (“US Privacy
Laws”) and relevant laws of other countries and/or regions, collectively referred to as
“Data Protection Laws”. As our practices evolve, this Privacy Policy may be revised to
reflect those changes. Notice of such amendments will be posted as an updated notice on this website. Please review this Privacy Policy periodically in order to keep up to date with any modifications.

2. Who is adMarketplace?

adMarketplace is a provider of Services that enable our Customers to reach consumers as they search for or indicate intent to learn more about or engage with our Customers’
products or services. Our Services do not use Personal Information to track, target, or
otherwise profile consumers across unrelated websites, apps, devices, platforms or
properties (collectively referred to herein as ‘Sites’). Personal Information (also referred to as Personal Data) means any information related to an identifiable person and includes IP addresses, cookie identifiers and device identifiers.

(Personal Information is distinct from Personally Identifiable Information (PII) which is
information that on its own is able to identify, contact, or locate an individual. An example of PII is an individual’s email address. adMarketplace Services do not collect, process, or use PII).

The corporate entity that decides how and for what purpose we process information (the
legal basis for processing) is:

adMarketplace, Inc.,
90 Park Ave,
11th Floor New York, NY 10016 USA
Tel. +1 212 925 2022
Email: privacy@admarketplace.com

3. Purposes of and Legal Bases for Processing of Personal Information

We process Personal Information as set out below:

a.  If you are an internet user visiting one of our Customer’s Sites: On behalf of our
Customer, we may process Personal Information in order to deliver ads to the Site
you visit. To illustrate, our technology shows ads in the following ways:

• Pre-search: we show tiles (display ads) for different trusted brands who are our
  Customers, below the search box
• During search: while a search request is being typed, we may show links that
  allow you to directly navigate to the brand Site(s) and "skip" having to go to
  a search engine results page
• Post-search: we may include links to brand Sites within search results
• Native Search: we may include links to brand Sites within editorial, informational
  or consumer-generated content
• Push Notifications: if you have expressly opted-in, we may show notifications
  from brands at a specific time of day to your desktop, mobile or other device
• Auto-complete Search: we may provide auto-complete feature and/or redirect
  your mistyped or misspelled brand searches to the actual brand domain you may
  have intended to type, and thus bypass parked pages

b.  We process Personal Information collected from our Customer’s Sites on their
behalf to deliver Services. Our bases for processing when you visit Customer Sites is
as follows:

• For display of advertising: we are a processor or service provider to the
  Publisher who has legitimate interest or obtained consent from you when you
  visited their Site, to display advertising
• When a consumer clicks on an ad (creative) displayed on the site of our
  publisher customer, we may operate as processor or service provider to the
  advertiser whose ad (creative) the consumer chose to click
• In order to improve our Services and to develop new services or features for our
  Customers
• In order to maintain security, identify fraud and similar misconduct
• In order to understand trends in how users react to particular types of
  advertisements or offers
• In order to provide insights and reporting back to Customers, such as statistical
  reporting in connection with the activity on Sites, optimization of the location of
  ad placement, ad performance, reach and frequency metrics, and billing
• In order to resolve or fix technical issues or problems and to respond to user
  inquiries and requests
• In order to comply with legal obligation - in some cases, we may have a legal
  obligation to collect, maintain, or disclose personal information about you in
  relation to the Services

c.   If you are a visitor to our Site (admarketplace.com): any processing of Personal
Information is as follows:

• To process the information voluntarily shared with us when you contact us
  (with inquiries, for example), and
• For operational purposes (relating to your device type, for example), to enable,
  improve, or otherwise manage the delivery of content on our Sites

4. What are the Categories of Personal Information we Collect for our Services?

1. Search information such as commercial search terms (keywords) entered into a
   search box
2. Online Identifiers, including browser and device information such as your device’s
   Internet protocol (“IP”) address, unique device identifiers such as advertising,
   hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for
   Android), information about the type of Internet browser, and general geographic
   information, and in some cases, cookie IDs. Cookies are text files with a small piece
   of data sent from a website and stored in a user’s web browser or pixels (graphics
   embedded in ad content to reflect an interaction with an ad on a Customer’s website
   – pixels work similarly to cookies). You can find more information about different
   types of cookies at allaboutcookies.org
3. Commercial Information, including products and services you may have
   interacted with on the Sites of our Customers
4. Internet Activity, including information about your actions on the Sites of our
   Customers, such as information related to the Site you are viewing; visit dates and
   times; the website you came from before, and visited after you clicked on an ad; ad
   engagement data
5. Advertisement performance information for ads served, viewed or clicked on,
   such as information about the type of ad, the online location where the ad was
   served, whether it was clicked on, and the products and offers viewed while
   browsing or searching
6. Inferences drawn by us or our Customers (or partners of our Customers or who
   work with us) such as age range, demographics, and product interests

As with any information we collect or process, we do not use any Personal Information
collected or shared with us to track, target, or otherwise profile consumers across
unrelated Sites.

5. What are Categories of Personal Information collected our website?

1. User Provided Information - on our website’s "contact us" pages, fields are
   provided so that customers or others interested in our Services can input contact
   details. We collect this information so that we can respond to the information sent to
   us
2. Online Identifiers - in order to maintain and manage our website, we record
   information such as IP addresses, page views and clicks, and cookies for gathering
   website statistics.

6. Statement about Sensitive Information and about Deidentified Information

We do not collect any personal information defined as “sensitive personal information”
under CCPA or US Privacy Laws, nor any “special categories” of personal data per GDPR.

The Services are not intended to process personal information of children under the age of 16 and we do not knowingly collect, sell, share, or process any personal information from children under the age of 16. If you, as a parent or guardian, believe that your child under the age of 16 has interacted with our Services and caused us to unknowingly collect their personal information, please contact us and we will use our best efforts to identify and remove their information to the extent it is in our records.

In addition to our personal information collection and processing, we may collect, create,
process, disclose and store information that is not considered personal information
because it is not identifiable to a particular individual, such as sets of aggregate data,
metadata, and other generalized information about online browsing, usage and
interactions, as well as de-identified information that does not reveal your identity. We do not attempt to re-identify or associate such information to you, and we retain the right to use and disclose such information in any manner permitted by applicable law.

7. What are the Sources of Personal Information?

1. Information received through technologies: When you interact with or on our
   Customer’s Sites, depending on the applicable laws in your location, we may receive
   the categories of information provided above, through technologies such as APIs or
   cookies
2. Information we receive from our Customers or their data providers: Our
   Customers may supply us with personal information about consumers, to the extent
   they have confirmed that they have sufficient authority to provide this information
   to us, in order to deliver more relevant content, advertising, products or services.
   Such processing is subject to those Customers’ privacy policies and the legal terms
   under which they collected the relevant personal information

8. Personal information disclosures

When we disclose personal information, we disclose it to the following categories of
recipients for the following business and commercial purposes:

1. to our Customers or their designated third-party representatives as part of our Services
2. to technology, infrastructure, operations and other service providers to help support
   the infrastructure necessary to provide the Services
3. We may also disclose information about you:

1. if we are required to do so by law or legal process, including in response to a valid
   request from law enforcement authorities or other government officials
2. when we believe disclosure is necessary or appropriate to prevent physical harm or
   financial loss or in connection with an investigation of suspected or actual illegal
   activity
3. if necessary to protect our legal rights or the legal rights of another individual or
   entity
4. in connection with a corporate reorganization or a sale or transfer of all or a portion
   of our business or asset, or
5. to any other person with your consent to the disclosure.

Selling and sharing personal information

We do NOT “sell,” “share,” process or disclose your personal information for targeted
advertising or otherwise as those terms are defined under applicable U.S. Privacy Laws.

9. Security

adMarketplace applies commercially reasonable physical, technical and organizational
security measures to protect information from unauthorized access, corruption or loss.
These include storing information in databases which are protected by security measures such as password protection, multi-factor authentication, and encryption using Transport Layer Security technology (TLS). However, no system can be completely secure, and we make no guarantees as to security of information transmitted through our Services or our own website (adMarketplace.com)

10. Third Parties we work with

We may use processors or service providers for our business purposes (e.g. for data storage or fraud detection); when we do so, we obligate these services to comply with our Privacy and Security policy requirements and the below Data Privacy Framework for onward data transfers, including obligations to provide the same level of protection that we afford for transferred data.

The adMarketplace website may contain links to third party websites; please be aware that we do not endorse and are not responsible for the privacy practices of those websites. If you follow a link to those websites, you should read their privacy notice and terms and conditions to discern their practices.

11. International Data Transfers

For EU and UK data transfers to entities in countries that have not been deemed to provide an adequate level of protection by the European Commission, we use approved contracts, such as the EU Standard Contractual Clauses for the transfer of personal data to Third Countries pursuant to Regulation (EU) 2016/679 in accordance with Commission
Implementing Decision (EU) 2021/914 of 4 June 2021 and the United Kingdom’s
International Data Transfer Addendum to the EU Commission Standard Contractual
Clauses, in force 21 March 2022, as appropriate and additional safeguards where required.

adMarketplace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  adMarketplace has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy
Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal
data received from the European Union in reliance on the EU-U.S. DPF and from the
United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
adMarketplace has certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard
to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the DPF Principles, adMarketplace commits to resolve complaints
about our collection or use of your personal information.  EU, UK, or Swiss individuals with questions concerning our DPF policy may directed them to privacy@admarketplace.com. If we have not been able to satisfactorily resolve the issue, then, you may submit your complaint to JAMS using this link: https://www.jamsadr.com/DPF-Dispute-Resolution.
JAMS is the alternative dispute resolution provider designated to address complaints and provide appropriate recourse free of charge to the affected individual.

For transfers of personal data from non-EU/UK countries where international data transfers are limited or restricted, we comply with the relevant applicable laws to legitimize such transfers.

adMarketplace is responsible for processing personal information it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. adMarketplace shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles unless it shows it is not responsible for the event giving rise to the matter.

adMarketplace is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Note: adMarketplace is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided than an individual has invoked binding arbitration by delivering notice to adMarketplace and following the procedures and subject to conditions set forth in Annex I of Principles.

12. Retention of Data

We retain Personal Information for only as long as necessary for the business purpose of
the processing. Personal Information collected by our Services is retained for sixty-one days in the normal course. Aggregated and anonymized may be retained for a longer period for statistical purposes and for reporting to and billing our customers.

13. Your Privacy Rights under Data Protection Laws

Description of your privacy rights

You may have certain rights regarding your personal information, based on applicable Data Protection Laws, which may include the following:

1. To know about our processing of your personal information/data – you may request
   that we provide you:
   
2. Confirmation as to whether we are processing your personal information/data
3. The categories of personal information we process about you
4. The purposes of processing, including our business or commercial purpose for
   collecting, selling, or sharing your personal information
5. The categories of sources from which we collected your personal information
6. The categories of personal information we disclosed for a business purpose and the
   categories of recipients to whom we disclosed it, especially international recipients
7. The categories of personal information we sold or shared with third parties for
   targeted or cross context behavioral advertising and the categories of third parties
   to whom we sold or shared it
8. The existence of any automated processing
9. Expected retention periods.
10. To Access your personal information/data portability – You may request that we send
    you (or another organization, under certain conditions) a copy of your personal data in
    our possession, in a readily usable and portable format.
11. To Rectify/Correct inaccurate personal information the information we hold about you
    – You may request that we correct personal information you believe is inaccurate or
    complete any information you believe is incomplete;
12. To Erase/Delete your personal information – You may request that we delete your
    personal information under certain conditions or subject to certain legal exceptions;
13. To Restrict/Limit our processing of your personal information – You may request that
    we restrict our processing of your personal information, under certain circumstances;
14. To Object to our Processing of your personal information – You may object to our
    processing of your personal information, under certain circumstances;
15. To Opt-out of certain disclosures of your personal information that may be considered
    selling or sharing for the purposes of targeted or cross-context behavioral advertising;
16. To Withdraw your Consent – You may request to withdraw your consent for processing
    that is based on your consent;
17. To Not Be Subject to Discrimination for exercising your rights – We will not discriminate
    against you for exercising any of your privacy rights by denying you goods or services,
    charging you or suggesting you may receive different prices or rates for goods or
    services, or providing you a different level or quality of goods or services if you exercise
    your rights.
18. To Lodge a Complaint – We appreciate the opportunity to address any complaint you
    may have about our processing of your personal information or handling of your rights
    request, so please direct any concerns to us via email at privacy@admarketplace.com.
    Regardless, you have the right to complain to a data protection authority about our
    collection and use of your personal information. Contact details for data protection
    authorities in the European Economic Area are available here:
    https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-be, and for the
    UK’s ICO here: https://ico.org.uk/global/contact-us/.

For Personal Information collected via our Services, you should contact the relevant
Customer (Site publisher or advertiser) that is the business controlling or controller of such information.

In regard to Personal Information collected from our own website (adMarketplace.com),
you can withdraw your consent by contacting us. In regard to Europe Data, you may also
contact our DPO at dpo@admarketplace.com or privacy@admarketplace.com.

14. California requirements

California residents have certain rights under the California Consumer Privacy Act:
Click here to read additional disclosures required under CCPA.

Shine the light

California law permits California residents to annually request certain details about how
their information is shared with third parties for their direct marketing purposes.  We do
not share your information with third parties for their direct marketing purposes.

Changes to this Privacy Policy

adMarketplace reserves the right to change or replace this Privacy Policy at any time to
reflect any changes in our privacy practices or updates to applicable laws. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes that affect your personal information if and where this is required by applicable data protection laws. Any changes or replacement will be posted on our website related to this Privacy Policy and located here. We encourage you to review our Privacy Policy on a regular basis.

Contact us

For any questions about our privacy practices, you may contact our data protection officer and privacy team by email here: privacy@admarketplace.com, or via:

Our postal address:
adMarketplace Inc.
90 Park Ave,
New York, NY 10016 USA
Tel. +1 212 925 2022