California Privacy Policy

Last updated: January 1, 2023

California Consumer Privacy Act (as amended by California Privacy Rights Act)

This section contains disclosures required by the California Consumer Privacy Act of 2018 (“CCPA”) and applies only to personal information of California residents that is subject to the CCPA.

Our Information Processing Practices

Below is a chart showing categories of personal information that Retail Media Labs operating companies (including subsidiaries and joint ventures, collectively as “Retail Media Labs” or “We”) may have collected, sources and purposes of the collection, categories of personal information that we have disclosed to third parties, categories of the third parties, and purposes of the disclosure in the preceding 12 months.

Category	Source	Purpose	Disclosed/shared with third-party businesses	Retention period
Identifiers (e.g. name, email address, phone number)	Online forms visitors submitted on Retail Media Labs websites	When site visitors fill out forms on Retail Media Labs websites, they may be contacted by Retail Media Labs representatives and/ or may receive newsletters/ webinar invitations regarding Retail Media Labs’ services/products.	Microsoft Dynamics	Retail Media Labs keeps your information for as long as necessary to carry out the purposes for which we collect such information, we need it to provide services/products, comply with legal obligations or protect our or other’s legitimate interests.
Protected classes	Not applicable	Not applicable	Not applicable	Not applicable
Commercial information (e.g. purchasing or consuming histories)	Not applicable	Not applicable	Not applicable	Not applicable
Biometric information	Not applicable	Not applicable	Not applicable	Not applicable

Category	Source	Purpose	Disclosed/shared with third-party businesses	Retention period
Network activity information (e.g. browsing history, search history)	Analytics tracking tools on Retail Media Labs websites by third- party providers, including: ▪  Google Analytics ▪  Google Ads ▪  Piano.io ▪  Hotjar ▪ Microsoft Clarity ▪  Facebook Ads ▪  LinkedIn Ads	Retail Media Labs collects certain information about visitor activities on our electronic networks, such as how consumers interact with our websites and apps. We use this information to help determine what pages or features are popular or where our products and services could be improved. We may also use such information for marketing purposes with your consent or on other applicable legal basis.	We share this information with Google Ads, Facebook Ads, and LinkedIn Ads so we can present our offerings to relevant visitors. We disclose this information to Piano. Piano.io allows us to handle transactions and improve the overall user experience of the website based on behavior and any information that visitors submit to us. We disclose this information to Google Analytics so we can improve our marketing of products and services. We disclose this information to Hotjar and Microsoft Clarity because they allow us to observe session behavior and make observations that create a better user experience.	Google Ads retains information on user behavior for a maximum of 540 days. You can learn more about the cookies Google Ads and Google Analytics set here: https://business.safety.google/adscookies/ Meta cookies have a lifespan of 365 days. You can learn more about Meta Advertising cookies here: https://www.facebook.com/policy/cookies/ LinkedIn Ads cookies are retained for 13 months. Information about LinkedIn cookies can be found here: https://www.linkedin.com/legal/l/cookie-table The longest Piano cookie stays with visitors for 2 years. You can see how long each of those cookies is stored here: https://docs.piano.io/track/piano-cookie-descriptions/ Hotjar retains information for 365 days. You can learn more about the cookies set by Hotjar here: https://help.hotjar.com/hc/en-us/articles/6952777582999- Cookies-Set-by-the-Hotjar-Tracking-Code Microsoft Clarity data will be retained for the webmaster’s consumption up to 30 days. You can learn more information about the cookies Clarity sets here: https://learn.microsoft.com/en-us/clarity/data-retention

Category	Source	Purpose	Disclosed/shared with third-party businesses	Retention period
Geolocation data	Location information in online forms that visitors submitted on Retail Media Labs’ websites Analytics tracking tools on Retail Media Labs’ websites by third- party providers, including: ▪  Google Analytics ▪  Google Ads ▪  Piano.io ▪  LinkedIn Ads ▪  Facebook Ads	Retail Media Labs serves content to people in different locations to ensure products, site functionality, and messaging are relevant to visitors.	▪ Microsoft Dynamics ▪ Google Analytics ▪ Google Ads ▪ Piano.io ▪ LinkedIn Ads ▪ Facebook Ads	Retail Media Labs keeps your geolocation information collected from online forms in Microsoft Dynamics. We store it for as long as necessary to carry out the purposes for which we collect such information, we need it to provide services/products, comply with legal obligations or protect our or other’s legitimate interests. For third-party analytics tracking tools, please refer to their respective cookie retention policy as indicated above.
Sensory data	Not applicable	Not applicable	Not applicable	Not applicable
Employment information	Not applicable	Not applicable	Not applicable	Not applicable

Category	Source	Purpose	Disclosed/shared with third-party businesses	Retention period
Education information	Not applicable	Not applicable	Not applicable	Not applicable
Profile inferences	Piano.io	Retail Media Labs uses Piano.io cookies to collect your information as the basis to recommend topics and offers that are relevant to you or your browsing activities.	Piano.io	The longest Piano cookie stays with users for 2 years. You can see how long each of these cookies is stored here: https://docs.piano.io/track/piano-cookie- descriptions/
Sensitive personal information	Not applicable	Not applicable	Not applicable	Not applicable

Your California Privacy Rights

If you are a resident of the state of California, you are entitled to make certain requests regarding your personal information. Retail Media Labs will fulfill each of these requests per the requirements of California law.

The CCPA provides Californians with the following rights:

1. Right to know. You can request access to a copy of personal information we have about you, including a list of categories of your personal information that we have and/or specific pieces of personal information that we have.
2. Right to correct. If we maintain inaccurate personal information about you, you can request us to correct that inaccurate personal information.
3. Right to delete. You can request that we delete your personal information. We honor such requests unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when information is being used to detect, prevent, or investigate security incidents, comply with legal obligations, identify and repair errors, or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
4. Do not sell my personal information. You can request us not to sell your personal data to third parties. “Sell” or “sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by Retail Media Labs to a third party for any valuable consideration.
5. Do not share my personal information. You can request that we stop sharing your personal information. “Share” or “sharing” means sharing, disclosing, or otherwise making available your personal information to a third party for cross-context behavioral advertising, but not necessarily a monetary benefit.

You can use this online request form or email us at support@retailmedialabs.com if you are interested in exercising any of the above rights.

Please note that Retail Media Labs does not use or disclose your sensitive personal information for any purpose other than what is specified in section 7027, subsection (m) of the CCPA Regulations.

Retail Media Labs uses certain companies to place tracking technologies like cookies and pixels on our websites, which allow those companies to receive information about your activity on Retail Media Labs websites that is associated with your browser or device. Those companies may use that data to serve you more relevant contents and ads on our websites or others. Except for this kind of selling or sharing, Retail Media Labs doesn’t otherwise sell or share your personal data.

We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please know, if you ask us to delete your personal information, it may impact your experience with us, and you may not be able to participate in certain programs or services which require usage of your personal information to function.

We understand the importance of protecting the privacy of minors, especially in the online environment. Our websites are not designed for or intentionally targeted at minors under the age of 18. We do not knowingly collect data from minors. If we become aware that we have received data from a person under the age of 18, we will take reasonable steps to delete such data from our records.

Verifying Your Identity For Requests to Know, Correct, or Delete

Because we want to avoid taking action regarding your personal information at the direction of someone other than you, only you or an “Authorized Agent” permitted to act on your behalf may submit a request. The CCPA also requires that we verify the identity of each person who makes a request.

To verify your identity, we will ask you to provide your:

• First name
• Last name
• Email address
• State residency
• Phone number (optional)

We will seek to match any personal information you (or an Authorized Agent) provide when submitting your request to any personal information we already maintain. In some instances, we may ask you to provide additional information and/ or documentation to verify your identity. If that happens, we will reach out to you directly with our request. We will use the additional information you provided solely for the purpose identified in this section.

What if We Can’t Verify Your Identity?

If we can’t verify your identity, we will not be able to process your request to
know what personal information we have about you, to correct your inaccurate information, or to delete the personal information we have about you. If we are unable to verify your identity with a high degree of certainty, we will only be able to provide a report with category-level information and we may not be able to correct or delete some of your personal information.

How to Submit A Request Using an Authorized Agent

An Authorized Agent is a person or business who has authorization to exercise California privacy rights on behalf of a consumer. Authorized agents use the same form or email described above to submit requests.

If you are submitting a request on behalf of another person, we require you to provide proof that the consumer gave you signed permission to submit the request. This can be a letter or other documentation signed by the consumer authorizing you to submit this request.

We may also require the consumer to verify their own identity directly with us, or directly confirm with us that they provided the authorized agent permission to submit the request.