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Last Updated: November 24, 2021

INTRODUCTION

Welcome to MediaMath’s Privacy Policy (“Policy”). In this Policy, we use the
terms “MediaMath“, “our“, “us” and “we” to refer to MediaMath, Inc. and our
affiliates.

MediaMath is committed to protecting the privacy of individuals (“users”, “you“,
“your“) when we process data about you via our proprietary “Future Proofed
Platform”™ (the “Platform“), when you visit our website at www.mediamath.com
(the “Website“) and when we engage in marketing activities based on contact
information you provide to MediaMath through other means described in this
Policy.

This Policy is provided in a layered format, so you can click through to the
specific sections that may interest you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purposes of this Policy

This Policy sets out how MediaMath collects and processes personal data,
personal information or the equivalent terminology in your jurisdiction
(“personal data” or “personal information“) about you via the Platform, when you
visit the Website, and when we engage in marketing activities based on contact
information you provide to MediaMath through other means described in this
Policy. It also sets out how we use personal data, the steps we take to protect
it, the parties we disclose it to, and the choices and rights that you have
regarding personal data we process about you. The date of the last update can be
found at the top of the Policy, and this Policy describes how we have handled
personal data in the twelve months prior to the date indicated.

You should read this Policy carefully so that you are fully aware of how and why
we are using your personal data.

Who we are

MediaMath is a global provider of digital advertising media and data management
technology. We provide a technology platform and services, which help our
advertiser clients (including agencies of such advertisers) do a more effective
job of reaching their desired audiences. Our Platform has several aspects. The
demand-side aspect enables our advertiser clients to purchase advertising space
(or “inventory“) from publishers (e.g. websites that display ads) in an
automated fashion. This inventory includes display, video, audio, social,
native, digital out-of-home (e.g., billboards or ads you may see in taxis or
buses) and mobile ads. The data management aspect of our Platform provides our
advertiser clients with tools to onboard, segment, activate, and understand the
data they upload to the Platform.

When MediaMath processes your personal data as a controller in the context of
operating the Platform, the Website and our marketing activities, the controller
of your personal data is MediaMath, Inc., MediaMath GmbH, MediaMath UK Limited
and/or MediaMath Publicidade Digital Ltda depending on which MediaMath entity
has contracted with the advertiser client.

MediaMath is an active member of the industry associations that govern user
privacy in the context of digital advertising. As of the last update of this
Policy, MediaMath is an active member in and complies with various industry
frameworks, including: the Network Advertising Initiative (“NAI“) and its NAI
Code of Conduct; the Digital Advertising Alliance (“DAA“) and its
“Self-Regulatory Principles for Online Behavioral Advertising”; Digital
Advertising Alliance of Canada (“DAAC“); the European Interactive DAA (“EDAA“);
the Interactive Advertising Bureau in the US, Europe and various countries
around the world (“IAB“); including the IAB Europe Transparency & Consent
Framework as Vendor ID 79 and its Specifications and Policies; and the
Association of National Advertisers (“ANA“).

Tailored advertising

Advertising which has been delivered to be relevant to individuals or groups of
individuals is referred to by MediaMath as “tailored” advertising. MediaMath
also facilitates the display of advertising which is not specifically relevant
to individuals or group of individuals, which is referred to as “basic”
advertising.

There are many terms such as interest-based, targeted, personalized and
behavioral used to describe advertising which is intended for individuals,
groups of individuals, or categories of individuals. In this Policy, we refer to
such advertising as “tailored” in that it is tailored to the types of products
or services individuals may be interested in. In this Policy we describe how you
can opt out of tailored advertising delivered via our Platform.

Personal data pertaining to children

MediaMath’s products and services are not designed to deliver tailored ads to
children. The definition of “child” varies by location. We do not knowingly
collect personal data from or about children under age 13 or any higher age
where not permitted to do so under applicable law. To the extent permitted by
applicable legislation, we decline any responsibility regarding any activities
that may be conducted by children without the permission of their parents or
legal guardians. If we are made aware that we may have received personal data
from or about a child in respect of whom we are not permitted to process
personal data under applicable law, we will use reasonable efforts to
investigate and remove that data from our records as soon as practicable. If you
have a reason to believe that we might have any information from or about a
child under the permitted age in the relevant location, please contact us at
privacy@mediamath.com.

Links, other websites and other third parties

This Policy relates solely to the personal data we collect and process about you
in relation to our Platform, our Website, and other interactions you may have
with MediaMath that are described in this Policy. MediaMath’s Website contains
links to other sites, and the ads delivered by the Platform may run on a variety
of other sites. Clicking on those links, accessing other sites, or enabling
those connections may allow third parties to collect or share data about you.
MediaMath does not control these third-party sites and is not responsible for
the privacy practices of such sites. You should refer to the privacy statements
of such third-party sites to find out how they collect and use your personal
data. Also, as explained below in Section 5, third parties may process personal
data from you when you visit the Website. Such processing is governed by the
privacy statements of such third parties.

2. THE PERSONAL DATA WE COLLECT VIA THE PLATFORM

MediaMath collects certain personal data while delivering ads via the Platform.
We do not intentionally collect directly identifiable data such as your name,
home address, phone number, or any government identifiers such as your Social
Security Number unless you provide such personal data in connection with any
request that you make directly to MediaMath. MediaMath identifies you by means
of personal data related to your computer or device using cookies and other
similar technologies, as explained below.

We assign a unique identifier called a “MediaMath ID” to your browser, to your
devices (such as your mobile device, connected television, or over-the-top
television devices (“OTT TV Device“)), or to other screens through which we
serve an ad to you on behalf of our advertiser clients. We also assign a
MediaMath ID when you access an advertiser client’s digital properties such as
their websites, emails, or apps (“Digital Properties“). The MediaMath ID enables
the Platform to determine within a reasonable level of confidence that a browser
or device is the same one with which the Platform has previously interacted. In
some cases, based on data we receive from our advertiser clients or data
partners (e.g. audience partners from whom we receive Third Party Segment Data
as defined below), we infer within a reasonable probability that another browser
or device should be associated with the same MediaMath ID. Where we are able to
associate more than one browser or device with the same MediaMath ID, we use
this information on behalf of our advertiser clients to deliver tailored ads to
you across multiple browsers or devices (known as “Cross-Device Advertising“).

The MediaMath ID can be a cookie ID (a unique ID assigned randomly by MediaMath
to an unrecognized browser), a mobile advertising ID (a unique ID assigned by
the mobile operating system, e.g., Apple ID for Advertising or Android
Advertising ID), or an OTT TV Device Identifier for Advertising (a unique ID
assigned by an OTT TV provider, e.g., Roku ID for Advertising).

Your MediaMath ID is personal data and is associated with other categories of
personal data that we collect about you including the following:

* Bid Request Data and Impression Data: MediaMath receives personal data about
you when we have the opportunity to show you an ad on Digital Properties,
(“Bid Request Data“). We collect additional data when we deliver an ad on
behalf of our advertiser clients (“Impression Data“). Bid Request Data
includes your Internet Protocol (“IP”) address, imprecise location (e.g.,
country, region, postal or zip code), browser type (e.g., Chrome or Internet
Explorer); operating system (e.g., Mac OS or Windows); browser language
(e.g., English or Spanish); and Internet Service Provider. It also may
include IDs that our partners assign to your browser or device, including
Google advertising identifiers associated with your browser or device and
used by MediaMath as part of its syncing processes. See Google’s Privacy
Policy to learn more about its use of the personal data which it receives
from partner sites and your ability to control the information which Google
collects on these sites. Impression Data includes elements from (and derived
from) Bid Request Data, campaign information and bidding information (e.g.,
site category, number of pages browsed, click event, Application ID, video
metrics, page URL, connected device ID, timestamp and connection speed). The
sources of Bid Request Data and Impression Data are your browser or device
and media supply sources, such as publishers (i.e. organizations who operate
Digital Properties) and exchanges or supply-side platforms (i.e.
organizations who display ads on publishers’ Digital Properties).
* Pixel Data and Other Client Data: MediaMath advertiser clients import
personal data to the Platform regarding your interactions with them via their
Digital Properties. This data falls into two main categories: Pixel Data and
Other Client Data.
* Pixel Data is collected by the use of MediaMath and/or third party pixels
(described below). Pixel Data includes the time you visited the site, the
page URL, your IP address, your browser type (e.g., Chrome or Internet
Explorer), the operating system (e.g., Mac OS or Windows), the type of
device you used (e.g. laptop or desktop), and data regarding your
activities on the Digital Properties. For example, if you are shopping on
an advertiser client’s website for a product, and you place a product in
your online shopping cart, or make an online purchase, the advertiser
client can import that data to the Platform . MediaMath uses this personal
data later to help the advertiser client show you an ad on a different
website or app. MediaMath advertiser clients may use the Platform to
collect personal data in a form that does not reveal your direct identity,
such as “hashed” email addresses that cannot be read in their directly
identifiable form (i.e. each email address is converted to a code that is
unique to that email address).
* Other Client Data is personal data that advertiser clients obtain outside
of the Platform and import into the Platform. This includes “Segments” that
advertiser clients create or obtain independently from third-party sources.
A Segment is a grouping of individuals who share one or more attributes
(e.g., “car enthusiast”). Individuals are identified in these Segments by
online identifiers and not by names or anything that reveals their names.
Other Client Data also includes personal data that advertiser clients
collect or independently obtain offline, such as purchases made in the
advertiser client’s store. Before advertiser clients transmit this offline
data to MediaMath, names and other directly identifying information are
removed and replaced with a MediaMath ID.
* Third-Party Segment Data and Other Third-Party Data: Third Party Segment Data
is personal data we receive from third party audience partners who create and
provide us with Segments for us and our advertiser clients to use for
advertising purposes. These Third- Party Segments are similar to the Segments
described above. Other Third Party Data we receive includes personal data
from third-party partners that allows them and/or us to associate or match
the MediaMath ID with those partners’ identifiers (through a process called
“Cookie Syncing”), personal data that associates your different devices with
each other, and personal data regarding video content that you view on
television.
* We may use an online identification code, generated by one of our first party
identity partners, for the purpose of delivering an ad to your device. This
code does not contain any of your identifiable personal data and cannot be
used to re-identify you. We use this code to enable our delivery and
management of tailored advertising throughout your online experience (e.g.
web, email, connected devices, and in-app, etc), as well as for data linking
and the measurement of ad performance.
* You have the right to express a choice regarding the use of your data for
these purposes. For more information about our partner LiveRamp and to opt
out of the use of your data in this manner, visit
https://liveramp.com/opt_out/ .
* Special or Sensitive Categories of Personal Data: We do not knowingly collect
any special categories of personal data about individuals in the EEA or the
UK, including: personal data revealing your racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union
membership; personal data concerning your health, sex life, or sexual
orientation; and genetic or biometric data. MediaMath also does not knowingly
collect any data about other sensitive categories such as personal data about
financial account numbers, insurance plan numbers, and criminal convictions
or offenses.

Where not considered sensitive in accordance with applicable law outside the EEA
or the UK we use personal data to create Segments for our clients to use in the
following ways:

* Our advertiser clients may use health-related Segments about non-sensitive
conditions such as an inferred interest in health and wellness or cough
medicine and allergy medications. Click here for a list of the standard
health-related Segments and a sample of custom health segments provided for
use by clients in our Platform.
* Our advertiser clients may use Segments based on political information or
interests. Click here for a list of the standard political interest Segments
and a sample of custom political Segments provided for use by advertiser
clients in our Platform.

When creating Segments MediaMath does not knowingly process personal data that
would be considered sensitive under applicable law (for example, we do not
create Segments of users based on personal data considered to be sensitive under
applicable laws, such as personal data revealing your racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union
membership, personal data concerning your health, sex life or sexual
orientation, or genetic or biometric data). MediaMath may process Segments based
on demographic information such as race, gender and income range where such is
information is not considered sensitive pursuant to applicable law. We take
steps designed to ensure that this is done in compliance with applicable laws
and self-regulatory guidelines, including through our contracts and policies
with our advertiser clients and partners. Our advertiser clients are responsible
for this processing, and you should direct any queries you have about this use
of Segments to them.

Categories of information collected pursuant to the California Consumer Privacy
Act (CCPA): For the purposes of the CCPA, the above-described personal
information collected can be classified as follows:

* Identifiers (such as an online identifier or an Internet Protocol (IP)
address);
* Internet or other electronic network activity information (such as the
browsing history, search history, and information regarding to interaction
with the Website or with advertiser clients’ Digital Properties)
* Geolocation data inferences

3. HOW WE COLLECT PERSONAL DATA INTO THE PLATFORM

We use various technologies to collect your personal data into the Platform.

Like most digital marketing platforms, MediaMath collects personal data using
cookies and other technologies that recognize browsers and devices. We use these
technologies to collect the categories of personal data described above in
Section 2.

The technologies we use include:

* Cookies – Cookies are small text files. MediaMath uses cookies to uniquely
identify an Internet browser. Certain browsers or browser settings sometimes
block cookies or prevent them from working effectively.
* Pixels – Pixels are transparent images, iFrames, JavaScript or mobile SDKs
that we, our advertiser clients, and our partners use to understand how users
interact with their Digital Properties.

We collect personal data into the Platform through other methods as well. The
Platform contains Pixel Data, Other Client Data, Third-Party Segment Data, and
Other Third Party Data that we receive through server- to-server transfers,
Cookie Syncing (defined in Section 2) and other advertiser client and partner
calls to MediaMath originating from the browser.

4. HOW WE USE PERSONAL DATA IN THE PLATFORM

We use personal data in the Platform for the commercial purposes of delivering
tailored ads to you on behalf of our advertiser clients. We use personal data
for our business purposes to improve our Platform, our products and our services
that we provide to our advertiser clients and partners, as well as to create new
products and services. Below, we have set out a description of specific ways we
use various combinations of your personal data in the Platform to fulfil our
commercial interests to serve our advertiser clients, as well as to improve our
products.

Purpose/Activity Personal Data Type
* Enabling MediaMath advertiser clients to create marketing campaigns;
* Creating Segments;
* Facilitating MediaMath advertiser clients’ creation of segments;
* Making decisions related to the opportunity to display an ad (e.g., deciding
which advertiser clients’ campaigns are a good match for a bid opportunity
and what price to bid in each case) and placing the bid on behalf of our
advertiser clients;
* Setting, reading and modifying a MediaMath cookie or reading a mobile
advertising identifier or OTT TV Device Identifier for Advertising;
* Collecting information about a browser or device;
* Facilitating our partners’ collection of personal data, including by placing
partners’ pixels or tags on our advertiser clients’ Digital Properties;
* Delivering ads, including ads based on your inferred interests or activities
on Digital Properties;
* Measuring the effectiveness of those ads and attributing your activities to
our advertiser clients’ campaigns;
* Generating and providing to advertiser clients reports and user-level data
related to their advertising campaigns in the Platform;
* Automated decision-
making and profiling based on personal preferences, interests, behavior, or
location;
* Transferring data to a third party where advertiser clients have elected to
use its services or where MediaMath has engaged a subcontractor to provide
certain functionality or capabilities as a part of the Platform or to improve
our Platform and the products and services that we provide to our advertiser
clients and partners; and
* Fraud detection and prevention.

* MediaMath ID Inserted Cells
* Bid Request and Impression Data
* Pixel Data and Other Client Data
* Third-Party Segment Data and Other Third-Party Data

* Synchronizing MediaMath cookie ID with third- party partners (Cookie
Syncing).

* MediaMath ID
* Impression Data
* Pixel Data
* Other Third-Party Data

* Associating multiple browsers and devices with each other;
* Development, maintenance, and commercialization of MediaMath’s cross- device
graph that associates your different devices with each other;
* Append audience membership to Client’s advertiser client’s first-party data.

* MediaMath ID
* Impression Data
* Third-Party Segment Data and Other Third-Party Data
* Pixel Data and Other Client Data

* Mapping data pixels to third-party segments.

* MediaMath ID
* Pixel Data and Other Client Data
* Third-Party Segment Data and Other Third- Party Data

* Honoring opt-out requests for users who have opted out.

* MediaMath ID

* Enabling hyperlocal targeting of devices within a defined location.

* Bid Request Data

We also publish or otherwise make public anonymous, aggregate, or summary
information regarding campaigns run in the Platform on behalf of our advertiser
clients. For example, we may publish a report that reflects aggregated
statistics regarding seasonal trends in shopping patterns or geographic
differences in advertising impression opportunities. These reports do not
contain personal data.

Automated decision-making and profiling

Our Platform uses proprietary algorithms to make automated decisions about
whether or not to bid on opportunities to serve you ads on behalf of our
advertiser clients and, if so, how much to bid. The ads you see are the result
of advertiser client campaigns that specify how much to spend and on what basis
to spend combined with the use of our algorithms. The ways in which we use
algorithms to determine bid prices may be considered automated decision-making
in certain jurisdictions. Additionally, these processes, in combination with
advertiser client campaigns described below, may constitute profiling in certain
jurisdictions.

These automated decisions use the MediaMath ID we assign to your browser or
device. Using proprietary technology, we associate data that we collect from
third parties with this MediaMath ID. We create Segments using inferred details
about certain of your preferences, behaviors, and demographic information, and
use those Segments to serve ads on behalf of our advertiser clients. For
example, if you are browsing a shoe retailer’s website on your mobile device, we
may infer that you are interested in buying sneakers and associate that mobile
device with a sneaker-buyer Segment. If an advertiser client subsequently wants
to advertise sneakers, the advertiser client may choose to target that Segment
across your devices. If MediaMath then receives an opportunity to show you an
ad, provided by an advertiser client, on your computer browser, which computer
browser has been associated with your mobile device by our algorithm,
MediaMath’s bidding technology will automatically decide whether to bid and if
so what price to bid on behalf of our advertiser clients, based on the data and
algorithms outlined above.

Legal basis for processing (EEA and UK)

Our legal basis under the General Data Protection Regulation (“GDPR“) for
processing the personal data in the Platform depends on the personal data
concerned and the specific context in which we process it.

However, we will normally collect personal data about you only where we have
your consent or the processing is in our (or a third party’s, such as our
advertiser clients’) legitimate interests and not overridden by your fundamental
rights and freedoms.

If we collect and use your personal data in reliance on our legitimate interests
(or those of any third party), this interest will normally be to deliver you
with ads through our technology (where we do not rely on your consent for such
purposes), to measure ad performance, to develop and improve our products, to
ensure appropriate security and to prevent and detect fraud in connection with
our services. We may have other legitimate interests and, if appropriate, we
will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal data, please contact us using
the contact details provided in Section 12 below.

CCPA sale of personal information

For the purposes of the CCPA, MediaMath may disclose all of the categories of
personal information collected on the Platform to the categories of third
parties as described in Section 7 below, for purposes that may be considered a
“sale” under the CCPA. We do not sell the personal information of minors under
16 years of age without affirmative authorization.

Some web browsers have options that may be characterized as “do not track”
settings, which may or may not affect your settings related to our Website. We
do not understand them to operate in that manner or to signify a “do not sell”
request made by a consumer under the CCPA. We are aware that various parties are
developing “do not sell” signals, and we may recognize certain such signals if
we conclude that such a program is appropriate and in accordance with the
requirements of the CCPA.

If you are a California resident and want to exercise your right to opt out of
the sale of your personal information, please see complete the Access Request
Form available. If you opt out of the sale of your personal information,
MediaMath may still process your personal data to show you ads that are not
personalised or otherwise provide certain services to advertiser clients that do
not involve the sale of personal information under the CCPA.

Opt-out and choice mechanisms

Opt out of tailored advertising

You may opt out from tailored advertising at any time through one of the ways
described below. If you opt out of tailored advertising, you will still see ads,
but those ads are less likely to have anything to do with products or services
you care about. With tailored advertising, you receive ads and offers that are
more likely to be useful to you.

Your opt-out is only applicable to the Platform and does not opt you out from
platforms provided by third-party companies. However, you can opt out from both
MediaMath and many third-party companies at once; to do so, please see “Other
ways to opt out of tailored advertising” below. When you opt out, MediaMath will
collect data from your browser, app, or device only as needed to honor your
opt-out and for limited research and development purposes to improve our
browser- and device-recognition technology, which also helps to improve our
ability to honor your opt-out. When you opt out, MediaMath also stops sending
tailored advertising to the opted-out browser, app, or device.

If you use multiple browsers or devices and wish to limit the data that
MediaMath collects and do not wish to receive MediaMath tailored advertising on
any of them, you must opt out from each browser and device individually.

Opt out of tailored advertising in a browser

You may opt out if you are using a browser by clicking the “Click here to opt
out” link below. Please note that if cookies are not enabled in your browser,
including if third-party cookies are disabled, or if you use certain ad-blocking
tools, our opt-out mechanism may not work properly. Please also note that
deleting your cookies does not opt you out. If you clear your cookies, or if you
use a different browser or device, you will need to renew your opt-out choice.

Opt this browser out of tailored advertising (if using a browser)

Your current opt-out status with MediaMath in this web browser is:

Opt out of tailored advertising in the mobile application environment

You may opt out in mobile app environments using the “AppChoices” mobile
application, where applicable, which you can download to your mobile device from
your App Store or via the DAA AppChoices page here.

Other ways to opt out of tailored advertising

You may learn more about tailored advertising and opt out of tailored
advertising from MediaMath and other online advertising companies that are also
members of applicable self-regulatory organizations by visiting their opt-out
links:

* NAI (browser) – http://optout.networkadvertising.org/
* DAA (browser) – http://optout.aboutads.info/
* DAA Canada (browser) – http://youradchoices.ca/choices
* EDAA (browser) – http://www.youronlinechoices.com/
* DAA AppChoices page (mobile) – http://www.aboutads.info/appchoices

Other ways to limit ad tracking in the mobile and OTT TV device application
environment

You also may limit ad tracking in mobile app environments on your mobile device
as well as on your OTT TV Device. For the most effective and up-to-date methods
for doing so, you should consult instructions provided by those device
manufacturers. The NAI provides additional information regarding opting out on
mobile available here and TV streaming devices available here.

Where MediaMath receives a signal to limit ad tracking, we will collect data
from your device only as needed to honor your choice and for limited research
and development purposes to improve our device-recognition technology, which
also helps to improve our ability to honor your choice. Where MediaMath receives
a signal to limit ad tracking, MediaMath also will not serve tailored
advertising in the apps on your mobile device or OTT TV Device.

5. THE PERSONAL DATA WE COLLECT VIA THE WEBSITE OR OFFLINE

If you visit our Website or certain third-party marketing applications used by
MediaMath or if you interact with MediaMath in other ways described below,
MediaMath collects certain personal data from you. This will include personal
data you choose to provide to us, and personal data we automatically collect.
Third parties may collect personal data from you if you use certain features on
the Website.

Personal data you provide

When you visit the Website, you may choose to provide certain personal data to
set up an account, request information such as a demonstration of our products,
or send us questions. You also may choose to provide us with your personal data
through sources other than the Website, including, for example when you register
for or attend an event hosted by MediaMath. The personal data may include your
name, email address, company, title, region, and information about your business
such as industry, size, revenue, and address. You have the ability to provide
additional information at your discretion.

You provide us with personal data when you participate in the publicly
accessible blogs on our Website. You should be aware that any information you
provide in these areas may be read, collected, and used by others who access
them.

We do not link the personal data described in this section with personal data
that we may have about you in the Platform.

Personal data we collect automatically

We automatically collect personal data in the form of certain technical
information from you when you visit the Website, such as IP address, browser
type, Internet Service Provider, referring and exit pages, operating system,
date and time stamp, and/or clickstream data. This information is obtained
automatically using various technologies including cookies and pixels, and
includes the types of personal data described above as Pixel Data. Our partners
and subcontractors may also collect personal data, may sync with additional
third parties, and may allow third parties with whom they partner to set cookies
on the Website.

Please note, MediaMath only has control over these partners’ and subcontractors’
use of cookie and Pixel Data to the extent that it allows the cookies and pixels
to be set on the Website (which may result in personal data being transmitted to
these parties). However, you should refer to the privacy statements of such
parties to find out more about their processing of personal data , how they use
cookies and how they interact with other third parties. For further information
on the cookies and pixels we use on the Website, including a list of the
partners and subcontractors described above, and how you can opt out, please see
our Cookie Notice.

Social media features and widgets

The Website includes social media features that allow you to share news, events,
and blog posts from the Website on platforms such as Facebook, Twitter, and
LinkedIn or by email. If you interact with these features, doing so will result
in certain personal data being provided to the relevant third party such as IP
address and your browser’s technical information, as well as the URL of the
content which you are seeking to share. These social media features are hosted
by the third parties providing them, and your interactions with these features
are governed by the privacy policies of the company providing them, which you
should read and ensure you understand.

Testimonials

We may display testimonials from satisfied clients on the Website in addition to
other endorsements. We will obtain our client’s permission before we place these
testimonials on the Website. If you are a client who wishes to update or delete
your testimonial, please contact us at privacy@mediamath.com.

Legal basis for processing

Our legal basis under the GDPR for processing the personal data described in
this Section 5 depends on the personal data concerned and the specific context
in which we collect it. However, we will normally collect your personal data
only where the processing is in our legitimate interests and not overridden by
your fundamental rights and freedoms, or where we have your consent to do so. If
we collect and use your personal data in reliance on our legitimate interests,
this interest will normally be to operate the Website, to communicate with you,
to send you marketing communications (unless we are required to obtain your
permission in accordance with applicable law), to show you ads on Digital
Properties. (where we do not rely on your consent for such purposes) and in
general to promote MediaMath goods and services. We may have other legitimate
interests and, if appropriate, we will make clear to you at the relevant time
what those legitimate interests are. Our legal basis for processing Pixel Data
is as described in Section 4.

In some cases, we also may have a legal obligation to collect personal data from
you. If we ask you to provide personal data to comply with a legal requirement,
we will make this clear at the relevant time and advise you whether the
provision of your personal data is mandatory or not (as well as of the possible
consequences if you do not provide your personal data).

Where we are required by applicable law to obtain your consent, for instance (in
some cases) in order to send you marketing communications, we will do so. In
such cases the legal basis for our processing of personal data will be your
consent.

6. HOW WE USE PERSONAL DATA COLLECTED VIA OUR WEBSITE OR OFFLINE

Personal data you provide

When you provide your personal data to MediaMath on the Website or through other
means described in this section, we use the data for the following business and
commercial purposes:

* To respond to your inquiry;
* To understand your business and offer you potential business opportunities;
* To know or infer your interest in marketing products and services;
* To enrich certain personal data you provide, for example your company
information with information obtained from third parties;
* To segment (group) you with similar individuals;
* To provide you with information and offers about MediaMath products and
services, information resources (e.g. whitepapers, reports and webinars),
industry news and opinions, and announcements about MediaMath;
* To inform you about and invite you to events, educational opportunities, or
training opportunities;
* To ask you to share MediaMath information, offers, and invitations with other
people;
* To attribute your responses or actions to specific marketing campaigns,
activities, and channels;
* To troubleshoot and for security purposes

You may choose to stop receiving marketing communications at any time by
following the unsubscribe instructions included in any marketing communications
we send you or by completing an opt out request using the form available.

Personal data we collect automatically

We use the Pixel Data that we collect from you on the Website for the purposes
described in Section 4 as well as to determine how you found out about us, what
your interests are regarding our services, how to further improve the
functionality of the Website and our service towards you, and to analyze trends
and administer the Website. For example, we may use Pixel Data that we collect
from you on the Website to deliver ads to you when you visit other Digital
Properties, and we may collect additional personal data from you on those
Digital Properties, such as Bid Request Data or Impression Data. For further
information on the cookies and pixels we use on the Website and how you can opt
out, please see our Cookie Notice.

7. OUR DISCLOSURE OF PERSONAL DATA FROM THE PLATFORM OR WEBSITE

We disclose the following categories of personal data to the following
categories of third parties for the business and commercial purposes set out
above in Section 4 and Section 6:

* To our affiliates in connection with our business operations that are based
in our regional offices in the UK, Spain, France, Germany, Singapore, Brazil,
Japan, Mexico and Australia:
* MediaMath ID;
* Pixel Data and Other Client Data;
* Bid Request and Impression Data; and
* Third-Party Segment Data and Other Third-Party Data.
* To our clients and resellers in connection with providing them with our
digital advertising media and data management services and products:
* MediaMath ID;
* Pixel Data and Other Client Data;
* Bid Request and Impression Data; and
* Third-Party Segment Data and Other Third-Party Data.
* At our clients’ direction, we disclose client Pixel Data and Other Client
Data to the third parties that they designate.
* To our audience partners in connection with creating custom advertiser client
Segments based on advertiser client-supplied seed data (i.e. data about the
advertiser client’s existing customers) or other data:
* MediaMath ID;
* Pixel Data and Other Client Data;
* Third-Party Segments; and
* Impression Data.
* To a limited number of audience partners in connection with audience creation
or modelling:
* Bid Request Data
* To our Cookie Sync partners in connection with synchronizing MediaMath cookie
IDs with third-party partners’ IDs:
* MediaMath IDs;
* Pixel Data;
* Impression Data; and
* Other Third-Party Data (specifically third-party IDs),
* To a number of parties (referred to in this Policy as subcontractors) that
help us provide the services requested by our clients. These subcontractors
provide the following services:
* measurement;
* viewability;
* location-based attribution and location-based targeting providers;
* dynamic creative optimization; attribution;
* fraud detection and prevention;
* providing mechanisms to honor user choices;
* infrastructure;
* storage;
* computing delivering content; and
* analyzing supply inventory and reporting; operation of our Website,
including services provided in connection with the Website including email
services, event management, maintenance of our marketing database, web
analytics, recruitment, management of marketing and customer relationship
and social media.

We disclose personal data to third parties such as competent law enforcement
bodies, regulatory authorities, government agency, court, advisor or other such
third parties, where we consider this to be necessary or where we are under a
duty to do so: (i) to establish or protect the legal rights of MediaMath or its
employees, agents and contractors, as well as the legal rights of its advertiser
clients, partners or other third parties; (ii) to protect the safety and
security of users and visitors to our Website; to protect against fraud; or
(iii) to comply with the law or legal process.

We disclose personal data to an actual or potential buyer (and its agents and
advisors) in connection with any actual or proposed purchase, merger or
acquisition of all or any part of MediaMath’s business.

8. INTERNATIONAL TRANSFERS OF PERSONAL DATA

The personal data that we collect from you and about you may be transferred to
and stored in a country other than your country of residence, such as the United
States, which may not offer the same level of protection of personal data as
your country of residence. However, we will take contractual and/or other
measures to ensure your personal data is protected.

For individuals in the EEA, UK and Switzerland

MediaMath has its headquarters in the United States and many of our partners or
vendors are based outside of the EEA, UK and Switzerland. Whenever we transfer
your personal data out of the EEA, UK and/or Switzerland, we ensure that it
receives a similar degree of protection by entering into the Standard
Contractual Clauses approved by the European Commission (and/or the applicable
UK and/or Swiss authority) with our group companies and applicable partners or
vendors.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Notwithstanding the invalidation of the Privacy Shield Frameworks as mechanisms
for the lawful transfer of data out of the EU and Switzerland (as applicable),
MediaMath, Inc., in addition to entering into the Standard Contractual Clauses
referred to above, continues to comply with the EU-U.S. Privacy Shield Framework
and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal data
transferred from the EU, the United Kingdom and Switzerland to the United
States, respectively.

MediaMath, Inc. has certified to the Department of Commerce that for all
personal data it receives from the EU, the United Kingdom and Switzerland, it
will adhere to the Privacy Shield Principles of Notice, Choice, Accountability
for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access, and
Recourse, Enforcement and Liability.

If there is any conflict between the terms in this Policy and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To find out more about
the Privacy Shield, access the Privacy Shield List, and find details of our
certification, please visit: https://www.privacyshield.gov/list.

Under the Privacy Shield, MediaMath, Inc. may remain liable if its
subcontractors process your personal data in a manner inconsistent with the
Privacy Shield Principles, unless we prove that we are not responsible for the
event giving rise to the damage.

Individuals in the EU, UK or Switzerland who believe that their personal data
has not been processed in compliance with the Privacy Shield Principles may
raise their complaint in the following ways:

1. You can contact MediaMath, Inc. directly using the details in the “How to
contact us” section above. We will respond to your complaint within 45 days
of receipt.
2. We have further committed to refer unresolved privacy complaints under the
Privacy Shield via the Better Business Bureau (“BBB”), an alternative
dispute resolution provider located in the United States. If you do not
receive a timely acknowledgment of your complaint, or if your complaint is
not satisfactorily addressed by us, please
https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information
and to file a complaint directly with the BBB.
3. Further, your complaint can be made or referred to the U.S. Department of
Commerce or the Federal Trade Commission for further investigation.
4. For residual disputes that cannot be resolved by the methods above, you may
be able to invoke a binding arbitration process under certain conditions. To
find out more about the Privacy Shield’s binding arbitration scheme, please
see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has investigation and enforcement authority over
our compliance with the Privacy Shield.

9. PERSONAL DATA SECURITY AND INTEGRITY

MediaMath implements appropriate technical and organizational measures to
safeguard personal data in our possession against being accidentally lost, used,
or accessed in an unauthorized way, altered, or disclosed. No transmission of
data over the Internet, however, is guaranteed to be completely secure. It may
be possible for third parties not under the control of MediaMath to intercept or
access transmissions or communications unlawfully. While we strive to protect
your personal data, we cannot ensure or warrant the security of any data you
transmit to us or that we collect about you. We have procedures in place to
address any suspected personal data breach, and if we are required by law, we
will notify you of any such breach.

MediaMath processes information in a way that is compatible with and relevant
for the purpose for which it was collected. To the extent necessary for those
purposes, we take reasonable steps to ensure that any information in our care is
accurate, complete, current, and reliable for its intended use. If you have any
questions about security on the Website or through the Platform, you can contact
us at privacy@mediamath.com.

10. PERSONAL DATA RETENTION

Retention of data collected on the platform

As described above, we process your personal data for different purposes, and
the length of time that we retain your personal data varies depending on the
processing purpose, the category of personal data and certain external factors.

We will retain the MediaMath ID and, where applicable, its association with
other devices for no longer than thirteen months from the last time we
encountered that MediaMath ID on your browser or device.

We will retain all other categories of personal data that we collect or receive
on the Platform, including Bid Request Data and Impression Data, Pixel Data and
Other Client Data, and Third-Party Segment Data and Other Third-Party Data, for
no longer than thirteen months. We retain much of this personal data for shorter
periods of time. Furthermore, we may delete personal data in response to a
request from a user under applicable law, when requested to do so by our clients
or when contracts with our clients end. Also, most cookies set via the Platform
expire within thirteen months, while certain cookies that are not used for
tracking are refreshed for as long as such cookies are necessary for our
legitimate business purposes (subject to obtaining any necessary consents).

Retention of data collected on the Website and for marketing

If you provide us with your personal data on our Website or through other means
described above in Section 5, we will retain your information for as long as it
is necessary for our legitimate business purposes. For example, if you sign up
for an account or request information on the Website, we will retain the data
you provide for as long as we think you may have an interest in receiving
information from us. Similarly, we retain log files for as long as it is
necessary for our legitimate business purposes.

We retain the Pixel Data that we collect as described above in the section
“Retention of data collected on the Platform”.

11. YOUR RIGHTS

MediaMath acknowledges that in some circumstances, you have certain rights under
data protection laws in relation to your personal data. Depending on where you
are located, which MediaMath entity is the data controller of your data, and
where you reside, these may include the right to access your personal data,
correct certain personal data, erase your personal data, object to certain
processing of your personal data, withdraw your consent to any processing of
your personal data carried out on the basis of consent, restrict certain
processing of your personal data, receive personal data in portable format, and
not be subject to decisions based solely on automated processing. that have
legal or similarly significant effects. To the extent required and permitted by
applicable law, we will provide you access to the personal data we hold about
you and also allow you to correct inaccurate information in certain situations
(e.g., if you submit your email address on the Website), honor the withdrawal of
your consent to any processing of your personal data carried out on the basis of
consent, delete your personal data, honor your objection to processing, restrict
certain processing of your personal data, or port your personal data and ensure
that you are not subject to decisions based solely on automated processing that
have legal or similarly significant effects.

If you would like to exercise any of these rights, please complete the Access
Request form available.

California Privacy Rights

California residents have the following CCPA rights, which can be exercised as
follows:

Right to know about your personal information which we collect, use, disclose
and/or sell for the 12-month period prior to the request date. You may ask for
information about:
* the categories of personal information we have collected about you in the
prior 12 months,
* the categories of sources from which your personal information has been
collected in the prior 12 months,
* the business or commercial purpose for collecting or selling your personal
information in the prior 12 months,
* the categories of third parties with whom we share or to whom we have shared
or sold your personal information in the prior 12 months
* the categories of personal information that have been provided to such third
parties in the prior 12 months.

You may also ask us for a copy of the specific pieces of personal information we
have collected about you in the prior 12 months in a machine-readable format.

* Complete the Access Request form available
* Call us toll-free at 1-844-966-4636

Right to request deletion of the personal information which we have collected
from you, except to the extent we have a basis for retention under the CCPA,
* Complete the Access Request form available
* Call us toll-free at 1-844-966-4636

Right to opt out of the sale of your personal information
* Complete the Access Request form available
* Call us toll-free at 1-844-966-4636

Right not to receive discriminatory treatment for exercise of CCPA rights
MediaMath does not discriminate against you if you choose to exercise your CCPA
rights.

In order to process your request, we may verify your identity by collecting
information from your device (where you submit your request online). You may
need to provide additional information about your device to allow us to confirm
your identity and the type of personal information we may hold about you. Our
Access Request form available has step by step guidance as to how you can make
your request, and the information we are required to seek from you.

You can designate an authorized agent to submit a request to exercise your above
rights by providing such agent with a power of attorney in accordance with
California law. If you submit your request through an authorized agent, we may
ask for verification that you have authorized the agent to act on your behalf.
The information that we may ask to verify your identity (and the identity of the
authorized agent) will depend on your prior interactions with us and the
sensitivity of the personal information at issue. We do this as a security
precaution and to ensure that we do not disclose personal data to or delete the
personal data of the wrong person.

California Civil Code Section 1798.83 (“Shine the Light“) permits California
customers to request certain information regarding our disclosure of personal
information to third parties for their direct marketing purposes. To make such a
request, please contact us using the contact details provided below.

Please note that “Shine the Light” rights and CCPA rights are established under
different legal regimes and must be exercised separately.

12. HOW TO CONTACT US

If you have any questions about this Policy, including any request to exercise
your legal rights, and/or you have a disability which prevents you from
electronically accessing this Policy and require it to be provided in
alternative format, please contact us as follows.

* If you are located in the United States or any other country outside of the
EEA or UK:
* By email to privacy@mediamath.com
* By post to MediaMath, Inc., Attn: Chief Privacy Officer, 4 World Trade
Center, 46th Floor, New York, NY 10007.
* If you are a California resident inquiring about the CCPA, you can also
call our CCPA Helpline, toll free at 1-844-966-4636.
* If you are located in the EEA or the UK, you can contact our data protection
officer who is responsible for overseeing questions in relation to this
Policy:
* By email to privacy@mediamath.com
* By post to MediaMath UK Ltd, Attn: Data Protection Officer (DPO), 230
Blackfriars Road, London, SE1 8NW

If you would like to exercise any of your rights in respect to your personal
data, please submit a request using the Access Request form available. We will
guide you through that process.

You have the right to lodge any complaints you have regarding our processing of
your personal data with a regulatory authority. We care about your privacy, and
we appreciate the chance to address your concerns before you do so.

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