Data Privacy Policy of Causal IQ

Principles

CIQ implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, ensures data is only transferred internationally with a lawful basis, only contracts with processors and sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.

Personal Data

Personal data (or personal information) comprises all information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household, such as a real name, postal address, e-mail address, telephone number, payment information, and account ID. When other information is directly associated with personal data, that information may also be considered personal data. Information that is aggregated, de-identified, or anonymized is not considered personal data. Publicly available information that is made available from federal, state, or local government records, also may not be personal information.

CIQ complies with all applicable privacy legislation. For the purposes of compliance with The General Data Protection Regulation (GDPR) (EU) 2016/679 ("GDPR"), a controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed. CIQ is the controller of personal data provided by you through the www.causaliq.com website ("Our Website"). Personal data for which CIQ is the controller may be provided by you to us in the following situations: (i) if you are a Client you may be required to provide us with personal and corporate information, such as name, address, email address and other account information, to be able to access and use our services; (ii) as part of our sales efforts, we may collect and store data through online forms for contact purposes; (iii) if you are a prospective Client, you may provide us with personal data through Our Website when applying to join our network or via email when corresponding with our sales representatives; (iv) you may provide us with personal data when you send us inquiries relating to our services or in relation to this Data Privacy Policy.

The collection of personal data is based on legitimate interest according to the above and for the performance of a contract to which you and CIQ are the parties.

For the purposes of compliance with the California Consumer Privacy Act of 2018, CIQ is a covered business with respect to information that is provided by you, directly or automatically, when you visit Our Website. CIQ is not a covered business with respect to activities CIQ undertakes on behalf of its Clients, in which it acts as a service provider on behalf of its clients. CIQ encourages you to visit its Clients' websites, or contact its Clients directly, should you wish to learn more about their personal information practices, or to assert any rights under this law.

Collection of Personal Data and Other Information

By providing our technologies and services we may collect information about your device, its unique ID, operating system and browser as well as your IP address. The way you get in touch with us or our technologies and services determines the scope of how we collect and process personally identifiable information. Data as a general term may include all kinds of information such as your name, your address or information on your device (e.g. your operating system or browser).

a. When visiting our website www.causaliq.com or when you contact us

This section provides information on how and which data we may collect from visitors to Our Website and those individuals who contact us. This information may be provided by your directly, or may be collected automatically from your device.

i. Cookies

Our Website uses cookies. Cookies are small text files that are sent from our servers to your browser to be stored on your device. The cookie stores information, which is linked to respective devices used, and may include your IP address, or other device identifiers. Cookies help to improve and optimize the usability of websites and other online services, including our own websites and online services and those of others. If you are a registered publisher, the cookie will also manage and control your login and session on those parts of Our Website that are only available to registered publishers. Our use of cookies is strictly compliant with any applicable cookie and data privacy legislation.

Visiting and surfing on our website is possible without cookies. Most browsers accept cookies automatically. You may delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. You may also alter the security settings of your web browser to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites only, or to be notified before receiving cookies. Please note, however, that these settings may have negative effects on the usability and user guidance of websites and other online services. If you are a registered publisher, certain parts of Our Website may only be used fully if your browser allows cookies.

You may also opt out of our use of cookies relating to our website on a specific device by using the following link https://causaliq.com/opt-out. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.

You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.

Cookies used on our website are listed below.

ii. Third Party Cookies

Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party's website for more information about cookie management and how to "opt-out" of receiving cookies from them.

If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices.

b. When you contact us

Regardless of how you contact us, we may collect personal data, such as your contact and identification information, including name, title, email address, postal address, and phone number. We may also collect any other personal data you provide to us in your communications with us. We may receive this information directly from you, or automatically; for example, when you call us, we may receive your telephone number.

c. When you are our Client or becoming one

You need to register in our Network to obtain access to our platform and services as a publisher. If you enter into a contractual relationship with us and/or register in our Network, we record all data, including personal data, which has been provided by you such as your name, address, telephone number, email address. You can see from our online registration form which personal data in detail we record. We do not record any further personal data other than voluntarily provided by you (e.g. in response to a request for information).

In the event your application to become a Publisher of CIQ is not successful, your information will be stored by CIQ for archiving purposes and will not be shared with any third parties unless it is in response to a demand by law enforcement authorities in connection with a criminal investigation, or by civil or administrative authorities in connection with a pending civil case or administrative investigation.

Our detailed privacy policy for our Publishers enrolled in our US network is located here:
https://performance2.globalwidemedia.com/privacy_policy

Our detailed privacy policy for our Publishers enrolled in our Canadian network is located here:
https://performance1.globalwidemedia.com/privacy_policy

By registering with our Network you give your consent that we may contact you via telephone, via mail and email in order to provide you with information on CIQ offers. You may withdraw your consent at any time by contacting us using the information in the Contact section below.

d. When using our services via websites and online services of our Clients

We use cookies to provide our marketing services on behalf of our Clients. We store cookies on devices of users who are visiting websites and using online services of our clients in order to record business transactions (leads and sales such as signing up for a newsletter or placing an order in a web shop). The only purposes of our tracking cookies are to allocate one successful advertisement to a particular business transaction, and to perform corresponding billing services. Tracking cookies only store information on when and on which device a click on an advertisement occurred. The data stored in our cookies is not attributed to a particular user and may contain hashed information (i.e. information in the forms of numbers and letters) on (i) the specific time of the user's action (click or view); (iv) hashed IP address to verify if a user is eligible for a marketing offer; (iii) device information (operating system and browser type) to verify eligibility for a marketing offer (iv) information indicating whether user converted on a marketing offer.

Our tracking cookies are listed below.

e. When you apply for a job with us

If you apply for a job with us, we will collect additional information in connection with your application. This may include: Name and contact information; Username and password; Work authorization status; Resume, CV, cover letter, work experience, and education information; Skills; Professional and work-related licenses, permits, and certifications held; Reference-related information; and Any other information that is publicly available or that you elect to provide to us (e.g., current salary, expected salary).

Processing and use of personal data

Visitors to our websites and those who contact us

We may use information collected in accordance with this Data Privacy Policy to: Provide the services you or others request; Provide user or technical support; Communicate with you; Measure and improve our products, business, products, services, and performance, including our programs and website layout and content; Perform analyses on the data we have collected, such as trends, and other research for statistical purposes; Provide, administer, and utilize our website; Prevent potentially fraudulent, prohibited, or illegal activities; and Comply with legal requirements, or assert or defend a legal claim.

Clients

We use personal data provided by our clients only for administrating and providing our services, for responding to clients' inquiries and, where applicable, executing the contract between a client and CIQ, including payment processing. We store personal and any other kind of data strictly in compliance with applicable data protection and privacy legislation and our contractual duties, and will prevent unauthorized access to data to the best of our abilities.

We may transmit your data to our subcontracted service providers, but only if we contractually assigned these providers to process data on our behalf and, both ourselves and the subcontracted service providers comply with all requirements of applicable data processing regulations pursuant to laws on data protection.

In order to fulfill our contractual obligations, we may transmit your data to companies that we control and subsidiaries of such, provided that these companies are subject to this Data Privacy Policy or privacy guidelines ensuring at least equal protection of your data.

Users of Clients' websites

We use your data to provide our marketing services on behalf of our Clients. CIQ encourages you to visit its Clients' websites, or contact its Clients directly, should you wish to learn more about their personal data practices.

Job Applicants

Information from job applicants may be collected from you directly, from your references, from a recruiter, from your prior employers, and from your places of education. We will only use this information to evaluate your candidacy, including by processing your application, assessing your qualifications, corresponding with you, and complying with legal obligations.

Disclosure of Your Personal Data

CIQ does not sell your personal data, and will not sell your personal data. CIQ may share some or all of your personal data:

• In connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the unlikely event of an insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Data Privacy Policy.
• If CIQ believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on CIQ; (iii) to protect or defend the rights or property of CIQ or users of Our Website; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law or this Data Privacy Policy.

Data security

CIQ takes all reasonable technical, physical, and organizational security measures required to protect your personal data from loss, unauthorized disclosure or other forms of misuse. Data is stored in a safe environment that is not open to public access. Our staff has been trained in privacy matters and in dealing with data and information, which they gain access to in a responsible manner. We encourage you to similarly be cognizant of safeguarding your personal information.

Your Choices and Rights Relating to Your Personal Data

You may have a right to access, delete, or rectify your personal information. If you are registered as a Publisher, you may access your publisher account and rectify some of your data yourself. In all other cases you may make a request by contacting us using the information provided in the Contact Us section below. Exceptions may apply, including based on whether your request is permitted or required by law.

Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information; (iii) the right to object to unlawful data processing; (iv) the right to erasure of personal information about you; (v) the right to demand that we restrict processing of your personal information if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (vi) the right to data portability of personal information that you provided us in a structured, commonly used, and machine-readable format; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.

We may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Data Privacy Policy and, if applicable, we will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to a third country.

California Residents

If you are a California resident, the California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA), may afford you the right, following a verifiable request, to:

(1) access—twice in a 12-month period, free of charge—the categories and specific pieces of personal information CIQ has collected about the you, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom CIQ shares personal information, for the 12-month period prior to the request; and

(2) delete personal information under certain circumstances.

CIQ does not discriminate against you on the basis of your exercising any rights afforded by the CCPA, which is further in accordance with California residents' rights under that title.

You can make the above-mentioned requests by contacting us using the information provided in the Contact Us section below. Please specify in your request the details of what personal information you would like to access, correct, or delete. Please note that not all data described in this Data Privacy Policy will be subject to CCPA.

Following any request, we will verify your identity using data points you have previously provided to us. Please have this information available so that we can verify your request. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

Further, in accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov.

California Do-Not-Track disclosure requirements

CIQ is committed to providing you with meaningful choices about the information we collect, and that is why we provide the below NAI Out-out link. However, we do not recognize or respond to browser initiated Do Not Track signals.

Children’s Information

We do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age of 16 has provided personal information, then you may alert us as set forth in the “Contact Us” section below and request that we delete that child’s personal information from our systems.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the “Contact Us” section below.

Amendments to this Data Privacy Policy

We may modify this Data Privacy Policy from time to time, in particular if new laws and regulations are adopted or we regard amendments reasonable. The date of amendments will be posted below the heading of this Data Privacy Policy.

Links to Other Sites

This website may provide links to other websites. CIQ does not endorse these websites, and is not responsible for the content of third-party websites. Nor CIQ have any control over information you may choose to provide to those websites.

The privacy policy described here does not apply to third-party websites, even if they are linked to CIQ's websites. Other websites you visit may have their own privacy policies or no policy at all. Other websites might use personal information differently than our policy permits. We strongly encourage you to review the privacy policies of any website before providing any personal information.

Opt-Out

CIQ may serve interest-based messages (banners or links) on behalf of organizations across the Internet. CIQ may receive anonymous information about your interests and use this information to display messages for issues that may be of interest to you. Please note that these messages do not reflect the views or opinions of CIQ.

The Network Advertising Initiative (NAI) works with providers like CIQ to promote responsible online communication practices. To help you understand how this messaging works, the NAI has developed an informative site to help you safeguard your online privacy and provide a way for you to opt-out of interest-based messaging. To learn more visit the NAI. http://optout.networkadvertising.org/?c=1#!%2F

Your interests are associated with a cookie or similar technology that associates devices or browsers. By selecting the below, you will be able to control whether and how Company serves messages to you by using the cookie. Remember, if you opt-out you will continue to receive messages, but they will not be as relevant to you.

If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.

https://causaliq.com/opt-out

Contact Us

If you have any questions regarding this Data Privacy Policy or need to access this Data Privacy Policy in an alternative format due to a disability, please email privacy@causaliq.com or call us at 1-877-532-3436, or write to us at the following address: 11766 Wilshire Boulevard Suite 1400, Los Angeles, CA 90025.