Updated March 18, 2020

WHITE OPS, INC. AND THE EU-U.S. and SWISS-U.S. PRIVACY SHIELD

White Ops, Inc. (“White Ops”) has certified to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield Frameworks”) with the U.S. Department of Commerce regarding the collection and processing of personal data from our advertisers, customers, or business partners in the European Union and, where a Swiss data controller uses White Ops as a data processor, Switzerland (“Partners”) in connection with the products and services described below. To learn more about the Privacy Shield program please visit http://www.privacyshield.gov.

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies with a mechanism to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. Both the European Commission and Swiss Government have deemed the Privacy Shield Frameworks as adequate to enable data transfers under EU and Swiss law. White Ops has joined both of the Privacy Shield Frameworks to benefit from these adequacy determinations; and has publicly declared its commitment to comply with the Framework’s requirements.

Scope: The Privacy Shield Principles (set out in each of the Privacy Shield Frameworks) relates to the collection of personal data, which is information that can be used to uniquely identify you, such as your name, telephone number, address, and e-mail address hereinafter referred to as “Personal Information”). The only Personal Information White Ops may collect is as follows:

• Dashboard. White Ops may collect Personal Information from clients and prospective clients for its Dashboard, but which will require a User ID and password to use. We use this information in order to create and maintain business records, billing information, and for other purposes essential to our client relationships. We generally store this information for so long as we maintain a business relationship with a given client and for a reasonable time after the termination of the business relationship, for billing and compliance purposes. Our Dashboard also collects certain non-personally identifiable information. For example, we log reporting transactions for the purposes of monitoring and improving our quality of service and the overall performance of the Dashboard and our client reporting in general.
• Information from Other Sources. White Ops may receive Personal Information from other sources, including its clients or third-party service providers (“Partners”). To the extent we receive such third-party sourced information we will treat the information as Personal Information to be protected under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices. White Ops may use the personal data provided by our Partners to provide Partner Services in accordance with the terms applicable to the relevant Partner service and otherwise with the Partners’ instructions. White Ops will work with its Partners to ensure that individuals are offered appropriate choices applicable under the Privacy Shield Principles. Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, White Ops will work with its Partners to provide individuals access to personal data about them that White Ops holds on behalf of its Partners. White Ops also will take reasonable steps to enable individuals, either directly or in connection with the Partners, to correct, amend, or delete personal data that is demonstrated to be inaccurate.
• To the extent White Ops may transfer data to third parties, including any service providers and other partners, White Ops will make reasonable commercial efforts to ensure that any processing of personal data by such third parties is not inconsistent with the Privacy Shield Principles. Personal data that is transferred to us by our Partners may be subject to disclosure pursuant to legal requests or other judicial and government process, such as subpoenas, warrants, or orders, or in response to national security or law enforcement requests. It is possible that White Ops can be held liable for unlawful transfer of personal data to third parties.

Enforcement. White Ops’ compliance with the Privacy Shield Principles is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Your Rights. Various laws around the globe regulate the processing of personal information. These laws often grant a specific set of rights to people whose data is being processed. To honor these rights, White Ops will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you may have the following rights with respect to that information:

• To access your Personal Information that White Ops collects and uses
• To rectify any errors, outdated information, or omissions in user information
• To delete or erase your Personal Information from our records
• To request that your user information not be used to contact you

Please understand that as a matter of general business practice, White Ops does not store or collect the personally identifiable information of individuals with the exception of IP addresses. As a result, we are unable to associate individuals to the data that we process, which may make it difficult to find, edit, or delete that information.

You will not be discriminated against for exercising your privacy rights. To exercise any of these rights, or to understand the choices and means offered for limiting the use and disclosure of personal data, please contact us by email:

privacy@whiteops.com.

We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

White Ops will not knowingly or intentionally share Personal Information with any third party absent your consent. Presently, White Ops does not transfer Personal Information to any third parties, nor does it sell Personal Information. In the event it later determines the need to transfer Personal Information to any third party acting as a data controller, White Ops will comply with the Notice and Choice Privacy Shield Principles; and will enter into a contract with the third party controller limiting the purposes for which the data may be processed, ensuring that the recipient will provide the same level of protection as White Ops. Any such transfer of information will be for a limited and specified purpose, and only after White Ops ascertains that the agent agrees to provide at least the same level of privacy protection as required by White Ops. White Ops will further take reasonable steps to ensure that the agent effectively processes this data in a manner consistent with White Ops who will, upon notice, take reasonable steps to stop and remediate any unauthorized processing; and upon request, provide a summary or copy of privacy provisions of its contract with the agent to the Department of Commerce.

Without limiting the foregoing, White Ops will take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. It will further take reasonable steps to limit processing to the purposes for which the Personal Information was collected, and to ensure that the Personal Information it collects (i.e. not through a third party) is reliable for its intended use, accurate, complete, and current. White Ops will otherwise retain personal information for as long as needed for the purpose of collection; and adhere to the Privacy Shield Principles for as long as it retains such information.

Recourse. White Ops complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework(s) (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield.  White Ops has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

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

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

WHITEOPS, INC. PRIVACY POLICY FOR TECHNOLOGY AND SERVICES

White Ops, Inc. ("White Ops") provides cutting-edge anti-fraud solutions across a spectrum of industries from advertising to eCommerce to Big Data and Enterprise Business. This Privacy Policy describes our practices in connection with information that we collect through the White Ops products, services and reporting platforms. Our Detection Tag and the technology behind it (our "Technology") determines humanity or non-humanity on a per-session level by examining and analyzing certain characteristics upon each pageload.

Collection and Use of Internet Data. White Ops uses various technologies, described below, to collect session-specific data in order to deliver anti-fraud solutions to our customers (collectively, our "Services"). The Services use JavaScript and/or pixels that place a small piece of HTML code either on a webpage, across a domain, or at the server level, to collect information about web or mobile app visits. This information is used to provide the Services. The types of data we collect using this technology include:

• Various parts of the HTTP Header (including IP Address, HREF, Referrer, and User Agent)
• Various technical aspects of the browser
• Generalized user interaction data

Our customers can pass parameters and information from Third-Party Digital Media Services (or any other integrated web service) to White Ops for reporting (i.e. campaign id, placement id, ad id, etc.). Some web services offer macros that allow their Cookie ID, Unique Id or identified Mobile Device ID to be passed to other companies involved in the measurement and delivery of the asset. White Ops customers may elect to have that Cookie Id, Unique ID or Device ID passed to White Ops for reporting on non-human activity and other fraud behaviors.

In general, our technology does not utilize cookie data or mobile Device ID in the detection and prevention of fraudulent online activity; and therefore, White Ops does not send nor collect cookie data through the browser’s http header elements, nor directly collect the Device ID through mobile applications.

We may work, alone or with our Partners, to anonymously integrate analytic data with data that those partners have independently collected to deliver enhanced anti-fraud services.

Use of Information. White Ops collects minimal personally identifiable information ("PII") via our Services. Some of the PII collected includes IP address, browser type, referring URL, and information on the click behavior of the visitor during a browser session. We use this information in order to provide our Services, and we may share that information with our clients to help them ensure fraud-free advertising campaigns and eCommerce transactions, and to ensure the security of online Enterprise business products and services. We also use the information for analytics that aid us in building an historic record of behavior patterns in order to enhance future Services, without collecting any personally identifiable information.

Data Security and Integrity. White Ops makes every reasonable effort to protect the information in our care from loss, misuse, alteration or destruction. Only authorized employees and clients have access to the data that we gather, and that access is limited by need. All employees who have access to client data are enjoined to maintain the confidentiality of such information. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use all commercially reasonable means to protect client information, we cannot guarantee absolute security.

Use of Collected Data. Except as otherwise stated herein, White Ops does not share information gathered by the Services except: (1) as is necessary to execute the Services; (2) in aggregated formats for general corporate marketing and industry benchmarking; (3) for sharing with official affiliates and/or partners of White Ops or service providers of White Ops (where the service providers are required to use the information only to perform services for White Ops); (4) as required by law or to comply with legal process; or (5) to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Privacy Policy: Client Portal (Our "Dashboard"). Please see the above section under Privacy Shield for the use of any Personal Information. Subject to and notwithstanding the use of Personal Information as described therein, this section explains how White Ops collects, uses, stores and protects the information gathered from our Client Portal, which is also sometimes referred to as the White Ops Dashboard. The Dashboard is a password protected website for clients and prospective clients, which are usually businesses.

Data Reporting. White Ops shares collected information with our clients, affiliates and partners to perform and deliver the antifraud services that we have been contracted to provide. The primary means by which we provide information to our customers is in aggregated reports provided as part of the White Ops Services, including but not limited to our customer dashboard, which is password protected. Use of the dashboard provides each client only with access to their own company's information and provides potential clients only with access to sample reports within the Dashboard. We may also provide aggregate, anonymized data in our marketing and promotional materials.

Use of Cookies on The Dashboard. Cookies are small pieces of information transferred to your computer's hard drive through your web browser to enable our systems to recognize your preferences and settings. We use cookies on the Dashboard to maintain authenticated access and user sessions. We also use cookies to ensure authorized access to client-specific secure content and reports. When accessing client-specific secure content, you are acting as a representative of your company and your interactions with our site in this capacity are governed by our relationship agreement with your company. Most browsers automatically accept cookies and you may manually disable them. For more information on disabling cookies, go to the "help" menu on your browser. Please note that if you disable cookies, the Client Portal may not operate correctly. For more information about cookies, please see our White Ops privacy Policy, below.

Privacy Policy: Whiteops.Com. White Ops may collect cookies on our website. We do not collect cookies on client sites as part of the information gathered by our Technology.

Changes to Our Privacy Policies. White Ops may change and update these Privacy Policies, including materially changing the use made of personal information described herein. Any change or update to our privacy policy will be posted on our Website at least 30 days prior to their implementation. Your continued use of the Technology and the Services after the effective date of any changes will constitute your acceptance of all of the changes.

Contacting Us. If you have questions regarding our privacy practices, please submit a privacy inquiry, or send us an email at info@whiteops.com.