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BOMBORA | PRIVACY POLICY

Last updated: June 10, 2021

GDPR

Data privacy requests

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CCPA

Do not sell my data

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Overview

Bombora, Inc. and its global subsidiaries (collectively, “Bombora”, “we”, “us”,
or “our”) value the privacy of each person (“you” or “your”) whose information
we collect or receive. This privacy notice (“Privacy Notice“) explains who we
are, how we collect, use and share personal information about you, and how you
can exercise your privacy rights.

The Privacy Notice covers personal information we collect:

1. a) When you provide information to the Bombora hosted platform and
related analytics products.
2. b) When you visit one of our corporate websites (such as
https://bombora.com, https://www.signal-hq.com/, https://www.netfactor.com/)
(“Website“) and/or provide information to Bombora over the usual course of
our business practices, such as in connection with our events, sales and
marketing activities (see ‘privacy for our websites’).

Quick links

We recommend that you read this Privacy Notice completely to ensure you are
fully informed. However, to make it easier for you to review those parts of this
Privacy Notice which may apply to you, we have divided up the Privacy Notice
into the following sections:

Who we are

List of our Services

Privacy for our services

Privacy for our websites

General information

Managing your personal information with us

Other important information

IAB Europe Transparency & Consent Framework

CCPA Consumer Request Metrics

1. WHO WE ARE

One of the primary ways Bombora collects data is from a proprietary data
cooperative (“Data Co-op”). The Data Co-op consists of business to business
(“B2B”) websites of publishers, marketers, agencies, technology providers, and
research and event firms that contribute content consumption data to a massive
pooled data set that details the buying intent of a company.

Co-op members provide consent-based brand-anonymous data, including Unique IDs
(including Cookie IDs), IP address, page URL and referrer URL, browser type,
operating system, browser language, and engagement data (including dwell time,
scroll velocity, scroll depth and time between scrolls) (collectively, “Event
Data”). Engagement data validates You are actually consuming content and not
quickly bouncing from the website. The full data set is refreshed weekly.

Bombora collects the Event Data, analyses the content You consumed on the
website, and assigns the content topics using the Bombora topic taxonomy
(“Topics”).

When Bombora is able to identify from Your Event Data which company You
represent (“Company Name/URL”), Bombora aggregates the Topics and Company
Name/URL to a company profile, including all events of other employees from the
same Company Name/URL.

The tag collects your actions but the actions are assigned to a company.

Bombora provides the following hosted platform and related analytics products
(collectively the “Services”) to its clients (“Subscribers”):

SERVICES

1.1 Company Surge® Analytics

An analytics report listing company name, topic and Company Surge® score. To
create the score Bombora collects, stores, organizes, uses and erases data which
is anonymized and aggregated such that no personal data exists. Bombora will not
disclose any data to a company other than company name, topics searched, and
Company Surge® score. These reports are created by collecting data from tags on
publisher websites. The Bombora Tag (defined below) collects IP address (which
is anonymous and converted to company URL), engagement metrics, and topics
(which are determined by real time algorithm). The topics (based on Bombora’s
B2B taxonomy) are attributed to company name. Our proprietary algorithm compares
topic interest over 30 Billion interactions to create a score. That score is the
company’s interest level in the topics, compared over time.

1.2 Audience Solutions

Audience Solutions is a data product that supports the process of digital ad
buying or ad targeting by our customers. Audience Solutions and Measurement
Products append data to, and share, a Cookie ID. Bombora appends firmographic
and demographic data to the Cookie ID, only at the domain (name of website) and
at the company level.

The firmographic and demographic data may include industry, functional area,
professional group, company revenue, company size, seniority, decision maker and
predictive signals. Bombora does not share any data which could be used to
identify You, an individual data subject.

* Facebook integration: As fully described in ‘‘what we do and collect and
why’, through the Bombora integration with Facebook, Bombora uploads
audiences derived from hashed emails associated with domains into Facebook.
Facebook matches these hashed emails against their database of users to
create a custom audience for targeting.
* LinkedIn integration: Through the LinkedIn Marketing Developer Platform API,
Bombora sends Company Surge® Intent data as a list of domains (e.g.,
companyx.com) into LinkedIn. LinkedIn matches its users to domains to create
a matched audience for targeting within the LinkedIn Ad Platform.

1.3 Measurement Products

The following Measurement suite of products collect demographic and firmographic
information. The Bombora Tag is (Bombora term) a JavaScript or pixel tag placed
on the websites of Subscribers which collects data from each device which visits
the Subscriber’s websites including (1) placement and synchronization of unique
identifiers, such as cookie ID or hashed email; (2) IP address and information
derived therefrom, such as city and state, company name, or domain name; (3)
engagement level data, such as dwell time, scroll depth, scroll velocity, and
time between scrolls; (4) page URL and information derived therefrom such as
content, context and topics; (5) referrer URL; (6) browser type and (7)
operating system (collectively the “Bombora Tag”). Each of the products in the
measurement suite uses information collected from the Bombora Tag in different
ways to provide subscribers with an end product.

* Audience Verification: With our Audience Verification product, a Subscriber
places a tag on their campaign creative. The audience verification tag is
able to collect the following data insights when You click the advertisement:
Unique IDs (including Cookie IDs), IP address and information derived such as
geography, User agent, browser type and operating system (OS).
* Visitor Insights: With our Visitor Insights product, a Subscriber places a
tag on their website. (We also have placed the Bombora Tag on our Websites).
The visitor insights tag collects insights about website visitors, including
but not limited to the following data: (i) overall visitor engagement
segmented by high, medium, and low percentages; (ii) overall visitor
engagement compared to previous date ranges; (iii) total companies, unique
users, sessions and page views; (iv) total companies, unique users, sessions
and page views compared to previous date ranges; (v) engagement by company
domain segmented by high, medium, and low and (vi) unique users, sessions,
and page views by company domain. This data can be delivered through the
Bombora user interface, from a daily feed, or directly from the Google
Analytics platform.
* Visitor Track: Visitor Track is used along with certain software tools, such
as JavaScript, to measure and collect session information. We do this in
order to analyze traffic to our Website, and to better understand the needs
of our customers and visitors. Some examples of the information we collect
and analyze include the Internet protocol (“IP”) address used to connect your
computer to the Internet; computer and connection information such as browser
type and version, operating system, and platform; the Uniform Resource
Locator (“URL”) referring page to our Website along with each page viewed,
including date and time.

Through the Services, Bombora provides data to our Subscriber to help them
better connect and target organizations they want to reach (we refer to the
individuals in those organizations as “End Users”). Bombora and its partners
engage in tracking End Users’ interactions with business-to-business content
across various digital properties like web registration forms, widgets, websites
and webpages (whether accesses via computer, mobile or tablet device or other
technologies) (“Digital Properties”). We then take this data and aggregate the
information collected into demographic segments, such as company revenue and
size, functional area, industry, professional group, and seniority. This helps
Subscribers customize engagement based on topics that organizations are
interested in and the intensity of their consumption.

2. PRIVACY FOR OUR SERVICES

This section describes how we collect and use information we receive or collect
from End Users through our Services (we refer to this collectively as
“Service Information“). This includes details about the type of information we
collect automatically, the types of information we receive from other sources
and the purposes of those collections.

2.1 What information do we collect and why?

Information we collect automatically:
We use and deploy various cookies and similar tracking technologies
(see ‘cookies and similar technologies’ ) to automatically collect certain
information about your device when you interact with Digital Properties that use
our technology. Some of this information, including your IP address and certain
unique identifiers, may identify a particular computer or device and may be
considered “personal data” in certain jurisdictions including in the European
Economic Area (“EEA“) and the United Kingdom (“U.K.”). However, for its
Services

For the services that we provide, Bombora does not collect any information that
we reverse engineer to enable us to identify you personally such as your name,
mailing address or email address. The information we collect is not used to
identify you as an individual.

We collect this information by assigning a random unique identifier (“UID“) to
your device the first time you interact with a Digital Property that uses our
technology. This UID is then used to associate you with information we collect
about you.

The information we automatically collect may include:

* Information about your device such as the type, model, manufacturer,
operating system (e.g. iOS, Android), carrier name, time zone, network
connection type (e.g. Wi-Fi, cellular), IP address and unique
identifiers assigned to your device such as its iOS Identifier for
Advertising (IDFA) or Android Advertising ID (AAID or GAID).
* Information about your online behavior such as information about the
activities or actions you take on Digital Properties we work with. This may
include time spent on a web page, whether you scroll or click on an ad or a
web page, session start/stop time, time zone, your referring website address,
and geo-location (including city, metro area, country, zip code and
potentially geographic co-ordinates if you have enabled location services on
your device) pages and times visited.
* Information about ads served, viewed, or clicked on such as the type of ad,
where the ad was served, whether you clicked on it and the number of times
you have seen the ad.

Information we receive from other sources
We may also combine, merge, and/or enhance the information we collect about you
(collectively “Service Information’). This can include the information we
collect about you with information collected from third parties such as other
web-based and mobile networks, exchanges and websites (“Partners“) or
our Subscribers (for example, they may upload certain “offline” data into the
Services). Here is a list of our current partners. In addition, the Service
Information we automatically collect may be combined and associated with
business profile information that we infer about you, such as: age, domain,
functional area, household income, income status and changes, language,
seniority, education, manufacturing, professional group, industry, company
revenue, and net-worth.

This information may include hashed identifiers derived from other information
such as email addresses, mobile device IDs, demographic or interest data (like
your industry, employer, company size, job title or department) and content
viewed, or actions taken on a Digital Property.

We use the Services Information as follows:

* To provide the services to our Subscribers. Generally, we use the Service
Information to help Subscribers better understand their current and
prospective customers and market trends. This enables Subscribers to better
target and customize websites, content, other general marketing efforts and
to measure and optimize the performance of their marketing.
* To build various inferenced data segments (“Data Segments”). We may use the
Service Information to build Data Segments related to, for instance, the
industry you are in or the type of content you or the organization you work
for appear to be interested in. We use these Data Segments to help our
Subscribers understand their own customers, evaluate customer and market
trends and create reports and scoring regarding their customer’s behavior.
The Data Segments also may be associated with UIDs, cookies and/or mobile
device advertising IDs.
* To do “interest-based advertising”. We sometimes use or work with Subscribers
and Partners that use UIDs or other information derived from information such
as email hashes. This information in turn may be associated with cookies and
may be used to target ads to you that are based on “offline” interest-based
segments – such as your interests, transactions or demographic information –
or used by Subscribers that target and analyze such ads. This is often known
as “interest-based advertising.” You can find out more about this type of
advertising at the DAA’s website.
* To do cross-device tracking. We (or our Partners and Subscribers we work
with) may use the Service Information (e.g. the IP addresses and UIDs) to try
to locate the same unique users across multiple browsers or devices (e.g.
smartphones, tablets or other devices), or work with providers that do this
in order to better target ad campaigns to common sets of End Users. For
example, a brand may wish to target customers that it usually recognizes on
web browsers through mobile apps.
* To do “user matching”: We (or our Partners) may use the Services Information,
in particular various UIDs, to sync cookies and other identifiers with other
Partners and Subscribers (i.e. to do “user matching“). For example, in
addition to the UID’s an End User has been assigned in our system, we may
also receive a list of UIDs our Partners or Subscribers have assigned to an
End User. When we identify matches, we then let our Subscribers and Partners
know in order to help them do any of the above, including enhancing their own
data and Data Segments to do interest-based advertising or provide insights
to other customers. For instance, we use Facebook Custom Audiences to match
users.
* As we believe to be necessary or appropriate under applicable law including
laws outside your country of residence:

1. to comply with legal processes
2. to respond to requests from public and government authorities including
authorities outside your country of residence
3. to enforce our terms and conditions
4. to protect our operations or those of any of our affiliates
5. to protect yours, our affiliates and/or our rights, privacy, safety or
property
6. to allow us to pursue available remedies or limit the damages that we may
sustain.

* To evaluate, operate or improve the Services.

2.2 Cookies and similar technologies

Our Partners and our Subscribers use various UIDs, cookies and similar tracking
technologies to automatically collect information from End Users across various
Digital Properties (as previously described above). Please review our Cookie
Statement for further information.

2.3 Legal basis for processing personal information (EEA residents only)

If you are an individual from the EEA or the U.K., our legal basis for
collecting and using personal information described herein will depend on the
personal information concerned and the specific context in which we collect it.
However, we normally rely on our legitimate interests to collect
personal information from you, except where such interests are overridden by
your data protection interests or fundamental rights and freedoms. Where we
rely on our legitimate interests to process your personal information, they
include the interests described in the ‘what information do we collect and
why’ section above. Bombora participates in the IAB Transparency and Consent
Framework (TCFv2.0) and uses legitimate interest as our basis for collecting
data for the following purposes:

* Measure ad performance (Purpose 7)
* Apply market research to generate audience insights (Purpose 9)
* Develop and improve products (Purpose 10)

In some cases, we may rely on our consent or have a legal obligation to collect
personal information from you or may otherwise need the personal information to
protect your vital interests or those of another person. If we rely on consent
to collect and/or process your personal information, we will obtain such consent
in compliance with applicable laws.

Under the IAB’s TCFv2 Bombora uses Consent as our basis for collecting data for
the following purposes:

* Store and/or access information on a device (Purpose 1)
* Create a personalized ads profile (Purposes 3)

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal information, please contact us
using the contact details provided below or complete the ‘contact us’ form.

3. PRIVACY FOR OUR WEBSITES

This section describes how we collect and use information from users of our
Websites, visitors to our Websites and in the usual course of our business in
connection with our events, sales and marketing activities.

3.1 Information we collect

Certain parts of our Websites may ask you to provide personal information
voluntarily.

3.2 Information you provide to us

1. For Marketing Purposes such as requesting a demo, expressing an interest in
obtaining additional information about Bombora or our Services, subscribe to
marketing emails. The personal information we collect may include:
1. first and last name
2. business email
3. phone number
4. professional information (e.g. your job title, department or job role) as
well as the nature of your request or communication.
2. When applying for a job on our career page by submitting an application,
the personal information we collect may include:
1. first name and last name
2. mailing address
3. telephone number
4. employment history and details
5. email address
6. contact preferences
7. professional information (e.g. your job title, department or job role) as
well as the nature of your request or communication
8. voluntarily asking you to provide U.S. Equal Opportunity Employment
Information
9. voluntarily asking you to provide your disability status

3. When you register for an account to gain access to Bombora’s User Interface,
the personal information we collect may include:

1. 1. 1. First name and last name
2. email
3. password

You may also provide us with personal information by contacting us via email or
completing a contact form on our website.

3.3 Information we collect automatically

When using our Website, we may automatically collect certain information from
your device. In the state of California and some countries including countries
in the European Union (“EU”) and the U.K., this information may be considered
personal data under data protection laws. The information we automatically
collect may include your IP address, Unique IDs (including Cookie IDs), IP
address, page URL and referrer URL, information about your operating system,
your browser ID, your browsing activity and other information about your system,
connection and how you interact with our Websites. We may collect this
information as a part of log files as well as through the use of cookies or
other tracking technologies as explained further in our Cookie Statement.

3.4 Information we collect from third party sources

We may partner with certain third parties to collect information on our Websites
to engage in analysis, auditing, research, reporting and to deliver advertising
that we believe may interest you based on your activity on our Websites and
other websites over time. These third parties may set and access cookies on your
computer or other device and may also use pixel tags, web logs, web beacons, or
other similar technologies. For more information about these practices and how
to opt out, please see our Cookie Statement.

3.5 How we use the information we collect

We will use your personal information for the following purposes:

* To respond to or provide you with information you request
* To provide and support our Websites and Services
* If you have an account with Bombora, to send administrative or account
related information to you
* If you have applied for a role with Bombora, for recruitment related purposes
* To post testimonials with your prior consent
* To communicate with you about our events or our partner events
* To provide you with marketing and promotional communications (where this is
in accordance with your marketing preferences). For more information about
managing your marketing preferences, please see ‘your data protection
rights’ below.
* To comply with and enforce applicable legal requirements, agreements and
policies
* To prevent, detect, respond and protect against potential or actual claims,
liabilities, prohibited behavior and criminal activity
* For other business purposes such as data analysis, identifying usage trends,
determining the effectiveness of our marketing and to enhance, customize and
improve our Websites and Services

4. GENERAL INFORMATION

This section describes how your information is shared, details about cookies and
other tracking technologies, your data protection rights and other general
information.

4.1 How do we share your information

Your personal information collected from our Services and Websites may be
disclosed as follows:

* Subscribers and Partners. If you are an End User, we share Service
Information with Subscribers and Partners for purposes relevant to our
business relationship with them and for purposes described in this
Privacy Notice. Our Subscribers and Partners are obligated to use the
information they receive in compliance with applicable laws and the
agreements with our Subscribers.
* Vendors, consultants and service providers. We also share the Service
Information with a variety of third-party service providers to help us to
operate, secure, monitor, operate and evaluate the Services. Examples of this
include to assist with technical, operational, or hosting support, software
and security services or to enable other services that we offer. For
Instance, the information that we collect for employment applications is
shared with Greenhouse Software, Inc. The software that we use for recruiting
management. We also use GoodHire to conduct background checks on employee
candidates.
* Website advertising partners. We may partner with third party advertising
networks and exchanges to display advertising on our Websites, or to manage
and serve our advertising on other sites and may share your personal
information with them for this purpose.
* Vital interests and legal rights. We may disclose information about you if we
believe it necessary to protect the vital interests or legal rights of
Bombora, you or any other person.
* Corporate affiliates and transactions. We reserve the right provide your
information to our affiliates (meaning any subsidiary, parent company or
company under common control with Bombora).
* Potential acquirers of our business. If Bombora is involved in a merger,
acquisition or sale of all or a portion of its assets, your information may
be shared or transferred as part of that transaction with the relevant
potential buyer, its agents and advisors, as permitted by law. Please note
that any potential buyer will be informed that they should use your
information only for the purposes disclosed in this Privacy Notice.
* Compliance with laws. We may disclose your information to any competent law
enforcement body, regulator, government agency court or other third party
where we believe disclosure is necessary:
i) as a matter of applicable law or regulation
ii) to exercise, establish or defend our legal rights
iii)to protect your vital interests or those of any other person.

If you are resident of the EEA and to the extent we are allowed to do so, we
will provide your data with adequate protection and provide you prior written
notice of any request to provide information to any competent law enforcement
body, regulator, government agency court or other third party in the United
States so that you can appeal and stop the disclosure of your information.

When Bombora provides its Services, the data that we collect is attributed to a
company and we do not reverse engineer the data to personally identify you so we
may be unable to provide you with such notice.

4.2 Cookies and other tracking technologies

We use cookies and similar tracking technology (“Cookies“) on our Websites to
collect and use personal information about you. For further information about
the types of cookies and other tracking technologies we use, why, and how you
can control Cookies, please see our Cookie Statement.

5. MANAGING YOUR PERSONAL INFORMATION WITH US

We strive to be as transparent as possible this section describes your data
protection rights. It’s important to us that you know that you have the right to
access, manage the data that we may have collected about you from third
parties.

You have the right to access this data at any time. It’s important that we
provide you with tools to object and, restrict the sale of your data, or
withdraw consent (where applicable) for the use of the data that we may have on
you. Please note, to help protect your privacy and maintain security, we take
steps to verify your identify through OneTrust. OneTrust is the secure
administrative software that we use to manage privacy request.

5.1 Data subject requests and your data protection rights

Please complete the data subject request form to request a copy of your platform
and/or business data from Bombora. The information you supply in this form will
only be used to identify the platform and/or business data you are requesting
and responding to your request. Once you submit a subject access request form we
will endeavor to respond to you within 72 hours of receipt of your request.
Please allow Bombora 27 days to process your request. You can also
email privacy@bombora.com with any questions or queries you have regarding your
data.

Any disclosures we provide will only cover the 12-month period preceding the
verifiable consumer requests. The response we provide will also explain the
reasons we cannot comply with a request, if applicable. Please note that because
most of the information we store can only identify a particular browser or
device, and cannot individually identify you. To help protect your privacy and
maintain security, we take steps to verify your identify in OneTrust. Making a
verifiable consumer request does not require you to create an account with us.
Before granting you access to your personal information or complying with
deletion, portability, or other related requests, you will need to provide us
with some additional information to enable us to identify the personal
information we hold about you and ensure that we accurately fulfill your
request.

You have the following data protection rights:

* You can request access to, or that we change, update or delete your
personal information, at any time by completing the above form. Please note
that we may impose a small fee for access and disclosure of your
personal information where permitted under applicable law which will be
communicated to you.
* In addition, if you are a resident of the EEA, you can object to processing
of your personal information, ask us to restrict processing of your personal
information or request portability of your personal information. To exercise
these rights please complete the above form.
* You can opt-out of receiving promotional emails from us by clicking the
“unsubscribe” link in the email or by completing the above form. Please
see ‘your choices’ for further information about your opt-out choices. If
you choose to no longer receive marketing information, we may still
communicate with you regarding your security updates, product functionality,
responses to service requests, or other transactional, non-marketing, or
administrative related purposes.
* If we have collected and processed your personal information with
your consent, then you can withdraw your consent at any time. Withdrawing
your consent will not affect the lawfulness of any processing we conducted
prior to your withdrawal, nor will it affect processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
* You have the right to complain to a data protection authority about our
collection and use of your personal information. Click here to access contact
details for data protection authorities in the EEA. If you are a consumer and
wish to open an Swiss-U.S. Privacy Shield case, please click here to file a
claim.

Opting-out of the sale of personal information

In addition to the data protection rights grated in this Privacy Notice, if you
are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”)
provides California residents with the right to opt-out of the sale of their
personal information, view the data Bombora may have collected over the past 12
months, and to know the following:

* The categories of personal information we have collected about you;
* The categories of sources from which the personal information is collected;
* The business or commercial purpose for collecting your personal information;
* The categories of third parties with whom we have shared your personal
information;
* The specific pieces of personal information we have collected about you.

In accordance with the Website, these are the categories of information we may
have collected on you and the purposes we may have used. The categories of
personal information we may have collected about you or your use of our Website
over the past twelve (12) months:

* Identifiers such as a real name, unique personal identifier, online
identifier; Internet Protocol address, email address, job position, and
company name;
* Personal: such as a name, education, employment information;
* Protected classification characteristics such as age and gender;
* Internet or other similar network activity such as browsing history, search
history, information on a consumer’s interaction with a website, application,
or advertisement;
* Geo location data such as metro area, country, zip code and potentially
geographic co-ordinates if you have enabled location services on your device.

For Employment and Job Application Purposes:

* Identifiers: such as name and address home address, telephone number, and
email address;
* Protected classification characteristics under CA Law: such as age, gender
and disability status;
* Personal Information: name and address home address, telephone number, email
address, education, employment, employment history;
* Professional or employment-related information: such as your job application,
resume or CV, cover letter, references, education history, employment
history, whether you are subject to prior employer obligations, and
information that referrers provide about you, references, language
proficiencies, education details, and information you make publicly available
through job search or career networking sites;

You can obtain more information on the categories of personal information
in ‘what we do and collect and why’.

We obtain the categories of personal information listed above from the following
categories of sources:

* Directly from you. For example, from forms you complete [information you
provide];
* Indirectly from you. For example, from observing your actions on our Website;
* From third party sources as set-forth in the [Information we collect from 3rd
Party sources]

For employment purposes

* Job board websites you may use to apply for a job with us;
* Prior employers that provide us with employment references

You can obtain more information on the sources of personal information
in ‘information we collect’. These are the business or commercial purposes for
which the personal information was collected:

* To fulfill or meet the reason you provided the information. For example, if
you share your name and contact information to request a demo, quote or ask a
question about our products or services, we will use that personal
information to respond to your inquiry.
* To provide, support, personalize, and develop our Website, products, and
Services.
* To personalize your Website experience and to deliver content and product and
service offerings relevant to your interests, including targeted offers and
ads through our Website, third-party sites, and via email (with your consent,
where required by law)
* For testing, research, analysis, and product development, including to
develop and improve our Website, products, and Services.

You can obtain more information on the Business or Commercial purposes for which
the personal information is collected in the sections, ‘what we do and collect
and why’ and ‘how we use the information we collect’.

These are categories of third parties with whom we have shared your personal
information:

* Data aggregators.
* Recruitment practices

You can obtain more information on the third parties with whom we have shared
your data with in ‘how do we share your information’. In the previous (12)
months, Bombora may have sold the following categories of personal information:

* Identifiers
* Personal
* Protected classification characteristics
* Internet or another similar network activity
* Geo location

You have the right to request certain information about our disclosure of
personal information to third parties for their own direct marketing purposes
during the preceding calendar year. This request is free. You also have the
right not to be discriminated against for exercising any of the rights listed.

California residents may also designate an agent to make requests to exercise
your rights under CCPA. As noted above Bombora will take steps both to verify
the identity of the person seeking to exercise their rights, and to verify that
your agent has been authorized to make a request on your behalf through
providing us with a signed Power of Attorney. You may only make a verifiable
consumer request for access or data portability twice within a calendar year.

California residents may exercise your rights described in this section by
visiting a privacy request form to exercise and the right to know the data we
may have on you. The right to request the deletion of the data we may have on
you. Click here to opt-out of the sale of your personal information. You can
also exercise these rights by emailing privacy@bombora.com with the subject “CA
Privacy Rights”.

5.2 Your choices

Opting-out of Bombora cookies

If you wish to opt-out of being tracked by us using cookies (including to
opt-out of receiving interest-based advertising from us), please go to
our opt-out page.

When you opt-out, we will place a Bombora cookie on or otherwise identify your
browser in a way that informs our systems not to record information related to
your business research activities. However, please note that if you browse the
web from multiple devices or browsers, you will need to opt-out from each device
or browser to ensure that we prevent personalization tracking on all of them.
For the same reason, if you use a new device, change browsers, delete the
Bombora opt-out cookie or clear all cookies, you will need to perform this
opt-out task again. To find out more about the use of cookies and how to opt out
of third-party cookies, please see our Cookie Statement.

Opting-out of interest-based advertising from cookies

As described above, to opt-out or receiving interest-based advertising from
Bombora’s Services through the use of cookies, please go to our opt-out page.

You may opt-out of interest-based advertising from numerous companies that
enable such advertising on those associations’ websites. Please access the DAA’s
opt-out portal to do this. You may also opt-out of some of the interest-based
advertising Partners that we work with by going to the Network Advertising
Initiative (NAI) consumer choice page.
You may opt-out of ad targeting that is based on your activities across mobile
applications and over time, through your device ‘settings’.

Opting-out of interest-based advertising in mobile applications
Our Subscribers and Partners may display interest-based advertising to you in
mobile applications based on your use of these over time and
across non-affiliated apps. To learn more about these practices and how to opt
out, please visit https://youradchoices.com/, download the DAA’s AppChoices
mobile app and follow the instructions provided in the AppChoices mobile app.

6. OTHER IMPORTANT INFORMATION

6.1 Data security

Bombora takes precautions to protect data and information under its control from
misuse, loss or alteration. Bombora has put in place appropriate technical and
organizational measures to protect the information it collects through its
Services and Websites. Bombora’s security measures include technology and
equipment to help protect our information, maintains security measures regarding
who may and may not access our information. Of course, no system or network can
ensure or guarantee complete security, and Bombora disclaims any liability
resulting from use of the Service or from third party hacking events or
intrusions.

6.2 Children

Our Websites and Services are not intended for children under 18 years old. If
you are aware of personal information we have collected from a child under 18,
we ask that you contact us via one of the methods listed in the ‘contact us’
section. If you are 16 years of age or older and a California Resident, you have
the right to direct us to not sell your personal information at any time (the
“right to opt-out”). We do not collect, store or sell the personal information
of consumers we actually know are less than 16 years of age.

6.3 Other websites

The Services or Websites may contain links to or integrations with other sites
that Bombora does not own or operate. This includes links from Subscribers and
Partners that may use the Bombora logo in a co-branding agreement, or websites
and web services that we work with in order to provide the Services. For
example, we might sponsor an event, or provide services in conjunction with
other businesses. Bombora does not control and is not responsible for these
parties’ sites, services, content, products, services, privacy policies or
practices.

Likewise, if you permit Service Information to be collected and used through a
website using the Services, you are choosing to disclose information to both
Bombora and the third party with whose brand the website is associated. This
Privacy Notice only governs Bombora’s use of your Service Information not the
use of any information by any other party.

6.4 International data transfers

Our servers and facilities that maintain our Websites, Services and the
information we collect are operated in the United States. With that said, we are
an international business, and our use of your information necessarily involves
the transmission of data on an international basis. If you are located in the
U.K. European Union, Canada or elsewhere outside of the United States, please be
aware that information we collect may be transferred to and processed in the
United States and other applicable territories in which the privacy laws may not
be as comprehensive as or equivalent to those in the country where you reside
and/or are a citizen.

However, we have taken appropriate safeguards to require that your personal
information will remain protected in accordance with this Privacy Notice.
This includes implementing the European Commission’s Standard Contractual
Clauses for transfers of personal information between our group companies,
which require all group companies to protect personal information they process
from the EEA in accordance with European Union data protection law. Our Standard
Contractual Clauses can be provided upon request. We have implemented similar
appropriate safeguards with our third-party service providers and partners and
further details can be provided upon request.

6.5 Data retention and deletion

We retain personal information we collect from you where we have an ongoing
legitimate business need to do so (e.g. to comply with applicable legal, tax or
accounting requirements, to enforce our agreements or comply with our legal
obligations).

When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize it. If this is not
possible (e.g. because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible.

California “Do Not Track”

California law requires that operators of websites and online services disclose
how they respond to a Do Not Track signal. Because there is not yet a common
understanding of how to interpret Do Not Track signals, we do not currently
respond to Do Not Track signals. However, we provide you with the ability to
opt-out of the use of tracking technologies used to send you interest-based
advertising as described above.

6.6 Changes to our Privacy Notice

We may revise this Privacy Notice from time to time to reflect changes in our
practices or in the applicable law. When such changes are material in nature we
will notify you either by prominently posting a notice of such changes prior to
implementing them or by directly sending you a notification. We encourage you to
review this Privacy Notice periodically. We will always show the date of the
latest modification date of the Privacy Notice at the top of the page so you can
tell when it has last been revised.

6.7 Contact us

If you have any questions about this Privacy Notice or Bombora’s privacy
practices, please contact our Data Protection Office by submitting the ‘contact
us’ form, or by mail using the details provided below:

US and EEA Residents

Attn: Havona Madama, Chief Privacy Officer – 102 Madison Ave, Floor 5 New York,
NY 10016

If you are resident in the EEA and the U.K. your data controller is Bombora,
Inc. Bombora is headquartered in New York, NY, USA. Find out more about us and
our services.

7. IAB EUROPE TRANSPARENCY & CONSENT FRAMEWORK

Bombora participates in the IAB Europe Transparency & Consent Framework (TCFv2)
and complies with its Specifications and Policies. Bombora’s identification
number within the framework is 163.

8. CCPA CONSUMER REQUEST METRICS

* CCPA 2021 Metrics

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