Our Services generally operate without direct interaction with individual consumers. Instead, we rely on data, including personal information, obtained from trusted third party data providers and partners that law fully collect such information and are responsible for providing any required notice and obtaining any required consent from consumers at the point of collection. Accordingly, references to “you” or “your” in this PrivacyPolicy refer to individuals whose personal information may be processed, used, or included within our data products or Services.

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If you have any questions about our privacy practices, please contact us as set forth in the “Contact Information” section below. If you are a resident of certain jurisdictions, including California, Colorado, Connecticut, Delaware, Iowa, Minnesota,Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas,Utah, Virginia, and other U.S. States with similar Privacy Laws (collectively,“Applicable States”), please see the additional disclosures at the endof this Privacy Policy.

For our privacy practices surrounding our website, job applicants, and mobile applications, please visit our Consumer Privacy Policy here: https://www.becausal.com/privacy-policy

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1. How We Collect Personal Information

We collect personal information in a variety of ways, depending on how individuals, clients, and partners interact with us. In most cases, we do not collect information directly from consumers, but rather obtain, derive, or generate information from trusted sources.

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We may collect or receive personal information as follows:

• From our data partners and suppliers, including commercial data providers, publishers, app developers, and other companies that lawfully collect and license consumer data for marketing, analytics, and advertising purposes.
• From our clients and advertising partners, who may provide pseudonymous identifiers, device identifiers, hashed contact data, or other audience information to enable data matching, activation, or measurement.
• ‍From  publicly available sources, as well as other information lawfully made available to the public.
• Through data modeling and analytics, where we derive or infer new attributes (for example, interests, demographics, or likely purchasing behavior) from other data points.‍
• From our corporate websites and communications, including information collected when business contacts visit our sites, request information, or engage with us for services.
• ‍From service providers and technology partners who support our operations, analytics, data enrichment, or security processes.

We may combine information obtained from different sources to create, validate, and improve our Services.

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2. The Categories of Personal Information We May Collect

Depending on how you interact with us, we may collect the following information:

• Contact Information, such as pseudonymous or hashed identifiers (for example, hashed email addresses) used for data matching or audience activation.
• Demographic Information, such as age range, gender, income range, or household size.
• Purchase Information, such as product category interests, purchase history indicators, or other commercial information related to consumer purchasing behavior.
• Location Data, such as city, ZIP code, or general geographic area. We do not collect or use precise geolocation.
• Device Information, such as mobile advertising identifiers (MAIDs), IP addresses, browser type, or other pseudonymous device identifiers provided by partners.
• Other Information Provided, such as limited business contact details or information voluntarily provided by clients or partners during business communications.
• Inferences, such as inferences drawn from any of the personal information identified and discussed in this Privacy Policy.

3. How We Use Personal Information

We may use your information for the following reasons, depending on your relationship with us:

• To provide you and our clients with our products and services as requested.
• To generate insights and enrich datasets (see “How We Use AI and ML”below for more information about our use of artificial intelligence and machine learning.)
• To match information with other data or supplement your information with other data that we may obtain directly or through third parties.
• To provide and deliver our data products and audience segments to our clients and partners.
• To operate, maintain, and improve our Services.
• To create, enhance, and validate audience segments, insights, and measurement tools.
• To respond to client inquiries, fulfill contractual obligations, and manage our business relationships.
• To comply with legal obligations, enforce our terms, and maintain the security and integrity of our systems.
• To conduct research, analytics, and quality assurance to ensure the accuracy and relevance of our Services.
• To detect and prevent fraud, misuse, or other prohibited activities.
• To support auditing, reporting, and regulatory compliance requirements.

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4. How We Disclose Personal Information

We may disclose or make available certain personal information that we collect, receive, or derive to the following categories of recipients and for the purposes described below. We generally disclose only pseudonymized, aggregated, or deidentified information in connection with our data products and Services.

• Clients and Advertising Partners. We may disclose personal information to our clients, advertising partners, demand-side platforms (DSPs), data management platforms (DMPs), and other partners that license or activate our audience segments for advertising, analytics, or measurement purposes.
• Consumer Brand Partners. We may disclose personal information to our clients who are manufacturers or brands of consumer products, as well as their advertising agencies, to help provide shopping-related offers, promotions, and marketing to you when you use our Services.
• Service Providers and Vendors. We may disclose personal information to service providers that perform operational or technical functions on our behalf, such as cloud hosting, data storage, analytics, modeling, auditing, security, or compliance services. These entities are contractually obligated to use the information only as necessary to provide services to us.
• Governmental, Regulatory, or Legal Requests. We may disclose information as required by applicable law, regulation, legal process, or government request, or to protect our rights, privacy, safety, or property, or that of our clients, partners, or the public.
• Corporate Transactions. We may disclose or transfer information in connection with a merger, acquisition, restructuring, sale of assets, or other corporate transaction involving all or a portion of our business.
• At Your Direction or With Consent. We may disclose information at your direction or when you authorize us to do so.
• Aggregate or Deidentified Information. We may disclose information in an aggregated, de-identified, or other form that cannot reasonably be used to identify an individual, for research, analytics, or similar purposes.

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5. Children's Privacy

You must be 18years or older to use our Services. Our Services are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 18 years of age. If a parent or guardian becomes aware that his or her child or minor has provided us with information without their consent, he or she should contact us at privacy@becausal.com.

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6. How We Use Cookies and Similar Technology

Our Services do not directly place cookies or similar tracking technologies on consumers’ browsers or devices for advertising purposes. Our audience segments may, however, be activated or made available to partners and platforms (such as demand-side platforms and data management platforms) that use cookies, mobile identifiers, or other technologies to deliver targeted advertising. Those partners are responsible for providing appropriate notice and obtaining consent for their use of such technologies.

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Please visit ourConsumer Privacy Policy here: https://www.becausal.com/privacy-policy for how we may use cookies and similar technologies on our consumer website and mobile applications.

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7. How We Use Artificial Intelligence and Machine Learning

We use artificial intelligence (“AI”) and machine learning (“ML”) technologies to, among other things, help organize and standardize information received from our licensed data partners.

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In some cases, limited personal information may be processed to prepare and align data for analysis. Once the data is standardized, our AI and ML systems analyze aggregated or deidentified information to identify patterns, create audience segments for our clients, measure advertising effectiveness, and enhance our services. We apply measures to help promote accuracy, fairness, and non-discrimination in these processes.

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We do not use personal information or audience data derived from our Services to make decisions that have legal or similarly significant effects on individuals, including decisions related to employment, credit, housing, or healthcare. OurAI and ML activities do not involve real-time tracking or profiling of identifiable individuals.

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8. Links to Third Party Websites

We may provide links to websites and other third party content that are not owned or operated by us. The websites and third party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.

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If you provide any personal information through a third party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

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9. Interested-Based Advertising

Our Services do not directly deliver advertisements to consumers or place cookies or similar technologies on individuals’ devices. However, when our audience segments are activated by our clients or advertising partners through demand-side platforms, data management platforms, or other AdTech systems, those partners may use cookies, pixels, mobile advertising identifiers, or similar technologies to deliver and measure targeted advertising on their own websites, apps, or networks. We are not responsible for the data collection or tracking practices of these third parties, and we encourage you to review the privacy policies of the advertising platforms and partners with whom you interact to learn more about their practices and your choices.

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To learn more about these practices and to exercise choices regarding interest-based advertising, you may visit the Digital Advertising Alliance’s opt out page(currently available at http://www.aboutads.info/choices/). You can also learn more about interest-based advertising  from theNetwork Advertising Initiative (NAI) by visiting their website (currently available at https://thenai.org/).

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Please note that opting out through opt-out tools will not stop advertising entirely; you may still see advertisements that are not based on interest-based data. You may also have additional rights related to targeted advertising, as described in the section “Additional Information for Residents of Applicable States” below.

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10. Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

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11. Additional Information for Residents of Applicable States

Depending on where you reside, you may have certain additional rights regarding your personal information. This section provides information for consumers residing in Applicable States in connection with the laws in those states, and other states with similar privacy laws (“ApplicableLaws”).

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Under these Applicable Laws, and for purposes of thisSection, “Personal Data” and/or “Personal Information” (collectively, “Personal Information) generally mean information that identifies, relates to, or describes a resident or household in one of theApplicable States, and, for Oregon residents, may also include information that is linkable or linked to a device. Personal Information and/or Personal Data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been deidentified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with state law. We do not reidentify Personal Information that has been deidentified.

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We make available or license certain Personal Information, such as pseudonymous identifiers and audience segments, to our clients and advertising partners, who may use that information to deliver online advertisements to individuals’ devices that are tailored to those individuals’ interest. Depending on your state of residence and under Applicable Laws, this activity may be considered “sharing,” “selling,” or “targeted advertising.” This Section provides details about the categories of Personal Information of consumers inApplicable States, and other U.S. states with similar privacy laws, that we have collected, disclosed, processed for purposes of targeted advertising,“shared,” or “sold” during the last 12 months, as well as the rights consumers have under Applicable Laws.

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Categories ofPersonal Information Collected, Disclosed, “Shared”, “Sold”, or Processed forTargeted Advertising: 

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The categories ofPersonal Information that we, under Applicable Laws, have collected, disclosed,“shared,” processed for purposes of targeted advertising, or “sold” in the past 12 months are listed below, along with the purposes for processing and the categories of third parties to whom each category of Personal Information was disclosed, “shared,” “sold,” or processed for the purpose of targeted advertising. Please note that we process certain categories of Personal Information in connection with targeted advertising, which may be considered “sharing” or “selling” under certain Applicable Laws. Depending on how you interact with us, we may not have processed Personal Information about you for each (or any) of these purposes.

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Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 18 years of age.

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Please note that we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

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Under Applicable Law,“sale” and “share” do not include, for example, the transfer of PersonalInformation as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

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Sensitive Personal Information

We do not process“sensitive” Personal Information of utilizing our Services for purposes other than those permitted by Applicable Law (such as to provide the services and for security purposes).

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DataRetention

We will retain your Personal Data and/orPersonal Information for the period necessary and proportionate to fulfill the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

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Purposes

We may use this Personal Information for the following purposes, including commercial purposes:

• To operate, manage, and maintain our business, systems, and infrastructure.
• To provide our products and services, including delivering data products and audience segments to ourclients and partners.
• To respond to requests, inquiries, and questions from clients, partners, or individuals.
• To accomplish our business purposes and objectives, including:
  
  • Developing, improving, and maintaining our data services, models, and related technology.
  • Generating insights and enriching datasets, including through the use of Artificial Intelligence (AI) and MachineLearning (ML) (see the section “How We Use AI and ML” above for more information).
  • Creating, enhancing, and validating audience segments, insights, and measurement tools.
  • Conducting research, analytics, and data analysis to ensure accuracy and relevance.
  • Performing quality and safety assurance measures.
  • Conducting risk and security controls and monitoring.
  • Detecting and preventing fraud, misuse, or other prohibited activities.
  • Performing identity verification and authentication.
  • Carrying out accounting, auditing, and other internal business functions.
  • Complying with applicable laws, legal processes, and internal policies.
  • Maintaining business records and documentation.
  • Exercising and defending

Depending on you interact with us, we may not have usedPersonal Information collected about you for each (or any) of these purposes.

Sources of Personal Information

We collectPersonal Information from a variety of sources, as permitted by applicable law, including from our data partners and suppliers, clients and advertising partners, publicly available sources, service providers, and through derived or modeled data created using analytics and AI/ML. All sources of personal information collected are noted in the “How We Collect Personal Information”and “The Categories of Personal Information We May Collect” sections above.

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Your PrivacyRights Under Applicable Laws

If you are a resident of an Applicable State, you may have the following rights with respect to any information about you that constitutes “Personal Information” or“Personal Data” depending on your state of residence.

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We are required bylaw to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by Applicable Law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request and any available appeal processes available to you.

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Right to Know andAccess Personal Information: You may request to access the following information we have collected and maintain about you: 

• The specific pieces of Personal Information we collected about you;
• The categories of Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or sellingPersonal Information about you; and,
• The categories of Personal Information about you that we sold, shared, or other wise disclosed and the categories of third parties (or, depending on your state of residence, a list of specific third parties) to whom we sold, shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

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Deletion of PersonalInformation: You may request that we delete your Personal Information.Depending on the scope of your request, we may refrain from granting your request, as permitted by Applicable Law. For example, we may be legally required to retain your Personal Information in our business records. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

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Opt Out of “Sale”, “Shares”, and Targeted Advertising: Depending on the state you reside in, you have the right to opt out of the “sale” of your data and the disclosure of your data for cross-context behavioral advertising/targeted advertising (known as a “share”in California). We also honor alternative opt out signals, such as the GPC.We process opt out preference signals in a frictionless manner.

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Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

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Non-Discrimination: You have the right to be free from unlawful discrimination for exercising their above-listed rights under Applicable Law.

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Right to Appeal: Depending on your state of residence, you may have the right to request an appeal of a denied consumer request. Please see below for how to submit an appeal.

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Authorized Agent

Depending on whether you reside in an Applicable State, consumers may have the right to submit a request through an authorized agent.If you are an authorized agent acting on behalf of a consumer to exercise a privacy right discussed in this section, you must be able to demonstrate that you have the requisite authorization to act on behalf of the consumer. We may also contact the consumer directly to verify his or her own identity and that the consumer granted you authorization to act on their behalf as an authorized agent. An authorized agent may also be permitted to act on behalf of a consumer in order to exercise certain opt-out rights.

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If you are an authorized agent trying to exercise rights on behalf of a consumer, please submit a request via the linked form here [https://www.becausal.com/data-subject-requests] and select the option for“Authorized Agent” under requestor type. We may request supporting verification information, which should include proof that you have the consumer’s authorization to act. Under certain circumstances, we may also require you to prove and verify your identity if you are acting as an authorized agent on behalf of a consumer.

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To Exercise Rights

In order to exercise your Right to Opt Out of “Sales” and/or “Shares”, please visit our "Do NotSell or Share My Personal Information" page.

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In order to exercise your other rights described above, please send an email privacy@becausal.com or submit a request through the linked form at [https://www.becausal.com/data-subject-requests]. Authorized agents may submit requests through the linked form. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

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12. Additional Information for Nevada Residents

Nevada residents have certain rights with respect to their covered information. We have provided information on the categories of covered information collected and the categories of third parties with whom this covered information may be disclosed above, as well as above in the “How We Collect PersonalInformation,” “The Categories of Personal Information We May Collect,” “How We UseYour Personal Information,” and “How We Disclose Personal Information” sections of this Privacy Policy.

If you would like to make a request to review and request changes to any of the covered information that we may have collected about you, please email us at [privacy@becausal.com] and specify that you are a Nevada resident in your email.

• If you would like to make a request to opt out of the sale, as defined by Nevada law, of covered information, please submit a request at [https://www.becausal.com/personal-information]. We are required by law to verify both the authenticity of the request and your identity prior to honoring your request. Failure to verify your identity may result in your request not being processed.

13. Information For Texas Residents and Metrics for California Related to Data Broker Activities

A.    Information for Texas Residents

The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (TexasSOS). Information about data broker registrants is available on the Texas SOS website.

B.    AnnualData Request Metrics for California

BECAUSAL is a registered data broker in California. As part of its registration requirements, BECAUSAL must compile and disclose information regarding their compliance with consumer requests under the CCPA for the previous calendar year. Please see the table below for information about the reporting period of January 1, 2024 – December 31, 2024.

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14. International Data Transfer

We are based in the United States. Any information you provide to us through use of theServices may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. We may need to send your personal information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to protect your privacy.

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15. Changes to Our Privacy Policy

This Privacy Policy may be amended from time to time. Any changes will be posted on this page. We will notify you of any material changes by, as applicable, placing a prominent notice on ourWebsites or otherwise as legally required.

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16. Contact Information

Questions about our Privacy Policy maybe directed to: privacy@becausal.com.