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PRIVACY POLICY




DATE OF POSTING:  JUNE 13, 2022


ANTERIAD DATA SERVICES AND WEBSITE PRIVACY POLICY

Anteriad, LLC (“We,” “Our,” “Anteriad”) provides a variety of data marketing and
consumer analytics products (the “Services”) designed to help for-profit and
not-profit organizations, and companies that work with them, to market their
goods and services in a relevant and efficient way.   Our solutions, many of
which are described on this website, are used through direct mail, email,
online, connected-TV and other marketing channels.

Anteriad operates under several different brands, including but not limited to
OmniChannelBase, OmniEngine, BtoB Trends, HR Trends, TechTrends, BtoBTech
Insights, Enterprise Insights.   For purposes of this Privacy Policy (“Privacy
Policy”), all such brands are collectively called “Services.”

We take seriously the privacy interests and consumer choices of the individuals
whose information we handle and maintain in our database.  This Privacy Policy
describes how we collect, use and manage information, and what rights consumers
have to control how their information is used in marketing.   

To review the “Addendum” we have created specifically to address disclosures
required under the California Consumer Privacy Act, please see our “CCPA PRIVACY
NOTICE.” 

We also operate corporate websites, designed for our own customers and
prospective customers, and others who want to learn about our services.  We
address the information we collect and use for those business purposes (such as
information we use to communicate with our corporate customers and potential
customers) in Section 6 of this Privacy Policy.


1. INFORMATION THAT WE COLLECT AND USE IN OUR SERVICES

In order to provide our Services, we receive data, including personal
information, from a variety of sources, including from websites and apps that
collect the information, public sources, and other data compilers.   We refer to
the information that we collect and process throughout this Privacy Policy  as
“Information” or “the Information.”

The Information often includes various contact information, such as name,
address, email address and telephone number.  It also includes demographic
information about individuals.   It may also include information (on the
individual, household, or wider (e.g., zip code) level), such as:

 * Professional information, including occupation and job title or job history,
 * Particular interests, such as (for instance) home improvement, music, online
   shopping, health and beauty sport, or travel, or political leanings,
 * Demographic information, such as gender, age or age range, level of education
   or likely income range.
 * Geolocation information, such as location coordinates tied to a device or
   wifi identifier.
 * Online identifiers (such as cookie or mobile ad IDs), and IP addresses

This type of information may be inferred – for instance, if a household is in a
particularly wealthy area, we might infer a particular income range.   

Anteriad also receives information through this website (and any other website
we operate), and through corporate interactions and events.   We describe this
information in Section 6.


2. HOW WE USE THE INFORMATION

Anteriad uses the Information for a range of purposes, including the following:


AS PART OF OUR SERVICES:

 * Data Marketing Services.  Our Services include providing marketing
   information to our customers, generally regarding which customers or
   prospective customers are most likely to be interested (or disinterested) in
   certain offers.   When we provide these Services, consumers may be identified
   (and their information shared) in various ways, such as by household, email
   address, or device identifier. Similarly, we help our customers identify and
   understand their customers better, by providing insights about them.   Our
   customers include (but are not limited to) brands and agencies and various
   marketing data platforms that help them to market and advertise to their own
   customers (and prospective customers); our customers also include other data
   compilers, who work with their own customers.
 * Online Targeting.  We sometimes create defined audience segments (“Audience
   Segments”) based on common demographics and/or shared (actual or inferred)
   interests or preferences (e.g., households with tech professionals, or with
   an interest in winter travel).  When we do this, we may work with a data
   partner that  “matches” our Information through de-identification techniques
   (such as through coded data “hashing”) with online cookies and other
   identifiers, in order to target and measure ad campaigns online across
   various display, mobile and other media channels.  You may learn more about
   how to opt out of this and other online ad targeting in Section 4.
 * Email Targeting.  We use the infrastructure and technology of either our
   Customers or our own service providers to help our Customers send and target
   (and measure and analyze) their email campaigns.
 * Additional Marketing Services.  Other Services we may sometimes provide to
   our customers (or that they may provide to their own customers), which may
   overlap with or supplement the above, may involve (a) help with targeting and
   optimizing direct mail, email campaigns, display, social and mobile
   marketing; (b) measuring how effective marketing campaigns have been, by
   determining which messages are most likely to be seen or opened by which
   types of consumers, or which types of ads are most likely to lead to
   purchases; (c) analyzing and optimizing our customers’ (or their service
   providers’) proprietary databases, or helping customers to detect and prevent
   fraud; or (d) providing “validation” or data “hygiene” services, which is how
   companies update and/or correct their databases by verifying or removing or
   correcting old, incorrect or outdated information.

 * To Operate Our Services.  We also use the Information for our own internal
   purposes – such as to improve, test, update and verify our own database;
   develop new products;  operate, analyze, improve and secure our Services and
   our databases and servers.


3. HOW WE SHARE INFORMATION WITH THIRD PARTIES, INCLUDING SERVICE PROVIDERS

Anteriad may share the Information with customers, marketing services and
platforms, as well as service providers that help us to provide the Services
we’ve described above (or other services we may add in the future).  This
includes sharing in the following ways:

 * With Our Customers:  As described above, we license the Information in
   various ways to our customers (and something to partners and resellers, who
   license the Information to their customer), when we provide our Services.  We
   may sometimes share the Information with those Customers’ service providers
   (for instance, a provider that prints or sends mailings or email for a
   Customer).
 * With Email Platforms:  We share our Customers’ data (but sometimes our own)
   with email platforms, for the purpose of targeting, measuring, sending and
   analyzing email campaigns.
 * With Our Partners:  We may also share the Information, including personally
   identifiable information (such as contact information) and Audience Segments,
   with business and data partners to help to tailor marketing and advertising
   campaigns and other communications.  Likewise, we may share the information
   with those partners for analytical purposes, including to help those parties
   measure campaign performance, inform future campaigns, or to handle, analyze,
   or segregate this Information – generally on our or our customers’ behalf,
   but sometimes to help those parties’ own customers.
 * With Our Service Providers:  We share the Information with a variety of
   service providers in order to operate, protect and advertise our Services and
   maintain our website(s).  For instance, we may share the Information with
   hosting providers, tech and customer support providers, marketing and
   advertising solution vendors, other data providers (such as to enhance or
   verify our Information), security providers, billing and payment vendors (as
   to our business to business information), and other companies that help us
   operate, improve or develop the Services.
 * Corporate transfers:  If Anteriad, its stock or its significant assets are
   acquired by or merged into another entity, our information will be
   transferred to that entity, and may be shared during due diligence in
   anticipation of any such transaction.
 * As required by law or to protect any person or entity:  Anteriad may disclose
   Information if we believe that such disclosure is necessary to (a) comply in
   good faith with relevant laws or to respond to subpoenas or warrants served
   on us; or (b) to protect or otherwise defend the rights, property or safety
   of Anteriad, our customers, or any other person or entity.


4. YOUR MARKETING AND OPT-OUT CHOICES

There are multiple ways that you can opt-out of having the Information used to
market to you:

 * First, you may contact us directly to have your personal information removed
   from our database via our website privacy portal located at Form.  When you
   do this, please provide your current address, your email address, and any
   prior home or email addresses you would like “opted out” of our marketing
   databases.   Or if you prefer, you can contact us directly by Email or mail,
   at:

> Attn:  Privacy
> 
> Anteriad, LLC
> 
> 2 International Drive, Suite 300,
> 
> Rye Brook, NY 10573, USA
> 
> Email: privacy@Anteriad.com

We will then in most cases remove your personal information from our active
marketing databases within 30 business days, from the time we received the
opt-out request.  We may in certain cases (but not in most cases) require that
you verify any of the information that you submit, such as through a verified
email response or another verified response.

 * If you would like to opt-out of direct mail advertising in general, we
   recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The
   DMA Choice service is run by the Direct Marketing Association and allows you
   to follow few easy steps to ensure that your marketing preferences are
   honored. 

 * If you wish to opt out of online targeted ads (sometimes referred to as
   “interest-based” or “personalized” advertising), you can also visit the
   opt-out portals operated the industry groups the National Advertising
   Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn
   more about how those opt-outs work on those linked web pages.  Please note
   that these online opt-outs are cookie-based (unlike Anteriad’s direct
   opt-out.  Thus, if you browse the web from multiple browsers or devices, you
   will need to opt out from each browser and/or device, and for the same
   reason, if you change browsers or clear your browser cookie cache, you will
   need to perform this opt-out function again.  Opting-out in this way will not
   prevent you from seeing all types of online ads; it generally will prevent
   targeted ads customized to what advertisers think may be most likely to be
   relevant and of interest to you.

 * If we market to you by email, in our corporate capacity – such as if you are
   a customer or prospective customer of ours and we send information about our
   Services — you may “unsubscribe” from our marketing emails through a link
   placed in your emails.


5. COOKIES AND SIMILAR TECHNOLOGIES


COOKIES AND HOW WE USE THEM

Anteriad its business partners use certain industry-standard technologies,
including cookies and similarly functioning technologies, which we describe
below. (We and/or our service providers use these technologies on our website,
for instance, and our partners may use these technologies in their own marketing
services.)

We may work with third parties or service providers to provide or enhance our
services (e.g. for purposes of tailoring ads, or placing browser cookies), or to
offer marketers ways to access or use our Information, often in de-identified
form.   These partners may set and access their own cookies, pixel tags and
similar technologies on your device, which may have cookies with varying
expiration periods. Those partners may, likewise, collect various types of
information about your browser, device, or browsing activities through use of
these cookies.

Cookies, in turn, are small data files that contain a string of characters, such
as a  unique browser identifier. Cookies are stored on your computer or other
device and act as tags that identify your device. Our (or other companies’)
servers send your device a cookie when you visit a website. A pixel tag (also
commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is
placed on certain web pages.  When you access web pages (such as the website of
a marketer), pixel tags may generate a generic notice of the visit and permit
our partners (or sometimes, us) to read the cookies that a respective company or
server has deployed.  Pixel tags are used in combination with cookies to track
the activity on a site by a particular device.  When you turn off cookies, pixel
tags simply detect a given  website visit.

We or our service providers, and other online marketing platforms that we or
they work with, may use cookies to, among other things, “remember” you,
determine visitor patterns and trends, collect information about your activities
on our clients’ sites, or interact with the advertising you see.   Cookies are
used in this way to provide relevant content to you and replace non-relevant
communications with ads that better match your interests.

Sometimes, we work with companies that link our Audience Segments to cookies (as
also described in Section 2), in order to help companies better target (or
suppress) advertisements to consumers.   This is one of type of the various
categories of advertising that are often referred to as “personalized” or
“interest-based” advertising” or “Interest-Based Advertising.”   You can opt out
of this type of advertising through the industry opt-out methods described in
Section 3, which are cookie-based.


DISABLING COOKIES

Most web browsers are set up to accept cookies. You may be able to set your
browser to warn you before accepting certain cookies or to refuse certain
cookies. However, if you disable the use of cookies in your web browser, some
features of our website and other services may be difficult to use or become
inoperable.


6. DATA COLLECTED THROUGH OUR CORPORATE WEBSITE


INFORMATION COLLECTED

Anteriad collects information from users of our website(s) (including any page
on which this Privacy Policy is posted), including:

 * The domain name and IP address of a user’s web browser, along with a time
   stamp and other information about a user’s browser or device.
 * Information about what content and pages users access, utilize or visit on
   our website, or how they interact with our content – for instance, if they
   spent a certain amount of time reviewing a particular blog post or
   description of particular services.
 * Information, including personally identifiable and contact information that
   you provide, which could include (for instance) survey information, sign-up
   information (e.g., if you sign up for events or newsletters), requests for
   information, mailing addresses and email addresses.


HOW ANTERIAD USES THE INFORMATION WE COLLECT THROUGH OUR WEBSITE

We use the Information we collect through our website(s) to do the following:

 * Create and manage your unique user account.
 * Provide Services to you.
 * Respond to and communicate with you (including regarding news and updates
   about our services).
 * Send you offers and ads for our products and services, when you browse the
   website(s) or other companies’ websites on the Internet (such as to
   “retarget” you with information about our services).
 * Send you offers and ads for products and services of partner brands, or other
   offers we believe may be of interest to you, such as invitations to events
   and webinars.
 * Perform data analysis (including market research).
 * We may combine the Information with other information we obtain from third
   parties, publicly available sources, and any other product or service we
   provide to further improve the relevance and effectiveness of products, and
   advertisements offered, including (but not limited to), those provided on or
   through our services.
 * We may use IP addresses to help diagnose problems with our servers and to
   administer our website(s).  We also may use IP addresses to help identify
   visitors to our website(s) for the duration of a session and to gather
   demographic information about our visitors. We may use clickstream data to
   determine how much time visitors spend on each web page of our website(s),
   how visitors navigate through the website(s), and how we may tailor our
   website(s) to better meet the needs of our visitors. We also use this
   Information for compliance with our legal obligations, policies and
   procedures, including the enforcement of our Terms and Conditions.
 * If we collect Information from “offline” sources – such as if you provide us
   your business card at a trade show – we will maintain that information and
   use it for marketing and business purposes, as well.


HOW ANTERIAD SHARES THE INFORMATION WE COLLECT THROUGH OUR WEBSITES

We may sometimes share or otherwise disclose the Information we collect about
you, as described in this Privacy Policy or otherwise disclosed to you when you
provide us with the information, including as follows:

 * We may share the Information with service providers who help us deliver the
   services you request or we provide.   For instance, we share the Information
   with tech and customer support providers, marketing and advertising
   providers, other data providers (such as to enhance or verify our
   Information), security and data hygiene vendors, payment vendors (as to our
   business to business information), and other companies that may help us
   deliver or develop Services.
 * We may share the Information to communicate with you and market to you,
   including through email, direct mail or display media.
 * We will disclose your PII (or other Information) if we believe in good faith
   that we are required to do so by law, regulation or other government
   authority or to protect the rights, safety or property of ourselves or any
   person or entity. We may also cooperate with law enforcement agencies in any
   official investigation and we may disclose any Information to the requesting
   agency in doing so.
 * If we or all or substantially all of our assets, are purchased by another
   company (such as in a merger, consolidation, restructuring, the sale of stock
   and/or assets, or other corporate change or financing transaction), the
   Information in our possession will likely be transferred to the successor
   entity.  We also may share the Information during the course of any due
   diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and
operational purposes and to market to you (such as to retarget ads to you when
you visit other sites across the Internet).


7. LINKS

This website may provide links to other websites that Anteriad thinks users will
find interesting or useful. Anteriad is not responsible for the privacy
practices of these other sites or companies.


8. SECURITY AND DATA INTEGRITY

Anteriad takes steps to help ensure that the data we possess is housed and
transmitted securely. This may include various types of physical and electronic
security, including firewall protections, encryption, hashing or truncation of
data, and access controls to personal information.  While neither we nor any
platform can guarantee 100 percent safety from hacks or illegal intrusion, we
employ efforts that are designed to ensure that this does not occur.


9. CHANGES TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. Any changes to it will
become effective when it is posted to our website, unless we indicate a later
effective date. Please check back to learn of any changes to this Privacy Policy


10. STORAGE OF INFORMATION IN THE UNITED STATES

If you are accessing our website from outside of the United States, your
connection likely will be through and to servers located in the United States
and all Information you provide will likely be processed and securely maintained
in our web servers and internal systems located within the United States.  (We
generally store the Information used in our Services in the United States.)  
Thus, you should be aware that in accessing this website or otherwise
communicating with us, the information we collect or receive from you may be
subject to laws with lesser or different privacy standards than those in your
own country (such as if you are in a country located in the European Union).


11. CAN SPAM, CALOPPA, CASL ACTS AND YOUR CHOICES AND ACCESS RIGHTS

The CAN-SPAM Act of 2003

Anteriad upholds and adheres to The CAN-SPAM Act of 2003 which establishes
regulations for commercial email, including what information must be included in
an email message, the types of messages that are prohibited, and how to
unsubscribe from commercial emails.

The CAN-SPAM Act was passed in response to concerns about the increasing amount
of spamming and other deceptive marketing practices. The law establishes
requirements for commercial messages, gives recipients the right to have Email
Marketers stop emailing them.

CAN-SPAM contains seven requirements that Anteriad adheres to in order to avoid
unsolicited email spamming.

 * Be honest and transparent in your header (including from, to, and routing
   information)
 * Do not be deceptive in your subject lines
 * Disclose the email as an advertisement
 * Provide your physical postal address in the body
 * Give instructions for opting out
 * Honor opt-out requests within ten business days
 * Ensure processors or third parties comply with CAN-SPAM

CalOPPA

Anteriad upholds and adheres to CalOPPA and requires that any person or company
whose website collects personally identifiable information from Californian
consumers must feature a conspicuous Privacy Policy stating exactly what
information is collected and with whom it is shared. This includes tracking of
online visits for marketing purposes.

The law applies to email marketing because it requires:

 * A Privacy Policy, and
 * Transparency about what kinds of personal data your app or website collects
 * To comply with the law’s requirements, it’s necessary to include a statement
   within our Privacy Policy that we collect email addresses and whether we
   share them with third parties or not.

Anteriad ensures that we provide subscribers with a means of opting out of email
marketing campaigns.

CASL

Anteriad upholds and adheres to CASL, or Canada’s anti-spam legislation,
protects consumers and businesses from misusing digital technology, including
spam and other electronic threats. It also aims to help companies stay
competitive in a global, digital marketplace.

CASL covers “Commercial Electronic Messages” (CEM), which is a bit broader than
simply applying to emails. For example, it also covers instant messages, text
messages, and social media messages that are related to commercial activities.

CASL, like the GDPR, touches on consent. Anteriad adheres to the requirements
for implied consent, such as (making a purchase, donation, gift, providing
volunteer time or resources, providing an email address, or publishing an email
address).

If Anteriad do not meet the conditions of implied consent, Anteriad obtains
express consent from subscribers. This requires either a written agreement or an
oral agreement from the subscriber stating that they consent to receive digital
communications from our or our client’s business.

If you wish to opt out of email marketing campaigns, please click here.


12. THE GDPR AND YOUR CHOICES AND ACCESS RIGHTS WITH RESPECT TO PERSONAL DATA

If you are a resident of one of many European countries, including the United
Kingdom, an important European privacy law (or an equivalent counterpart) the
General Data Privacy Regulation (the “GDPR”) provides you with certain rights,
and places certain obligations on companies, regarding how your “personal data”
(as the GDPR uses that term) is used.  We describe those rights and obligations
below, and how and in what circumstances we honor them.  (Please only rely on
this Section 11 if you are in fact a resident of such a country – it will not
apply otherwise.)

Legal Basis. The GDPR requires us to tell you about the legal ground we’re
relying on to process any “personal data” (as the GDPR uses that term) about
you. The legal grounds for us processing your personal data for the purposes set
out in Section 2 above will typically be because:

 * You provided your (legally sufficient) consent;
 * It is necessary for our contractual relationship, e.g., in order to provide
   you services or features you’ve requested and we’ve promised;
 * The processing is necessary for us to comply with our legal or regulatory
   obligations – for instance, to communicate with you about or to help honor
   your legal rights; and/or
 * The processing is in our legitimate interest. For instance, we may process
   and share business data (such as a person’s business email or address and job
   title) in order to assist our customers to send relevant business-related
   communications. (As an example, if you are a technology attorney, we might
   help a privacy foundation or legal association send you an invitation to a
   privacy law conference by providing or validating for them your most recent
   contact information.)   

Your rights. Your rights to access, correct, delete or withdraw consent. right
to request access to a copy of your personal data, or request that we correct or
“rectify,” restrict or delete Your personal data, You may exercise these rights
by contacting us at privacy@Anteriad.com or through our website privacy portal
located at Form. If you request that we delete your personal data, or withdraw
your consent, we will customarily retain a copy of your data sufficient to
suppress it from our active databases in the future:  but if that is not what
you wish, you may indicate that to us (in which case your information may be
added to our database later, because we will not have “suppressed” it).

Moreover, when we delete your personal data, we may retain it (to the extent
legal permissible) for certain important (but narrow) internal purposes such as
legal, compliance, accounting or auditing purposes. Likewise, when you request
access to your information, we are required — for privacy and other important
compliance reasons — to verify your identity in a legally sufficient manner: if
we cannot do so, we will not be able to satisfy your access request.

Personalized Online Advertising Opt Outs has been amended to the following:
Personalized Online Advertising Opt-Outs. You may object to profiling by online
advertising platforms with whom we sometimes partner to help generate (and
measure or analyze) “personalized” online advertising. These platforms are
generally separate third party “controllers” of your data. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies are
being sent. To learn how you can manage your Flash cookie settings, visit the
Flash player settings page on Adobe’s website. If you disable or refuse cookies,
please note that some parts of the Website may then be inaccessible or not
function properly. To opt-out of our collection and use of data for online
interest-based advertising on your browser (including a mobile browser if
third-party cookies are enabled in your browser) from companies participating in
the Digital Advertising Alliance Consumer Choice Page, please visit
www.aboutads.info/choices. To opt out of advertising solutions that tailor ads
shown within mobile apps based on your likely interests, please either set the
preference on your mobile device to limit ad tracking or download the Digital
Advertising Alliance’s AppChoices app and configure it to opt out of any Digital
Advertising Alliance participating company. For more information on this and to
opt out, please visit www.policies.google.com/privacy,
www.adssettings.google.com/ or www.optout.networkadvertising.org/.

If you are located in the European Union or European Economic Area, you can also
opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu.To
opt-out of the collection and use of data for interest-based advertising on your
mobile device, you can also modify the settings on your mobile device. Please
note that after choosing to opt-out via any of the methods above, if you use a
different device or a different browser, or if you delete browser cookies, you
may need to repeat the opt-out steps for that particular device or browser. In
addition, if you block cookies on your browser or if third-party cookies are
blocked by default, some of the opt-out tools above may not function.

You may unsubscribe from marketing and other communications that we may send (on
behalf of ourselves or others) by clicking the “opt-out” or “unsubscribe” link
in the footer of those emails.

Questions or Concerns.  If you have a complaint or concern or question about how
we handle your personal data, please contact us as at the above contact
addresses, and we will seek to address any concerns you may have.  If you are
not happy with how we have attempted to resolve your complaint, you may contact
the relevant data protection authority.

When We are a Processor. EU data protection law makes a distinction between
organisations that process personal data for their own purposes (known as “data
controllers”) and organisations that process personal data on behalf of other
organisations (known as “data processors”).   Anteriad sometimes acts as a data
controller (for instance, when we make decisions about the data that comprises
our own datasets) and sometimes acts as a processor (for instance, when we
ingest information that belongs to a customer, such as a “CRM” file that we help
analyze).   We generally are only able to help data subjects exercise their
rights as to data we are a data controller of.   If you have a question or
request as to data we’re a processor of, you should generally address that to
the relevant data controller.


13. PRIVACY SHIELD/TRANSFER OF YOUR INFORMATION?

On July 16, 2020, the European Court of Justice invalidated Privacy Shield as a
Transfer Mechanism for data between EU and US companies. Anteriad intends to
utilize the alternate transfer mechanism of Standard Contractual Clauses going
forward for data transfers. Even though Privacy Shield was invalidated, Anteriad
will continue to honor its commitments with respect to EU personal data
transferred pursuant to Privacy Shield before July 16, 2020.

Anteriad LLC (referred to herein as “Anteriad,” “we,” “us,” or “our” as
applicable), has created this Privacy Shield Privacy Notice to help you
understand how we are subject to and comply with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework. These frameworks are
established by the U.S. Department of Commerce regarding the collection, use,
and retention of personal information transferred from the European Union
(“EU”), the United Kingdom (“UK”), and Switzerland to the United States.
Anteriad has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles. If there is any conflict between the terms in this
Notice and the Privacy Shield Principles, the Privacy Shield Principles shall
govern.

Anteriad is committed to educating individuals, our clients, and employees in
the United States and in the EU, the UK, and Switzerland about the issues,
guidelines and laws surrounding compliance with Privacy Shield. To learn more
about the Privacy Shield program, and to view our certification, please
visit https://www.privacyshield.gov/list.


SCOPE

Anteriad collects, stores, transfers, and processes Personal Data in accordance
with applicable data protection law, including where it is necessary to provide
our Premium Services, to perform the Terms of Use, or to perform obligations
under contract. We may transfer your information to affiliates, partners and
other third parties as described herein. We will protect your Personal Data in
accordance with this Privacy Policy wherever it is processed.

The type of Personal Data transferred to Anteriad from the EU, the UK and
Switzerland pursuant to Privacy Shield consists of Personal Data from clients in
the EU, the UK and Switzerland that Anteriad processes on behalf of its clients,
such as end-user name, address, email and transaction information. Since the
requirements for compliance with Privacy Shield vary depending on whether we are
acting as a Processor on behalf of our clients or as a Controller, our policies
and manner of compliance are described separately below.

The practices we employ under the EU-U.S. Privacy Shield, as outlined also apply
to data transferred from Switzerland to the United States in compliance with the
Swiss-US Privacy Shield Framework. Anteriad will adhere to the Privacy Shield
Principles with respect to data transferred pursuant to the Privacy Shield
Principles for as long as it retains such data.


PURPOSES OF DATA PROCESSING

Anteriad acts as a data processor with respect to Personal Data we receive from
our clients and process such information only under the instruction of our
clients and are controlled by our clients in the EU, the UK and/or Switzerland.
In this capacity, we do not own or control any of the information we process on
behalf of our clients. All such information is owned and controlled by our
clients. In this capacity, we receive information transferred from the EU, the
UK and Switzerland to the United States merely as a Processor on behalf of our
clients.

Before starting any processing on behalf of our clients, we enter into a
processing contract with the Controller that ensures the Controller is in
compliance with the General Data Protection Regulations (“GDPR”) or Member State
Data Protection law that may apply. The processing contract will also specify
that the processing will be carried out with appropriate data security measures.
We have measures in place designed to protect Personal Data from loss, misuse,
unauthorized access, disclosure, alteration and destruction.

Any data processed by us will not be further disclosed to third parties except
where permitted or required by the processing contract, Privacy Shield, GDPR, or
the applicable Member State Data Protection law. Any information our client
(acting as the Controller) identifies as sensitive, will be treated accordingly.

When Anteriad provides business and consumer information products, we act as a
Controller of the Personal Data contained in the information products. As a
Controller, we share Personal Data with third parties that fall into various
categories: clients, vendors and partners. Our clients include but not limited
to financial, retail, insurance, and automotive companies.  Our vendors include
data suppliers and service providers. We also share Personal Data with partners
such as other data resellers for marketing purposes. When we act as a Controller
of Personal Data, the policies outlined apply to all Personal Data that has been
transferred from the EU, the UK or Switzerland to the United States.

Anteriad and its affiliates located in the EU, the UK or Switzerland, develop
and maintain Personal Data on data subjects, households, and businesses located
throughout EU Member States, the UK or Switzerland. This information is obtained
from public records, publicly available information, information acquired
through information providers, and information collected directly from data
subjects.

This information is provided to qualified businesses for marketing, customer
data integration, and connectivity purposes. This information may also be used
to provide information services, enhance the understanding a company has about
its customers, aid in accurate integration of a company’s customer information,
and be used as lists for direct marketing purposes.


NOTICE

We may be required to disclose Personal Data in response to lawful requests by
public authorities, including requests to meet national security or law
enforcement requirements. Prior to the transfer of Personal Data from the EU,
the UK or Switzerland to the United States, we require contractual confirmation
from the Controller from whom we acquired the information that the Personal Data
has been provided to us in accordance with GDPR, Privacy Shield, or the
applicable EU Member State Data Protection law, thereby ensuring the data
subjects have been provided with proper notice regarding how their Personal Data
will be used. In addition, when Personal Data is collected directly from data
subjects, we provide the data subject with notice regarding the manner and
circumstances in which the Personal Data will be used and transferred to third
parties.


CHOICE

We provide choices and means for individuals to limit the use of their Personal
Data. In addition to providing individuals with choices regarding our use of
their information, we will remove an individual’s name and related information
from our direct marketing information products if they request it. Consumers may
request an opt-out form by writing Anteriad at the address below, sending an
e-mail to us at privacy@Anteriad.com or via a Form.

To request an opt-out form by mail, write to:

Privacy Officer
EU-US Privacy Shield Opt-Out
Anteriad LLC
2 International Drive, Rye Brook, New York NY10573


ONWARD TRANSFER

Since we share Personal Data with third parties as referenced above, we comply
with the notice and choice principles as described above for all data disclosed
or transferred to a third party. We take reasonable and appropriate steps
designed to ensure that the third party effectively processes the Personal Data
transferred in a manner consistent with our obligations under the Principles.

When we use data processors to perform processing tasks on our behalf and at our
direction and instruction, we require our data processors either:

 * Subscribe to the Privacy Shield (in the case of US-based processors), comply
   with the General Data Protection Regulations (in the case of EU, UK or
   Switzerland -based processors), or another adequacy finding (in the case of
   processors in countries outside the US, EU, UK, or Switzerland); or
 * Enter into a written agreement with us requiring the data processor(s) to
   process the data only for limited and specified purposes and to provide the
   same level of protection as Anteriad

In cases of onward transfer to third parties, we may be liable for the acts of
the third party that are in violation of the Privacy Shield Principles.


SECURITY

We have an information security policy in place designed to protect Personal
Data from loss, misuse, unauthorized access, disclosure, alteration, and
destruction. Our Chief Information Security Officer is primarily responsible for
conducting investigations into any alleged computer or network breaches,
incidents or problems and ensuring that proper disciplinary action is taken
against those who violate our Information Security Policy.


DATA INTEGRITY

We take reasonable steps designed to ensure the information transferred from the
EU, the UK or Switzerland to the United States is reliable, accurate, and
complete. The steps we take to assure data integrity are based on the purposes
for which the Personal Data is used.


ACCESS

An individual may request access to the Personal Data processed pursuant to the
Privacy Shield we maintain in our information products. Individuals have the
right to learn whether data about him or her is found in our information
products and to correct, amend or delete that information when it is inaccurate.
This right applies only to Personal Data about the individual making the request
and is subject to other limitations as defined by law. Individuals can request
access by writing or sending an email request to privacy@Anteriad.com.

Privacy Officer
Anteriad LLC
3 International Drive
Rye Brook, New York NY10573

Anteriad’s Privacy Officer will explain the process for making an access
request. In order to confirm the identity of the individual and the necessary
information to retrieve the individual’s information, Anteriad’s Privacy Officer
will provide a form for the individual to fill out, sign, and return to
Anteriad.

We agree to process all reasonable requests for access within a reasonable time
period but reserve the right to deny access or limit access in cases where the
burden or cost of providing access would be disproportionate to the risks to the
individual’s privacy or when the request is manifestly unfounded or excessive.


RECOURSE, ENFORCEMENT AND LIABILITY

We have Annual Data and IT Security Awareness Certification requirements for
each of our employees. This training includes our Privacy Shield compliance
program implementation. Our employee policies contain clear statements that
training and annual refresher courses in our privacy practices, including our
participation in the Privacy Shield Frameworks, are required and failure to
complete such training and annual refresher courses may result in discipline up
to and including termination. Part of this program includes a certification log
which provides an objective review of employee compliance with our Privacy
Shield certification training.

Individuals who wish to make inquiries, file a complaint, or who take issue with
our Privacy Shield practices or policies as described herein should contact
Anteriad’s Privacy Officer at privacy@Anteriad.com.

Anteriad’s Privacy Officer will explain the process to be followed when filing a
complaint.

Under certain conditions, an individual may invoke binding arbitration to
resolve residual claims. We are subject to the investigatory and enforcement
powers of the U.S. Federal Trade Commission. In addition, we agree to cooperate
with local EU Data Protection Authorities or the Swiss Federal Data Protection
and Information Commissioner to resolve a dispute concerning an alleged breach
of the Privacy Shield Principles.

In compliance with the Privacy Shield Principles, Anteriad commits to resolve
complaints about our collection or use of your personal information. EU and
Swiss individuals with inquiries or complaints regarding our Privacy Shield
policy should first contact Anteriad, LLC at: Privacy@anteriad.com

Anteriad has further committed to refer unresolved Privacy Shield complaints to
the American Arbitration Association (AAA)’s Independent Conflict Dispute
Resolution ICDR/AAA Program, an alternative dispute resolution provider located
in the United States. If you do not receive timely acknowledgment of your
complaint from us, or if we have not addressed your complaint to your
satisfaction, please visit www.adr.org/Support for more information or to file a
complaint. The services of ICDR/AAA Program are provided at no cost to you.


14. CHILDREN’S PRIVACY

Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age
16 may provide any information to or on the Website. We do not knowingly collect
personal information from children under 16. If you are under 16, do not use or
provide any information on this Website or on or through any of its features. If
we learn we have collected or received personal information from a child under
16 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 16, please
contact us at privacy@anteriad.com.

California residents under 16 years of age may have additional rights regarding
the collection and sale of their personal information. Please
see your-california-rights for more information.


15. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, the California Consumer Protection Act
(CCPA) provides certain rights of disclosure, access and deletion of your
Information as described below in the “Addendum for California Residents” at the
end of this Privacy Policy.


16. CONTACT US

Anteriad has a designated privacy contact.  If you have questions related to
this Privacy Policy, or regarding our products or services, please contact us:

Attn: Privacy Officer

Anteriad, LLC

2 International Drive, Suite 300,

Rye Brook, NY 10573, USA

Email: privacy@Anteriad.com

We appreciate your comments and questions regarding Anteriad’s privacy
practices.

———————————————————————


ADDENDUM FOR CALIFORNIA RESIDENTS


CALIFORNIA PRIVACY RIGHTS

Last Modified:  June 23, 2022

 


NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY
PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to
residents of California. This section of the Privacy Policy applies if you are a
natural person who is a resident of California (“California Consumer”) and uses
our Services.  This Addendum supplements the information in the Privacy Policy. 
However, this Addendum is intended solely for, and is applicable only as to,
California Consumers:  if you are not a California Consumer (or a resident of
California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

 1. Our Collection of Personal Information – the types of Personal Information
    (which the CCPA defines broadly) that we collect, the types of sources we
    collect it from,
 2. Our Disclosure and Sale of Personal Information – the types of recipients to
    whom we disclose or sell Personal Information.
 3. Our Business Purposes –  our business purposes for (a) collecting and (b)
    sharing Personal Information, which are generally the same.
 4. Your California Privacy Rights and Choices – what rights you have under the
    CCPA, for instance, to request that we “opt out” your information from our
    marketing database (also called “do not sell” rights), or to request
    categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes
for which we may use California Consumers’ personal information:


1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories
of information summarized in the table below. The following table also describes
how we collect and use such categories of information.

Category

Categories of Sources

Identifiers, e.g., name; alias; postal address; mobile ad identifiers;  IP
address; telephone number; email address; social network handles

 * Data compilers and consumer data resellers, informational and retail websites
   (“Commercial Source Categories”)
 * Public records and other publicly available sources
 * Government entities
 * Social networks

Characteristics of protected classifications under California or US law
(inferenced or actual, including self-reported)

E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)

 * Commercial Source Categories
 * Public records and other publicly available sources
 * Government entities
 * Social networks

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.

 * Commercial Source Categories
 * Public records and other publicly available sources

Internet or other electronic network activity information

E.g., browsing history; online interests.

 * Commercial Source Categories

Geolocation data

 * Commercial Source Categories

Professional or employment-related information

E.g., current or past job history or job title.

 * Commercial Source Categories
 * Public records and other publicly available sources

Inference Data

E.g., consumer information or preferences.

 * Commercial Source Categories

 


2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above
for various business purposes, with service providers and with third parties
including our customers.  The chart below how and with whom we share or disclose
personal information, and whether (based on the CCPA’s definition of “sell”) we
believe we have “sold” a particular category of information in the prior 12
months.

Category

Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months



Identifiers, e.g., name; alias; postal address; mobile ad identifiers;  IP
address; telephone number; email address; social network handles

 * Data compilers and consumer data resellers, consumer goods retailers,
   informational and retail websites, content publishers, non-profit
   organizations, business-to-business services and organizations, consumer
   surveys and survey companies, affiliate networks (“Commercial Recipient
   Categories”)
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Characteristics of protected classifications under California or US law
(inferenced or actual)

E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Internet or other electronic network activity information

E.g., browsing history; online interests.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers, and social networks

 Yes

Professional or employment-related information

E.g., current or past job history or job title.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Inference Data

E.g., consumer information or preferences.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Location data

 * Geolocation information, e.g., tied to a device identifier.

No


WE ALSO MAY SHARE ANY OF THE PERSONAL INFORMATION WE COLLECT AS FOLLOWS:

Sharing for Legal Purposes:  In addition, we may share personal information with
third parties in order to: (a) comply with legal process or a regulatory
investigation (e.g. a subpoena or court order); (b) enforce our Terms of
Service, this Privacy Policy, or other contracts with you, including
investigation of potential violations thereof; (c) respond to claims that any
content violates the rights of third parties; and/or (d) protect the rights,
property or personal safety of us, our platform, our customers, our agents and
affiliates, its users and/or the public.  We likewise may provide information to
other companies and organizations (including law enforcement) for fraud
protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal
information in the event of a major corporate transaction, including for example
a merger, investment, acquisition, reorganization, consolidation, bankruptcy,
liquidation, or sale of some or all of our assets, or for purposes of due
diligence connected with any such transaction.

Sharing With Service Providers:    We share any personal information we collect
with our service providers, which may include (for instance) providers involved
in tech or customer support, operations, web or data hosting, billing,
accounting, security, marketing, data management, validation, enhancement or
hygiene, or otherwise assisting us to provide, develop, maintain and improve our
services.

Sharing of Aggregate Information:  We may aggregate and/or de-identify any
information collected so that such information can no longer be linked to you or
your device (“Aggregate/De-Identified Information”).  We may use
Aggregate/De-Identified Information for any purpose, including without
limitation for research and marketing purposes, and may also share such data
with any third parties, including advertisers, promotional partners, and
sponsors, in our discretion.


3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we
collect for the following purposes, as we also have described in our Privacy
Policy and/or our website.


OUR PURPOSES FOR COLLECTING, USING AND SHARING PERSONAL INFORMATION

Data marketing services, for example:

 * Generally, creating data marketing tools and products for our marketer
   clients, as more fully described in our Privacy Policy (and on our
   websites).   This includes our provision of datasets, data “appends”
   (connecting data across datasets), data “scoring” (providing inferences about
   potential consumer behavior), data hygiene services (helping customers to
   evaluate, validate and correct personal information they hold), and security
   and anti-fraud services (helping customers to identify potentially fraudulent
   activity).
 * Helping our Clients identify and understand their consumers better, by
   providing insights about them and managing loyalty programs, as well as
   providing financial and other scoring products.
 * Assisting our Clients through our Services to provide their current and
   prospective customers with better service, improved offerings, and special
   promotions, for instance, advising on which current or prospective customers
   are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

 * Creating or helping to create defined audience segments based on common
   demographics and/or shared (actual or inferred) interests or preferences
   (e.g., households with prospective students). When we do this, we work with a
   data partner that “matches” our or other Information through
   de-identification techniques (such as through coded data “hashing”) with
   online cookies and other identifiers, in order to target and measure ad
   campaigns online across various display, mobile and other media channels.
 * Assisting Clients in creating “identity” graphs, to help locate users across
   various channels, such as based on common personal, device-based, or
   network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example (which may overlap with “data
marketing services” above):

 * Assisting in targeting and optimizing of direct mail and email campaigns,
   display, mobile and social media marketing.
 * Measuring the effectiveness of online or offline ad campaigns by determining
   which messages are most likely to be seen or opened by which types of
   consumers, or which types of ads are most likely to lead to purchases.
 * Analyzing and optimizing our Clients’ (or their service providers’)
   proprietary databases, or helping Clients to identify and mitigate potential
   fraud.
 * Providing “verification” or data “hygiene” services, which is how companies
   update and/or “clean” their databases by either verifying or

Operating our Services, for example:

 * Improving, testing, updating and verifying our own database.
 * Developing new products.
 * Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security
incidents, debugging, short-term and transient use, quality control, and legal
compliance.

We sometimes use the information collected from our own website,  from social
networks, from other “business to business” interaction (such as at trade shows)
or from data compilers for the above, as well as for our own marketing purposes.




4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California
residents have the right to request that we disclose what personal information
we collect from you, to delete that information, and to opt-out of the sale of
your personal information, subject to certain restrictions. You also have the
right to designate an agent to exercise these rights on your behalf. This
section describes how to exercise those rights and our process for handling
those requests.  (To the extent permitted by applicable law, we may charge a
reasonable fee to comply with your request.)

Sometimes, we act only as a “service provider” to our clients (for instance, if
they provide information to us for analytics, processing or other data
management services), in which case any consumer requests for opt-out, deletion
or access to data must be made through that client:  we will forward any such
requests to a named client, as feasible, but we recommend making any requests
directly to the company you wish to direct the request to.


A. RIGHT TO “OPT-OUT” OF THE SALE OF YOUR PERSONAL INFORMATION

California residents may opt out of the “sale” of their personal information.
California law broadly defines what constitutes a “sale” – including in the
definition making available a wide variety of information in exchange for
“valuable consideration.”

Depending what information we have about you, and whether we have included any
of it in our marketing products and services, we may have sold (as defined by
California law) certain categories of information about you in the last 12
months, as described in the above table in Section II of this Addendum,
titled OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION.


B. RIGHT TO REQUEST ACCESS TO YOUR PERSONAL INFORMATION

California residents have the right to request that we disclose what categories
of your personal information that we collect, use, or sell.  As explained in
Section (D) below, you may also request the specific pieces of personal
information that we have collected from you.  (We may withhold some personal
information where the risks are too great to permit disclosure of the
information.)


C. RIGHT TO REQUEST DELETION OF YOUR PERSONAL INFORMATION

As explained further in Section (D) below, you may also request that we delete
any personal information that we collected from , such as if you have been a
customer of ours.  (Note that this is different from your right to “opt out” of
us selling your personal information, which is described below; also note that
we do not generally collect personal information directly from consumers.) 
However, we may retain personal information for certain important purposes, such
as (a) to protect our business, systems, and users from fraudulent activity, (b)
to address technical issues that impair existing functionality (such as
de-bugging purposes), (c) as necessary for us, or others, to exercise their free
speech or other rights, (d) to comply with law enforcement requests pursuant to
lawful process, (e) for scientific or historical research, (f) for our own
internal purposes reasonably related to your relationship with us, or to comply
with legal obligations.  Additionally, we need certain types of information so
that we can provide our Services to you.  If you ask us to delete it, you may no
longer be able to access or use our Services.


D. HOW TO EXERCISE YOUR ACCESS, AND (IF APPLICABLE) DELETION RIGHTS

Access:  California residents may exercise their California privacy rights by
sending an email to privacy@Anteriad.com, submitting their removal request
through our form, or by contacting us at 1-800 368 7602.

Because it is required by California law (and also, for security purposes), we
will verify your identity – in part by requesting certain information from you
or by requesting you demonstrate possession of a particular identification
method (such as an email account) — when you request to exercise your California
privacy rights.  For instance, if you request categories or specific pieces of
personal information we have received about you, you may need to confirm your
possession of such an identifier (such as an email address) or to provide a
piece of identification that confirms you are the person you claim to be.

Once we have verified your identity, we will respond to your request as
appropriate:

 * Where you have requested the categories of personal information that we have
   collected about you, we will provide a list of those categories.
 * Where you have requested specific pieces of personal information, we will
   provide the information you have requested, to the extent required under the
   CCPA and provided we do not believe there is an overriding privacy or
   security concern to doing so.

Deletion:  Where you have requested that we delete personal information that we
have collected from you, we will seek to confirm whether your request is for an
“opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us
to maintain your information for “suppression” purposes – i.e., to prevent us
from selling information about you in the future (which is what many consumers
requesting “deletion” actually desire to occur), we try to explain this in order
to ensure we are meeting consumers’ preferences.  (In addition, “deletion”
rights only apply to information that we have collected “from” consumers – which
does not apply to much of the information in our databases.)


E. RIGHT TO NONDISCRIMINATION

We do not deny to you, charge different prices for, or provide a different level
of quality of goods or services to you, if you choose to exercise these rights.


F. INFORMATION ABOUT PERSONS UNDER THE AGE OF 16

We do not knowingly collect personal information from minors under 16 years of
age in California unless we have received legal consent to do so. If we learn
that personal information from such California residents has been collected, we
will take reasonable steps to remove their information from our database (or to
obtain legally required consent).


G. AUTHORIZED AGENTS

You may also designate an agent to make requests to exercise your rights under
CCPA as described above. We will take steps both to verify the identity of the
person seeking to exercise their rights as listed above, and to verify that your
agent has been authorized to make a request on your behalf through providing us
with a signed written authorization or a copy of a legally sufficient power of
attorney.  We likewise may require that you verify your own identity, depending
on the type of request you make.


DATE OF POSTING:  JUNE 13, 2022


ANTERIAD DATA SERVICES AND WEBSITE PRIVACY POLICY

Anteriad, LLC (“We,” “Our,” “Anteriad”) provides a variety of data marketing and
consumer analytics products (the “Services”) designed to help for-profit and
not-profit organizations, and companies that work with them, to market their
goods and services in a relevant and efficient way.   Our solutions, many of
which are described on this website, are used through direct mail, email,
online, connected-TV and other marketing channels.

Anteriad operates under several different brands, including but not limited to
OmniChannelBase, OmniEngine, BtoB Trends, HR Trends, TechTrends, BtoBTech
Insights, Enterprise Insights.   For purposes of this Privacy Policy (“Privacy
Policy”), all such brands are collectively called “Services.”

We take seriously the privacy interests and consumer choices of the individuals
whose information we handle and maintain in our database.  This Privacy Policy
describes how we collect, use and manage information, and what rights consumers
have to control how their information is used in marketing.   

To review the “Addendum” we have created specifically to address disclosures
required under the California Consumer Privacy Act, please see our “CCPA PRIVACY
NOTICE.” 

We also operate corporate websites, designed for our own customers and
prospective customers, and others who want to learn about our services.  We
address the information we collect and use for those business purposes (such as
information we use to communicate with our corporate customers and potential
customers) in Section 6 of this Privacy Policy.


1. INFORMATION THAT WE COLLECT AND USE IN OUR SERVICES

In order to provide our Services, we receive data, including personal
information, from a variety of sources, including from websites and apps that
collect the information, public sources, and other data compilers.   We refer to
the information that we collect and process throughout this Privacy Policy  as
“Information” or “the Information.”

The Information often includes various contact information, such as name,
address, email address and telephone number.  It also includes demographic
information about individuals.   It may also include information (on the
individual, household, or wider (e.g., zip code) level), such as:

 * Professional information, including occupation and job title or job history,
 * Particular interests, such as (for instance) home improvement, music, online
   shopping, health and beauty sport, or travel, or political leanings,
 * Demographic information, such as gender, age or age range, level of education
   or likely income range.
 * Geolocation information, such as location coordinates tied to a device or
   wifi identifier.
 * Online identifiers (such as cookie or mobile ad IDs), and IP addresses

This type of information may be inferred – for instance, if a household is in a
particularly wealthy area, we might infer a particular income range.   

Anteriad also receives information through this website (and any other website
we operate), and through corporate interactions and events.   We describe this
information in Section 6.


2. HOW WE USE THE INFORMATION

Anteriad uses the Information for a range of purposes, including the following:


AS PART OF OUR SERVICES:

 * Data Marketing Services.  Our Services include providing marketing
   information to our customers, generally regarding which customers or
   prospective customers are most likely to be interested (or disinterested) in
   certain offers.   When we provide these Services, consumers may be identified
   (and their information shared) in various ways, such as by household, email
   address, or device identifier. Similarly, we help our customers identify and
   understand their customers better, by providing insights about them.   Our
   customers include (but are not limited to) brands and agencies and various
   marketing data platforms that help them to market and advertise to their own
   customers (and prospective customers); our customers also include other data
   compilers, who work with their own customers.
 * Online Targeting.  We sometimes create defined audience segments (“Audience
   Segments”) based on common demographics and/or shared (actual or inferred)
   interests or preferences (e.g., households with tech professionals, or with
   an interest in winter travel).  When we do this, we may work with a data
   partner that  “matches” our Information through de-identification techniques
   (such as through coded data “hashing”) with online cookies and other
   identifiers, in order to target and measure ad campaigns online across
   various display, mobile and other media channels.  You may learn more about
   how to opt out of this and other online ad targeting in Section 4.
 * Email Targeting.  We use the infrastructure and technology of either our
   Customers or our own service providers to help our Customers send and target
   (and measure and analyze) their email campaigns.
 * Additional Marketing Services.  Other Services we may sometimes provide to
   our customers (or that they may provide to their own customers), which may
   overlap with or supplement the above, may involve (a) help with targeting and
   optimizing direct mail, email campaigns, display, social and mobile
   marketing; (b) measuring how effective marketing campaigns have been, by
   determining which messages are most likely to be seen or opened by which
   types of consumers, or which types of ads are most likely to lead to
   purchases; (c) analyzing and optimizing our customers’ (or their service
   providers’) proprietary databases, or helping customers to detect and prevent
   fraud; or (d) providing “validation” or data “hygiene” services, which is how
   companies update and/or correct their databases by verifying or removing or
   correcting old, incorrect or outdated information.

 * To Operate Our Services.  We also use the Information for our own internal
   purposes – such as to improve, test, update and verify our own database;
   develop new products;  operate, analyze, improve and secure our Services and
   our databases and servers.


3. HOW WE SHARE INFORMATION WITH THIRD PARTIES, INCLUDING SERVICE PROVIDERS

Anteriad may share the Information with customers, marketing services and
platforms, as well as service providers that help us to provide the Services
we’ve described above (or other services we may add in the future).  This
includes sharing in the following ways:

 * With Our Customers:  As described above, we license the Information in
   various ways to our customers (and something to partners and resellers, who
   license the Information to their customer), when we provide our Services.  We
   may sometimes share the Information with those Customers’ service providers
   (for instance, a provider that prints or sends mailings or email for a
   Customer).
 * With Email Platforms:  We share our Customers’ data (but sometimes our own)
   with email platforms, for the purpose of targeting, measuring, sending and
   analyzing email campaigns.
 * With Our Partners:  We may also share the Information, including personally
   identifiable information (such as contact information) and Audience Segments,
   with business and data partners to help to tailor marketing and advertising
   campaigns and other communications.  Likewise, we may share the information
   with those partners for analytical purposes, including to help those parties
   measure campaign performance, inform future campaigns, or to handle, analyze,
   or segregate this Information – generally on our or our customers’ behalf,
   but sometimes to help those parties’ own customers.
 * With Our Service Providers:  We share the Information with a variety of
   service providers in order to operate, protect and advertise our Services and
   maintain our website(s).  For instance, we may share the Information with
   hosting providers, tech and customer support providers, marketing and
   advertising solution vendors, other data providers (such as to enhance or
   verify our Information), security providers, billing and payment vendors (as
   to our business to business information), and other companies that help us
   operate, improve or develop the Services.
 * Corporate transfers:  If Anteriad, its stock or its significant assets are
   acquired by or merged into another entity, our information will be
   transferred to that entity, and may be shared during due diligence in
   anticipation of any such transaction.
 * As required by law or to protect any person or entity:  Anteriad may disclose
   Information if we believe that such disclosure is necessary to (a) comply in
   good faith with relevant laws or to respond to subpoenas or warrants served
   on us; or (b) to protect or otherwise defend the rights, property or safety
   of Anteriad, our customers, or any other person or entity.


4. YOUR MARKETING AND OPT-OUT CHOICES

There are multiple ways that you can opt-out of having the Information used to
market to you:

 * First, you may contact us directly to have your personal information removed
   from our database via our website privacy portal located at Form.  When you
   do this, please provide your current address, your email address, and any
   prior home or email addresses you would like “opted out” of our marketing
   databases.   Or if you prefer, you can contact us directly by Email or mail,
   at:

> Attn:  Privacy
> 
> Anteriad, LLC
> 
> 2 International Drive, Suite 300,
> 
> Rye Brook, NY 10573, USA
> 
> Email: privacy@Anteriad.com

We will then in most cases remove your personal information from our active
marketing databases within 30 business days, from the time we received the
opt-out request.  We may in certain cases (but not in most cases) require that
you verify any of the information that you submit, such as through a verified
email response or another verified response.

 * If you would like to opt-out of direct mail advertising in general, we
   recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The
   DMA Choice service is run by the Direct Marketing Association and allows you
   to follow few easy steps to ensure that your marketing preferences are
   honored. 

 * If you wish to opt out of online targeted ads (sometimes referred to as
   “interest-based” or “personalized” advertising), you can also visit the
   opt-out portals operated the industry groups the National Advertising
   Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn
   more about how those opt-outs work on those linked web pages.  Please note
   that these online opt-outs are cookie-based (unlike Anteriad’s direct
   opt-out.  Thus, if you browse the web from multiple browsers or devices, you
   will need to opt out from each browser and/or device, and for the same
   reason, if you change browsers or clear your browser cookie cache, you will
   need to perform this opt-out function again.  Opting-out in this way will not
   prevent you from seeing all types of online ads; it generally will prevent
   targeted ads customized to what advertisers think may be most likely to be
   relevant and of interest to you.

 * If we market to you by email, in our corporate capacity – such as if you are
   a customer or prospective customer of ours and we send information about our
   Services — you may “unsubscribe” from our marketing emails through a link
   placed in your emails.


5. COOKIES AND SIMILAR TECHNOLOGIES


COOKIES AND HOW WE USE THEM

Anteriad its business partners use certain industry-standard technologies,
including cookies and similarly functioning technologies, which we describe
below. (We and/or our service providers use these technologies on our website,
for instance, and our partners may use these technologies in their own marketing
services.)

We may work with third parties or service providers to provide or enhance our
services (e.g. for purposes of tailoring ads, or placing browser cookies), or to
offer marketers ways to access or use our Information, often in de-identified
form.   These partners may set and access their own cookies, pixel tags and
similar technologies on your device, which may have cookies with varying
expiration periods. Those partners may, likewise, collect various types of
information about your browser, device, or browsing activities through use of
these cookies.

Cookies, in turn, are small data files that contain a string of characters, such
as a  unique browser identifier. Cookies are stored on your computer or other
device and act as tags that identify your device. Our (or other companies’)
servers send your device a cookie when you visit a website. A pixel tag (also
commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is
placed on certain web pages.  When you access web pages (such as the website of
a marketer), pixel tags may generate a generic notice of the visit and permit
our partners (or sometimes, us) to read the cookies that a respective company or
server has deployed.  Pixel tags are used in combination with cookies to track
the activity on a site by a particular device.  When you turn off cookies, pixel
tags simply detect a given  website visit.

We or our service providers, and other online marketing platforms that we or
they work with, may use cookies to, among other things, “remember” you,
determine visitor patterns and trends, collect information about your activities
on our clients’ sites, or interact with the advertising you see.   Cookies are
used in this way to provide relevant content to you and replace non-relevant
communications with ads that better match your interests.

Sometimes, we work with companies that link our Audience Segments to cookies (as
also described in Section 2), in order to help companies better target (or
suppress) advertisements to consumers.   This is one of type of the various
categories of advertising that are often referred to as “personalized” or
“interest-based” advertising” or “Interest-Based Advertising.”   You can opt out
of this type of advertising through the industry opt-out methods described in
Section 3, which are cookie-based.


DISABLING COOKIES

Most web browsers are set up to accept cookies. You may be able to set your
browser to warn you before accepting certain cookies or to refuse certain
cookies. However, if you disable the use of cookies in your web browser, some
features of our website and other services may be difficult to use or become
inoperable.


6. DATA COLLECTED THROUGH OUR CORPORATE WEBSITE


INFORMATION COLLECTED

Anteriad collects information from users of our website(s) (including any page
on which this Privacy Policy is posted), including:

 * The domain name and IP address of a user’s web browser, along with a time
   stamp and other information about a user’s browser or device.
 * Information about what content and pages users access, utilize or visit on
   our website, or how they interact with our content – for instance, if they
   spent a certain amount of time reviewing a particular blog post or
   description of particular services.
 * Information, including personally identifiable and contact information that
   you provide, which could include (for instance) survey information, sign-up
   information (e.g., if you sign up for events or newsletters), requests for
   information, mailing addresses and email addresses.


HOW ANTERIAD USES THE INFORMATION WE COLLECT THROUGH OUR WEBSITE

We use the Information we collect through our website(s) to do the following:

 * Create and manage your unique user account.
 * Provide Services to you.
 * Respond to and communicate with you (including regarding news and updates
   about our services).
 * Send you offers and ads for our products and services, when you browse the
   website(s) or other companies’ websites on the Internet (such as to
   “retarget” you with information about our services).
 * Send you offers and ads for products and services of partner brands, or other
   offers we believe may be of interest to you, such as invitations to events
   and webinars.
 * Perform data analysis (including market research).
 * We may combine the Information with other information we obtain from third
   parties, publicly available sources, and any other product or service we
   provide to further improve the relevance and effectiveness of products, and
   advertisements offered, including (but not limited to), those provided on or
   through our services.
 * We may use IP addresses to help diagnose problems with our servers and to
   administer our website(s).  We also may use IP addresses to help identify
   visitors to our website(s) for the duration of a session and to gather
   demographic information about our visitors. We may use clickstream data to
   determine how much time visitors spend on each web page of our website(s),
   how visitors navigate through the website(s), and how we may tailor our
   website(s) to better meet the needs of our visitors. We also use this
   Information for compliance with our legal obligations, policies and
   procedures, including the enforcement of our Terms and Conditions.
 * If we collect Information from “offline” sources – such as if you provide us
   your business card at a trade show – we will maintain that information and
   use it for marketing and business purposes, as well.


HOW ANTERIAD SHARES THE INFORMATION WE COLLECT THROUGH OUR WEBSITES

We may sometimes share or otherwise disclose the Information we collect about
you, as described in this Privacy Policy or otherwise disclosed to you when you
provide us with the information, including as follows:

 * We may share the Information with service providers who help us deliver the
   services you request or we provide.   For instance, we share the Information
   with tech and customer support providers, marketing and advertising
   providers, other data providers (such as to enhance or verify our
   Information), security and data hygiene vendors, payment vendors (as to our
   business to business information), and other companies that may help us
   deliver or develop Services.
 * We may share the Information to communicate with you and market to you,
   including through email, direct mail or display media.
 * We will disclose your PII (or other Information) if we believe in good faith
   that we are required to do so by law, regulation or other government
   authority or to protect the rights, safety or property of ourselves or any
   person or entity. We may also cooperate with law enforcement agencies in any
   official investigation and we may disclose any Information to the requesting
   agency in doing so.
 * If we or all or substantially all of our assets, are purchased by another
   company (such as in a merger, consolidation, restructuring, the sale of stock
   and/or assets, or other corporate change or financing transaction), the
   Information in our possession will likely be transferred to the successor
   entity.  We also may share the Information during the course of any due
   diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and
operational purposes and to market to you (such as to retarget ads to you when
you visit other sites across the Internet).


7. LINKS

This website may provide links to other websites that Anteriad thinks users will
find interesting or useful. Anteriad is not responsible for the privacy
practices of these other sites or companies.


8. SECURITY AND DATA INTEGRITY

Anteriad takes steps to help ensure that the data we possess is housed and
transmitted securely. This may include various types of physical and electronic
security, including firewall protections, encryption, hashing or truncation of
data, and access controls to personal information.  While neither we nor any
platform can guarantee 100 percent safety from hacks or illegal intrusion, we
employ efforts that are designed to ensure that this does not occur.


9. CHANGES TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. Any changes to it will
become effective when it is posted to our website, unless we indicate a later
effective date. Please check back to learn of any changes to this Privacy Policy


10. STORAGE OF INFORMATION IN THE UNITED STATES

If you are accessing our website from outside of the United States, your
connection likely will be through and to servers located in the United States
and all Information you provide will likely be processed and securely maintained
in our web servers and internal systems located within the United States.  (We
generally store the Information used in our Services in the United States.)  
Thus, you should be aware that in accessing this website or otherwise
communicating with us, the information we collect or receive from you may be
subject to laws with lesser or different privacy standards than those in your
own country (such as if you are in a country located in the European Union).


11. CAN SPAM, CALOPPA, CASL ACTS AND YOUR CHOICES AND ACCESS RIGHTS

The CAN-SPAM Act of 2003

Anteriad upholds and adheres to The CAN-SPAM Act of 2003 which establishes
regulations for commercial email, including what information must be included in
an email message, the types of messages that are prohibited, and how to
unsubscribe from commercial emails.

The CAN-SPAM Act was passed in response to concerns about the increasing amount
of spamming and other deceptive marketing practices. The law establishes
requirements for commercial messages, gives recipients the right to have Email
Marketers stop emailing them.

CAN-SPAM contains seven requirements that Anteriad adheres to in order to avoid
unsolicited email spamming.

 * Be honest and transparent in your header (including from, to, and routing
   information)
 * Do not be deceptive in your subject lines
 * Disclose the email as an advertisement
 * Provide your physical postal address in the body
 * Give instructions for opting out
 * Honor opt-out requests within ten business days
 * Ensure processors or third parties comply with CAN-SPAM

CalOPPA

Anteriad upholds and adheres to CalOPPA and requires that any person or company
whose website collects personally identifiable information from Californian
consumers must feature a conspicuous Privacy Policy stating exactly what
information is collected and with whom it is shared. This includes tracking of
online visits for marketing purposes.

The law applies to email marketing because it requires:

 * A Privacy Policy, and
 * Transparency about what kinds of personal data your app or website collects
 * To comply with the law’s requirements, it’s necessary to include a statement
   within our Privacy Policy that we collect email addresses and whether we
   share them with third parties or not.

Anteriad ensures that we provide subscribers with a means of opting out of email
marketing campaigns.

CASL

Anteriad upholds and adheres to CASL, or Canada’s anti-spam legislation,
protects consumers and businesses from misusing digital technology, including
spam and other electronic threats. It also aims to help companies stay
competitive in a global, digital marketplace.

CASL covers “Commercial Electronic Messages” (CEM), which is a bit broader than
simply applying to emails. For example, it also covers instant messages, text
messages, and social media messages that are related to commercial activities.

CASL, like the GDPR, touches on consent. Anteriad adheres to the requirements
for implied consent, such as (making a purchase, donation, gift, providing
volunteer time or resources, providing an email address, or publishing an email
address).

If Anteriad do not meet the conditions of implied consent, Anteriad obtains
express consent from subscribers. This requires either a written agreement or an
oral agreement from the subscriber stating that they consent to receive digital
communications from our or our client’s business.

If you wish to opt out of email marketing campaigns, please click here.


12. THE GDPR AND YOUR CHOICES AND ACCESS RIGHTS WITH RESPECT TO PERSONAL DATA

If you are a resident of one of many European countries, including the United
Kingdom, an important European privacy law (or an equivalent counterpart) the
General Data Privacy Regulation (the “GDPR”) provides you with certain rights,
and places certain obligations on companies, regarding how your “personal data”
(as the GDPR uses that term) is used.  We describe those rights and obligations
below, and how and in what circumstances we honor them.  (Please only rely on
this Section 11 if you are in fact a resident of such a country – it will not
apply otherwise.)

Legal Basis. The GDPR requires us to tell you about the legal ground we’re
relying on to process any “personal data” (as the GDPR uses that term) about
you. The legal grounds for us processing your personal data for the purposes set
out in Section 2 above will typically be because:

 * You provided your (legally sufficient) consent;
 * It is necessary for our contractual relationship, e.g., in order to provide
   you services or features you’ve requested and we’ve promised;
 * The processing is necessary for us to comply with our legal or regulatory
   obligations – for instance, to communicate with you about or to help honor
   your legal rights; and/or
 * The processing is in our legitimate interest. For instance, we may process
   and share business data (such as a person’s business email or address and job
   title) in order to assist our customers to send relevant business-related
   communications. (As an example, if you are a technology attorney, we might
   help a privacy foundation or legal association send you an invitation to a
   privacy law conference by providing or validating for them your most recent
   contact information.)   

Your rights. Your rights to access, correct, delete or withdraw consent. right
to request access to a copy of your personal data, or request that we correct or
“rectify,” restrict or delete Your personal data, You may exercise these rights
by contacting us at privacy@Anteriad.com or through our website privacy portal
located at Form. If you request that we delete your personal data, or withdraw
your consent, we will customarily retain a copy of your data sufficient to
suppress it from our active databases in the future:  but if that is not what
you wish, you may indicate that to us (in which case your information may be
added to our database later, because we will not have “suppressed” it).

Moreover, when we delete your personal data, we may retain it (to the extent
legal permissible) for certain important (but narrow) internal purposes such as
legal, compliance, accounting or auditing purposes. Likewise, when you request
access to your information, we are required — for privacy and other important
compliance reasons — to verify your identity in a legally sufficient manner: if
we cannot do so, we will not be able to satisfy your access request.

Personalized Online Advertising Opt Outs has been amended to the following:
Personalized Online Advertising Opt-Outs. You may object to profiling by online
advertising platforms with whom we sometimes partner to help generate (and
measure or analyze) “personalized” online advertising. These platforms are
generally separate third party “controllers” of your data. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies are
being sent. To learn how you can manage your Flash cookie settings, visit the
Flash player settings page on Adobe’s website. If you disable or refuse cookies,
please note that some parts of the Website may then be inaccessible or not
function properly. To opt-out of our collection and use of data for online
interest-based advertising on your browser (including a mobile browser if
third-party cookies are enabled in your browser) from companies participating in
the Digital Advertising Alliance Consumer Choice Page, please visit
www.aboutads.info/choices. To opt out of advertising solutions that tailor ads
shown within mobile apps based on your likely interests, please either set the
preference on your mobile device to limit ad tracking or download the Digital
Advertising Alliance’s AppChoices app and configure it to opt out of any Digital
Advertising Alliance participating company. For more information on this and to
opt out, please visit www.policies.google.com/privacy,
www.adssettings.google.com/ or www.optout.networkadvertising.org/.

If you are located in the European Union or European Economic Area, you can also
opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu.To
opt-out of the collection and use of data for interest-based advertising on your
mobile device, you can also modify the settings on your mobile device. Please
note that after choosing to opt-out via any of the methods above, if you use a
different device or a different browser, or if you delete browser cookies, you
may need to repeat the opt-out steps for that particular device or browser. In
addition, if you block cookies on your browser or if third-party cookies are
blocked by default, some of the opt-out tools above may not function.

You may unsubscribe from marketing and other communications that we may send (on
behalf of ourselves or others) by clicking the “opt-out” or “unsubscribe” link
in the footer of those emails.

Questions or Concerns.  If you have a complaint or concern or question about how
we handle your personal data, please contact us as at the above contact
addresses, and we will seek to address any concerns you may have.  If you are
not happy with how we have attempted to resolve your complaint, you may contact
the relevant data protection authority.

When We are a Processor. EU data protection law makes a distinction between
organisations that process personal data for their own purposes (known as “data
controllers”) and organisations that process personal data on behalf of other
organisations (known as “data processors”).   Anteriad sometimes acts as a data
controller (for instance, when we make decisions about the data that comprises
our own datasets) and sometimes acts as a processor (for instance, when we
ingest information that belongs to a customer, such as a “CRM” file that we help
analyze).   We generally are only able to help data subjects exercise their
rights as to data we are a data controller of.   If you have a question or
request as to data we’re a processor of, you should generally address that to
the relevant data controller.


13. PRIVACY SHIELD/TRANSFER OF YOUR INFORMATION?

On July 16, 2020, the European Court of Justice invalidated Privacy Shield as a
Transfer Mechanism for data between EU and US companies. Anteriad intends to
utilize the alternate transfer mechanism of Standard Contractual Clauses going
forward for data transfers. Even though Privacy Shield was invalidated, Anteriad
will continue to honor its commitments with respect to EU personal data
transferred pursuant to Privacy Shield before July 16, 2020.

Anteriad LLC (referred to herein as “Anteriad,” “we,” “us,” or “our” as
applicable), has created this Privacy Shield Privacy Notice to help you
understand how we are subject to and comply with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework. These frameworks are
established by the U.S. Department of Commerce regarding the collection, use,
and retention of personal information transferred from the European Union
(“EU”), the United Kingdom (“UK”), and Switzerland to the United States.
Anteriad has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles. If there is any conflict between the terms in this
Notice and the Privacy Shield Principles, the Privacy Shield Principles shall
govern.

Anteriad is committed to educating individuals, our clients, and employees in
the United States and in the EU, the UK, and Switzerland about the issues,
guidelines and laws surrounding compliance with Privacy Shield. To learn more
about the Privacy Shield program, and to view our certification, please
visit https://www.privacyshield.gov/list.


SCOPE

Anteriad collects, stores, transfers, and processes Personal Data in accordance
with applicable data protection law, including where it is necessary to provide
our Premium Services, to perform the Terms of Use, or to perform obligations
under contract. We may transfer your information to affiliates, partners and
other third parties as described herein. We will protect your Personal Data in
accordance with this Privacy Policy wherever it is processed.

The type of Personal Data transferred to Anteriad from the EU, the UK and
Switzerland pursuant to Privacy Shield consists of Personal Data from clients in
the EU, the UK and Switzerland that Anteriad processes on behalf of its clients,
such as end-user name, address, email and transaction information. Since the
requirements for compliance with Privacy Shield vary depending on whether we are
acting as a Processor on behalf of our clients or as a Controller, our policies
and manner of compliance are described separately below.

The practices we employ under the EU-U.S. Privacy Shield, as outlined also apply
to data transferred from Switzerland to the United States in compliance with the
Swiss-US Privacy Shield Framework. Anteriad will adhere to the Privacy Shield
Principles with respect to data transferred pursuant to the Privacy Shield
Principles for as long as it retains such data.


PURPOSES OF DATA PROCESSING

Anteriad acts as a data processor with respect to Personal Data we receive from
our clients and process such information only under the instruction of our
clients and are controlled by our clients in the EU, the UK and/or Switzerland.
In this capacity, we do not own or control any of the information we process on
behalf of our clients. All such information is owned and controlled by our
clients. In this capacity, we receive information transferred from the EU, the
UK and Switzerland to the United States merely as a Processor on behalf of our
clients.

Before starting any processing on behalf of our clients, we enter into a
processing contract with the Controller that ensures the Controller is in
compliance with the General Data Protection Regulations (“GDPR”) or Member State
Data Protection law that may apply. The processing contract will also specify
that the processing will be carried out with appropriate data security measures.
We have measures in place designed to protect Personal Data from loss, misuse,
unauthorized access, disclosure, alteration and destruction.

Any data processed by us will not be further disclosed to third parties except
where permitted or required by the processing contract, Privacy Shield, GDPR, or
the applicable Member State Data Protection law. Any information our client
(acting as the Controller) identifies as sensitive, will be treated accordingly.

When Anteriad provides business and consumer information products, we act as a
Controller of the Personal Data contained in the information products. As a
Controller, we share Personal Data with third parties that fall into various
categories: clients, vendors and partners. Our clients include but not limited
to financial, retail, insurance, and automotive companies.  Our vendors include
data suppliers and service providers. We also share Personal Data with partners
such as other data resellers for marketing purposes. When we act as a Controller
of Personal Data, the policies outlined apply to all Personal Data that has been
transferred from the EU, the UK or Switzerland to the United States.

Anteriad and its affiliates located in the EU, the UK or Switzerland, develop
and maintain Personal Data on data subjects, households, and businesses located
throughout EU Member States, the UK or Switzerland. This information is obtained
from public records, publicly available information, information acquired
through information providers, and information collected directly from data
subjects.

This information is provided to qualified businesses for marketing, customer
data integration, and connectivity purposes. This information may also be used
to provide information services, enhance the understanding a company has about
its customers, aid in accurate integration of a company’s customer information,
and be used as lists for direct marketing purposes.


NOTICE

We may be required to disclose Personal Data in response to lawful requests by
public authorities, including requests to meet national security or law
enforcement requirements. Prior to the transfer of Personal Data from the EU,
the UK or Switzerland to the United States, we require contractual confirmation
from the Controller from whom we acquired the information that the Personal Data
has been provided to us in accordance with GDPR, Privacy Shield, or the
applicable EU Member State Data Protection law, thereby ensuring the data
subjects have been provided with proper notice regarding how their Personal Data
will be used. In addition, when Personal Data is collected directly from data
subjects, we provide the data subject with notice regarding the manner and
circumstances in which the Personal Data will be used and transferred to third
parties.


CHOICE

We provide choices and means for individuals to limit the use of their Personal
Data. In addition to providing individuals with choices regarding our use of
their information, we will remove an individual’s name and related information
from our direct marketing information products if they request it. Consumers may
request an opt-out form by writing Anteriad at the address below, sending an
e-mail to us at privacy@Anteriad.com or via a Form.

To request an opt-out form by mail, write to:

Privacy Officer
EU-US Privacy Shield Opt-Out
Anteriad LLC
2 International Drive, Rye Brook, New York NY10573


ONWARD TRANSFER

Since we share Personal Data with third parties as referenced above, we comply
with the notice and choice principles as described above for all data disclosed
or transferred to a third party. We take reasonable and appropriate steps
designed to ensure that the third party effectively processes the Personal Data
transferred in a manner consistent with our obligations under the Principles.

When we use data processors to perform processing tasks on our behalf and at our
direction and instruction, we require our data processors either:

 * Subscribe to the Privacy Shield (in the case of US-based processors), comply
   with the General Data Protection Regulations (in the case of EU, UK or
   Switzerland -based processors), or another adequacy finding (in the case of
   processors in countries outside the US, EU, UK, or Switzerland); or
 * Enter into a written agreement with us requiring the data processor(s) to
   process the data only for limited and specified purposes and to provide the
   same level of protection as Anteriad

In cases of onward transfer to third parties, we may be liable for the acts of
the third party that are in violation of the Privacy Shield Principles.


SECURITY

We have an information security policy in place designed to protect Personal
Data from loss, misuse, unauthorized access, disclosure, alteration, and
destruction. Our Chief Information Security Officer is primarily responsible for
conducting investigations into any alleged computer or network breaches,
incidents or problems and ensuring that proper disciplinary action is taken
against those who violate our Information Security Policy.


DATA INTEGRITY

We take reasonable steps designed to ensure the information transferred from the
EU, the UK or Switzerland to the United States is reliable, accurate, and
complete. The steps we take to assure data integrity are based on the purposes
for which the Personal Data is used.


ACCESS

An individual may request access to the Personal Data processed pursuant to the
Privacy Shield we maintain in our information products. Individuals have the
right to learn whether data about him or her is found in our information
products and to correct, amend or delete that information when it is inaccurate.
This right applies only to Personal Data about the individual making the request
and is subject to other limitations as defined by law. Individuals can request
access by writing or sending an email request to privacy@Anteriad.com.

Privacy Officer
Anteriad LLC
3 International Drive
Rye Brook, New York NY10573

Anteriad’s Privacy Officer will explain the process for making an access
request. In order to confirm the identity of the individual and the necessary
information to retrieve the individual’s information, Anteriad’s Privacy Officer
will provide a form for the individual to fill out, sign, and return to
Anteriad.

We agree to process all reasonable requests for access within a reasonable time
period but reserve the right to deny access or limit access in cases where the
burden or cost of providing access would be disproportionate to the risks to the
individual’s privacy or when the request is manifestly unfounded or excessive.


RECOURSE, ENFORCEMENT AND LIABILITY

We have Annual Data and IT Security Awareness Certification requirements for
each of our employees. This training includes our Privacy Shield compliance
program implementation. Our employee policies contain clear statements that
training and annual refresher courses in our privacy practices, including our
participation in the Privacy Shield Frameworks, are required and failure to
complete such training and annual refresher courses may result in discipline up
to and including termination. Part of this program includes a certification log
which provides an objective review of employee compliance with our Privacy
Shield certification training.

Individuals who wish to make inquiries, file a complaint, or who take issue with
our Privacy Shield practices or policies as described herein should contact
Anteriad’s Privacy Officer at privacy@Anteriad.com.

Anteriad’s Privacy Officer will explain the process to be followed when filing a
complaint.

Under certain conditions, an individual may invoke binding arbitration to
resolve residual claims. We are subject to the investigatory and enforcement
powers of the U.S. Federal Trade Commission. In addition, we agree to cooperate
with local EU Data Protection Authorities or the Swiss Federal Data Protection
and Information Commissioner to resolve a dispute concerning an alleged breach
of the Privacy Shield Principles.

In compliance with the Privacy Shield Principles, Anteriad commits to resolve
complaints about our collection or use of your personal information. EU and
Swiss individuals with inquiries or complaints regarding our Privacy Shield
policy should first contact Anteriad, LLC at: Privacy@anteriad.com

Anteriad has further committed to refer unresolved Privacy Shield complaints to
the American Arbitration Association (AAA)’s Independent Conflict Dispute
Resolution ICDR/AAA Program, an alternative dispute resolution provider located
in the United States. If you do not receive timely acknowledgment of your
complaint from us, or if we have not addressed your complaint to your
satisfaction, please visit www.adr.org/Support for more information or to file a
complaint. The services of ICDR/AAA Program are provided at no cost to you.


14. CHILDREN’S PRIVACY

Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age
16 may provide any information to or on the Website. We do not knowingly collect
personal information from children under 16. If you are under 16, do not use or
provide any information on this Website or on or through any of its features. If
we learn we have collected or received personal information from a child under
16 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 16, please
contact us at privacy@anteriad.com.

California residents under 16 years of age may have additional rights regarding
the collection and sale of their personal information. Please
see your-california-rights for more information.


15. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, the California Consumer Protection Act
(CCPA) provides certain rights of disclosure, access and deletion of your
Information as described below in the “Addendum for California Residents” at the
end of this Privacy Policy.


16. CONTACT US

Anteriad has a designated privacy contact.  If you have questions related to
this Privacy Policy, or regarding our products or services, please contact us:

Attn: Privacy Officer

Anteriad, LLC

2 International Drive, Suite 300,

Rye Brook, NY 10573, USA

Email: privacy@Anteriad.com

We appreciate your comments and questions regarding Anteriad’s privacy
practices.

———————————————————————


ADDENDUM FOR CALIFORNIA RESIDENTS


CALIFORNIA PRIVACY RIGHTS

Last Modified:  June 23, 2022

 


NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY
PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to
residents of California. This section of the Privacy Policy applies if you are a
natural person who is a resident of California (“California Consumer”) and uses
our Services.  This Addendum supplements the information in the Privacy Policy. 
However, this Addendum is intended solely for, and is applicable only as to,
California Consumers:  if you are not a California Consumer (or a resident of
California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

 1. Our Collection of Personal Information – the types of Personal Information
    (which the CCPA defines broadly) that we collect, the types of sources we
    collect it from,
 2. Our Disclosure and Sale of Personal Information – the types of recipients to
    whom we disclose or sell Personal Information.
 3. Our Business Purposes –  our business purposes for (a) collecting and (b)
    sharing Personal Information, which are generally the same.
 4. Your California Privacy Rights and Choices – what rights you have under the
    CCPA, for instance, to request that we “opt out” your information from our
    marketing database (also called “do not sell” rights), or to request
    categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes
for which we may use California Consumers’ personal information:


1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories
of information summarized in the table below. The following table also describes
how we collect and use such categories of information.

Category

Categories of Sources

Identifiers, e.g., name; alias; postal address; mobile ad identifiers;  IP
address; telephone number; email address; social network handles

 * Data compilers and consumer data resellers, informational and retail websites
   (“Commercial Source Categories”)
 * Public records and other publicly available sources
 * Government entities
 * Social networks

Characteristics of protected classifications under California or US law
(inferenced or actual, including self-reported)

E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)

 * Commercial Source Categories
 * Public records and other publicly available sources
 * Government entities
 * Social networks

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.

 * Commercial Source Categories
 * Public records and other publicly available sources

Internet or other electronic network activity information

E.g., browsing history; online interests.

 * Commercial Source Categories

Geolocation data

 * Commercial Source Categories

Professional or employment-related information

E.g., current or past job history or job title.

 * Commercial Source Categories
 * Public records and other publicly available sources

Inference Data

E.g., consumer information or preferences.

 * Commercial Source Categories

 


2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above
for various business purposes, with service providers and with third parties
including our customers.  The chart below how and with whom we share or disclose
personal information, and whether (based on the CCPA’s definition of “sell”) we
believe we have “sold” a particular category of information in the prior 12
months.

Category

Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months



Identifiers, e.g., name; alias; postal address; mobile ad identifiers;  IP
address; telephone number; email address; social network handles

 * Data compilers and consumer data resellers, consumer goods retailers,
   informational and retail websites, content publishers, non-profit
   organizations, business-to-business services and organizations, consumer
   surveys and survey companies, affiliate networks (“Commercial Recipient
   Categories”)
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Characteristics of protected classifications under California or US law
(inferenced or actual)

E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Internet or other electronic network activity information

E.g., browsing history; online interests.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers, and social networks

 Yes

Professional or employment-related information

E.g., current or past job history or job title.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Inference Data

E.g., consumer information or preferences.

 * Commercial Recipient Categories
 * Advertising networks and media platforms, political campaigns, internet
   service providers, data analytics providers
 * Social networks

Yes

Location data

 * Geolocation information, e.g., tied to a device identifier.

No


WE ALSO MAY SHARE ANY OF THE PERSONAL INFORMATION WE COLLECT AS FOLLOWS:

Sharing for Legal Purposes:  In addition, we may share personal information with
third parties in order to: (a) comply with legal process or a regulatory
investigation (e.g. a subpoena or court order); (b) enforce our Terms of
Service, this Privacy Policy, or other contracts with you, including
investigation of potential violations thereof; (c) respond to claims that any
content violates the rights of third parties; and/or (d) protect the rights,
property or personal safety of us, our platform, our customers, our agents and
affiliates, its users and/or the public.  We likewise may provide information to
other companies and organizations (including law enforcement) for fraud
protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal
information in the event of a major corporate transaction, including for example
a merger, investment, acquisition, reorganization, consolidation, bankruptcy,
liquidation, or sale of some or all of our assets, or for purposes of due
diligence connected with any such transaction.

Sharing With Service Providers:    We share any personal information we collect
with our service providers, which may include (for instance) providers involved
in tech or customer support, operations, web or data hosting, billing,
accounting, security, marketing, data management, validation, enhancement or
hygiene, or otherwise assisting us to provide, develop, maintain and improve our
services.

Sharing of Aggregate Information:  We may aggregate and/or de-identify any
information collected so that such information can no longer be linked to you or
your device (“Aggregate/De-Identified Information”).  We may use
Aggregate/De-Identified Information for any purpose, including without
limitation for research and marketing purposes, and may also share such data
with any third parties, including advertisers, promotional partners, and
sponsors, in our discretion.


3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we
collect for the following purposes, as we also have described in our Privacy
Policy and/or our website.


OUR PURPOSES FOR COLLECTING, USING AND SHARING PERSONAL INFORMATION

Data marketing services, for example:

 * Generally, creating data marketing tools and products for our marketer
   clients, as more fully described in our Privacy Policy (and on our
   websites).   This includes our provision of datasets, data “appends”
   (connecting data across datasets), data “scoring” (providing inferences about
   potential consumer behavior), data hygiene services (helping customers to
   evaluate, validate and correct personal information they hold), and security
   and anti-fraud services (helping customers to identify potentially fraudulent
   activity).
 * Helping our Clients identify and understand their consumers better, by
   providing insights about them and managing loyalty programs, as well as
   providing financial and other scoring products.
 * Assisting our Clients through our Services to provide their current and
   prospective customers with better service, improved offerings, and special
   promotions, for instance, advising on which current or prospective customers
   are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

 * Creating or helping to create defined audience segments based on common
   demographics and/or shared (actual or inferred) interests or preferences
   (e.g., households with prospective students). When we do this, we work with a
   data partner that “matches” our or other Information through
   de-identification techniques (such as through coded data “hashing”) with
   online cookies and other identifiers, in order to target and measure ad
   campaigns online across various display, mobile and other media channels.
 * Assisting Clients in creating “identity” graphs, to help locate users across
   various channels, such as based on common personal, device-based, or
   network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example (which may overlap with “data
marketing services” above):

 * Assisting in targeting and optimizing of direct mail and email campaigns,
   display, mobile and social media marketing.
 * Measuring the effectiveness of online or offline ad campaigns by determining
   which messages are most likely to be seen or opened by which types of
   consumers, or which types of ads are most likely to lead to purchases.
 * Analyzing and optimizing our Clients’ (or their service providers’)
   proprietary databases, or helping Clients to identify and mitigate potential
   fraud.
 * Providing “verification” or data “hygiene” services, which is how companies
   update and/or “clean” their databases by either verifying or

Operating our Services, for example:

 * Improving, testing, updating and verifying our own database.
 * Developing new products.
 * Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security
incidents, debugging, short-term and transient use, quality control, and legal
compliance.

We sometimes use the information collected from our own website,  from social
networks, from other “business to business” interaction (such as at trade shows)
or from data compilers for the above, as well as for our own marketing purposes.




4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California
residents have the right to request that we disclose what personal information
we collect from you, to delete that information, and to opt-out of the sale of
your personal information, subject to certain restrictions. You also have the
right to designate an agent to exercise these rights on your behalf. This
section describes how to exercise those rights and our process for handling
those requests.  (To the extent permitted by applicable law, we may charge a
reasonable fee to comply with your request.)

Sometimes, we act only as a “service provider” to our clients (for instance, if
they provide information to us for analytics, processing or other data
management services), in which case any consumer requests for opt-out, deletion
or access to data must be made through that client:  we will forward any such
requests to a named client, as feasible, but we recommend making any requests
directly to the company you wish to direct the request to.


A. RIGHT TO “OPT-OUT” OF THE SALE OF YOUR PERSONAL INFORMATION

California residents may opt out of the “sale” of their personal information.
California law broadly defines what constitutes a “sale” – including in the
definition making available a wide variety of information in exchange for
“valuable consideration.”

Depending what information we have about you, and whether we have included any
of it in our marketing products and services, we may have sold (as defined by
California law) certain categories of information about you in the last 12
months, as described in the above table in Section II of this Addendum,
titled OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION.


B. RIGHT TO REQUEST ACCESS TO YOUR PERSONAL INFORMATION

California residents have the right to request that we disclose what categories
of your personal information that we collect, use, or sell.  As explained in
Section (D) below, you may also request the specific pieces of personal
information that we have collected from you.  (We may withhold some personal
information where the risks are too great to permit disclosure of the
information.)


C. RIGHT TO REQUEST DELETION OF YOUR PERSONAL INFORMATION

As explained further in Section (D) below, you may also request that we delete
any personal information that we collected from , such as if you have been a
customer of ours.  (Note that this is different from your right to “opt out” of
us selling your personal information, which is described below; also note that
we do not generally collect personal information directly from consumers.) 
However, we may retain personal information for certain important purposes, such
as (a) to protect our business, systems, and users from fraudulent activity, (b)
to address technical issues that impair existing functionality (such as
de-bugging purposes), (c) as necessary for us, or others, to exercise their free
speech or other rights, (d) to comply with law enforcement requests pursuant to
lawful process, (e) for scientific or historical research, (f) for our own
internal purposes reasonably related to your relationship with us, or to comply
with legal obligations.  Additionally, we need certain types of information so
that we can provide our Services to you.  If you ask us to delete it, you may no
longer be able to access or use our Services.


D. HOW TO EXERCISE YOUR ACCESS, AND (IF APPLICABLE) DELETION RIGHTS

Access:  California residents may exercise their California privacy rights by
sending an email to privacy@Anteriad.com, submitting their removal request
through our form, or by contacting us at 1-800 368 7602.

Because it is required by California law (and also, for security purposes), we
will verify your identity – in part by requesting certain information from you
or by requesting you demonstrate possession of a particular identification
method (such as an email account) — when you request to exercise your California
privacy rights.  For instance, if you request categories or specific pieces of
personal information we have received about you, you may need to confirm your
possession of such an identifier (such as an email address) or to provide a
piece of identification that confirms you are the person you claim to be.

Once we have verified your identity, we will respond to your request as
appropriate:

 * Where you have requested the categories of personal information that we have
   collected about you, we will provide a list of those categories.
 * Where you have requested specific pieces of personal information, we will
   provide the information you have requested, to the extent required under the
   CCPA and provided we do not believe there is an overriding privacy or
   security concern to doing so.

Deletion:  Where you have requested that we delete personal information that we
have collected from you, we will seek to confirm whether your request is for an
“opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us
to maintain your information for “suppression” purposes – i.e., to prevent us
from selling information about you in the future (which is what many consumers
requesting “deletion” actually desire to occur), we try to explain this in order
to ensure we are meeting consumers’ preferences.  (In addition, “deletion”
rights only apply to information that we have collected “from” consumers – which
does not apply to much of the information in our databases.)


E. RIGHT TO NONDISCRIMINATION

We do not deny to you, charge different prices for, or provide a different level
of quality of goods or services to you, if you choose to exercise these rights.


F. INFORMATION ABOUT PERSONS UNDER THE AGE OF 16

We do not knowingly collect personal information from minors under 16 years of
age in California unless we have received legal consent to do so. If we learn
that personal information from such California residents has been collected, we
will take reasonable steps to remove their information from our database (or to
obtain legally required consent).


G. AUTHORIZED AGENTS

You may also designate an agent to make requests to exercise your rights under
CCPA as described above. We will take steps both to verify the identity of the
person seeking to exercise their rights as listed above, and to verify that your
agent has been authorized to make a request on your behalf through providing us
with a signed written authorization or a copy of a legally sufficient power of
attorney.  We likewise may require that you verify your own identity, depending
on the type of request you make.


H. NOTICE TO EMPLOYEES/APPLICANTS

As you have self-reported that you are a resident of California, we are serving
notice that the Company collects and retains certain information about you.

California’s Consumer Privacy Act (“CCPA”) and California Privacy Rights Act
(“CPRA”) provides California employees and applicants with certain rights:

 * Knowledge of information collected;
 * Deletion of information collected;
 * Opt-out of information collected;
 * Opt-in of information collected;
 * Correction of information collected;
 * Go to court;
 * Limit use of information collected;
 * Not to be discriminated or retaliated against for exercising rights under the
   law.

Where We Get Your Information From. The Company collects information about you
from the following sources: 1) you; 2) prior employers, references, recruiters,
job-related social media platforms; 3) third-party sources of demographic
information; 4) third-party companies, such as background check companies; and
5) claim administrators and investigators. Depending on the Company’s
interactions with you, we may or may not collect all of the information
identified about you.

The Personal and Sensitive Personal Information That We Are Collecting. We are
collecting the following information:

 * Identifiers, such as name, government-issued identifier (e.g., Social
   Security number), and unique identifiers (e.g., employee ID);
 * Personal information, such as legal name, signature, SSN, physical
   characteristics or description, address, telephone number, passport number,
   driver’s license or state identification card number, passport number,
   federal identification authorizing work in the United States, access and/or
   passcodes, insurance policy number, education, employment, employment
   history, bank account number, other financial information, medical
   information, or health insurance information;
 * Characteristics of protected classifications under California or federal law,
   such as age, marital status, gender, sex, race, color, disability,
   citizenship, primary language, immigration status, military/veteran status,
   disability, request for leave, and medical conditions;
 * Commercial information, such as transaction information and purchase history
   (e.g., in connection with travel or other reimbursements);
 * Internet or network activity information, such as browsing history and
   interactions with our online systems and websites and any personal
   information that you provide while accessing the Company’s computer systems,
   such as personal credit card information and passwords;
 * Geolocation data, such as device location from usage of the Company’s
   devices;
 * Biometric information related to access to the Company’s secured access
   points;
 * Audio, electronic, visual, and similar information;
 * Professional or employment-related information, such as work history and
   prior employer;
 * Non-public education information; and
 * Inferences drawn from any of the Personal and Sensitive Personal Information
   listed above to create a profile or summary about, for example, an
   individual’s preferences and characteristics.

How Your Personal and Sensitive Personal Information is Used. We may use
Personal and Sensitive Personal Information:

 * To operate, manage, and maintain our business;
 * For hiring, retention, and employment purposes;
 * To otherwise accomplish our business purposes and objectives, including, for
   example:
   * Emergency services;
   * Conducting research, analytics, and data analysis;
   * Maintaining our facilities and infrastructure;
   * Quality and safety assurance measures;
   * Conducting risk and security controls and monitoring;
   * Protecting confidential and trade secret information;
   * Detecting and preventing fraud;
   * Performing identity verification;
   * Performing accounting, audit, and other internal functions, such as
     internal investigations;
   * Complying with the law, legal process, and internal policies;
 * Maintaining records;
 * Claims processing;
 * Responding to legal requests for information and subpoenas; and
 * Exercising and defending legal claims.
 * Any other purposes authorized by the California Privacy Protection Agency,
   California or Federal law.

We may or may not have used Personal and Sensitive Personal Information about
you for each of the above purposes.

Sharing of Personal Information. We only share your information with the
following current third-party entities:

 * US payroll provider (ADP)
 * Health & welfare benefit registration platform (Employee Navigator)
 * Health & welfare benefits insurance broker (IMA)
 * Employee benefit carriers (UnitedHealthcare, Optum, Unum, Advanced Benefit
   Strategies)
 * 401(k) plan recordkeeper (Principal)
 * 401(k) plan third party administrator (Prime Pensions, Inc.)
 * 401(k) plan advisor (Pallas Capital Advisors)
 * Applicant Tracking System (Greenhouse)
 * Corporate Learning Management System (Cornerstone)
 * Legacy Performance Review System (Darwinbox)
 * Employee Travel & Expense Platform (Emburse Certify)
 * Corporate Intranet (Jostle)
 * Background Screening Services (Good Hire/Checkr, HireRight)
 * Email Licensing Platform (Microsoft)
 * Telephone Extension Service (OneBox)
 * Lenders for Employment Verifications (Employee Selected and Authorized)

The Company may also use other third-party companies to operate, manage and
maintain our business.

Selling of Personal Information. The Company DOES NOT sell your personal
information.

Data Retention. The Company retains the information it receives about you for a
period of: seven (7) years, unless a shorter or longer period is required by
California or Federal law.

For Inquiries and/or to Submit Requests for Information, Deletion or Correction.
Please contact Heather Buxton, Chief People Officer, 914-368-1112,
hbuxton@anteriad.com, 2 International Drive, Rye Brook, NY 10573 for inquiries
about the Company’s policy, or to submit your requests for information, deletion
or correction.

For more information, about Data that the Company collects, stores and
transfers, please refer to the Company’s Privacy Policy.

Anteriad respects your privacy and strives to uphold all applicable privacy laws
in our business relationship with you.

December 20, 2022

Anteriad

Headquarters

2 International Drive
Rye Brook, New York 10573

914-368-1000

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