Effective Date: February 11, 2019

Introduction and Overview
This Privacy Policy describes how Distributed Media Lab, Inc. (“DML,” “we,” “our,” or “us”) collects, uses, and
shares information about you as well as your rights and choices about such use and sharing. This policy applies
to your use of the website (the “Site”) and any other online service location that posts
a link to this Privacy Policy. It also applies to all features, content, and other services that we own,
control, and make available through such online service locations (collectively, the “Services”). In addition,
this Privacy Policy describes how we use data to provide the Distributed Media Lab Services to our publisher

When Distributed Media Lab is a Data Controller or Data Processor
EU data protection law makes a distinction between organizations that process personal data for their own
purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations
(known as “processors”). Distributed Media Lab may act as either a controller or a processor in respect of your
personal data, depending on the circumstances.

Distributed Media Lab, located at the address in the section entitled “Contact Us” below, is the controller with
respect to information you provide through the Site.

More often Distributed Media Lab operates as a processor on behalf of a publisher partner, a separate legal
entity, which is the data controller. Distributed Media Lab provides content exchange services to its publisher
members and processes personal data on their behalf to help them engage in targeted digital advertising. Please
visit the applicable publisher’s privacy policy for information about their privacy practices. Any questions
that you may have relating to such personal data and your rights under data protection law should therefore be
directed to the publisher as the controller, not to Distributed Media Lab.

A Little About Digital Identifiers and Tracking Technology
Many commercial websites and programmatic marketplaces employ one or more Digital Identifiers in conjunction
with user tracking technologies, which are essential for measurement and verification, and can also be used to
enable interest-based advertising. Below is a brief summary of the Digital Identifiers and tracking technologies
Distributed Media Lab may employ in conjunction with our publishers and demand partners, along with a brief
explanation of each.

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique
identifier. For more information about cookies, and how to disable cookies, visit{' '}

“Log files” track actions occurring on sites. Logs may include IP addresses, browser types, Internet service
provider identifiers, referring/exit pages, platforms and device types, date/time stamps, and impression and
click data.

“Web beacons” or “tracking pixels” are electronic files used to track user navigation and browsing behavior
within and across website. They can also be used to verify the completion of transactions, or to connect
advertising exposure with a conversion (e.g., purchase).

Device fingerprinting is the process of analyzing and combining sets of information elements from your
device’s browser and other device-specific information in order to uniquely identify your device.
In the context of user tracking, software development kits (SDKs) are code that can be used to send
information about your use of a web or mobile app to a server. An SDK can, in effect, enable the app version
of a tracking pixel. These SDKs allow companies like ours to deliver advertising both on and off the Service,
to track conversions and for other measurement and verification purposes.

GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when
you enable location-based services through your device. Location data may be used for purposes such as
verifying your device’s location and delivering or restricting relevant content and advertising based on that

The privacy policies that follow explain how Distributed Media Lab employs these technologies, how you, as a
user of our site and Service, may control data we collect, and other information to help you take control of
your digital privacy.

Your Privacy Choices when you Visit the Distributed Media Lab Website

Information We Collect on Our Site
Similar to most commercial websites, we collect information about how our website is used. Some of this
information, including, for example, your IP addresses and certain unique device identifiers, may identify a
particular computer or device, and may be considered “personal data” in some jurisdictions in the European Union
and elsewhere. The website usage information we collect may include the following: IP address, MAC address,
device advertising ID (e.g., IDFA or AAID), domain, browser type and language, referring website addresses,
date/time of visits, page view data, the type of device or browser you use, your device’s operating software,
your internet service provider, your device’s regional and language settings, data about your device’s location
(which can be precise such as latitude/longitude data or imprecise such as location derived from an IP address
or data that indicates a city or postal code level), and search keywords. In this privacy policy, we refer to
this information as “Digital Identifiers,” which we have described above.

In addition, when you visit our Site you may optionally choose to submit information such as contact
information, demographic information, and/or questions. In so doing, you may provide us with personal
information about you that you knowingly choose to disclose, such as name and email address, and of course, the
content of your question. You may choose to voluntarily submit such information to us through the Service that
we do not request, and, in such instances, you are solely responsible for such information.

How We Use Information
We and our third-party service providers may use personal information you provide for our legitimate interests,

- to respond to your inquiries and fulfill your requests;
- to send administrative information to you, for example, information regarding the Services and changes to our
- terms, conditions, and policies;
- to alert you of Distributed Media Lab developments we believe may be of interest to you;
- for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new
products, enhancing, improving or modifying our Services and identifying usage trends; and
- to prevent and address fraud, breach of policies or terms, and threats or harm.

We also use information about you to fulfill any other purpose disclosed to you and with your consent.

We may use information that does not identify you (including information that has been de-identified) without
obligation to you except as prohibited by applicable law.

For information on your rights and choices regarding how we use your information, please see the section
entitled “Your Rights and Choices” below.

Sharing Your Information
We share information collected on the Site with:
- a very limited number of third-party service providers (“Service Providers”) who assist with the operation of
our Site. Service Providers are prohibited from using your information for any purpose other than to provide
this assistance, although we may permit them to use aggregate information which does not identify you or
de-identified data for other purposes;
- with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case
we will require our Affiliates to honor this Privacy Policy;
third parties, in connection with any transaction in which we raise money or transfer all or a portion of our
business or assets;
- with third parties for purposes of facilitating your requests (such as when you choose to share information
with a social network about your activities on the Service) and in measuring and improving our Service;
- Law enforcement agencies and others in conformance with applicable law or to respond to subpoenas or warrants
served on us;
with third parties to protect or defend our rights and property or those of our users, and to investigate or
assist in preventing any violation or potential violation of the law or our terms, conditions, and policies;
- with third parties for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not
identify you or de-identified information about you with third parties or affiliates for any purpose except as
prohibited by applicable law. For information on your rights and choices regarding how we share your
information, please see the section entitled “Your Rights and Choices” below.

Other Parties
In connection with the operation of the Site, we may allow analytic services who use cookies and other
technologies to analyze how users use the Site. These companies use the information collected on our Site in
accordance with their own privacy policies. For a list of such companies, please contact us at:

Your Privacy Choices when you Visit a Website that uses Distributed Media Lab Services
Information We Collect in the Distributed Media Lab Network

We provide products and services for our publisher partners (“Distributed Media Lab Services”), and collect and
process information about individuals (including through tracking technologies) at the direction of our
publisher partners (“Publisher Data”). Publisher Data has historically included contact data, demographic data,
content, service use data, device connectivity and configuration data, and location data, among other
information. Our processing of Publisher Data is governed by the terms of our service agreements with our
publisher members, and not this Privacy Policy. To the extent we combine Publisher Data with information we have
collected about you through the Service, we will treat the combined information in accordance with the practices
described in this Privacy Policy, plus any additional restrictions imposed by our publisher members. We are not
responsible for how our publisher members treat the information we collect on their behalf, and we recommend you
review their privacy policies.

In the delivery of advertising through Distributed Media Lab Services, Distributed Media Lab may collect
information that is linked or reasonably linkable to a particular computer or device, such as: browser and
device information; IP address; time spent on a particular webpage, pages visited including the analysis of the
content contained on such pages, language preferences, date and time an ad was served, clicks on ads, and other
traffic data; general location inferred from IP address; unique identifier, including operating system type and

We and our third-party service providers may collect this information in a variety of ways, including through:
your browser or device; your mobile advertising identifier, such as Apple’s IDFA and Google’s Android
Advertising ID; the use of statistical identifiers (which collect and use certain characteristics of your device
to help us identify it over time); your use of the apps; the use of pixel tags and other similar technologies;
your IP address; the aggregation of information; HTTP entity tags and web cache; and cookies.

How We Use Information for our Publisher Partners
We use Publisher Data:
-to operate, improve, analyze and manage the Distributed Media Lab Services for our publisher partners;
for our partners’ advertising purposes, such as fraud prevention, billing, logging the number and type of ads
served on a device to cap the number of times a consumer sees an ad or to sequence ad creative (aka “frequency
capping” and “ad sequencing”);
-to measure and report on the success of marketing campaigns via pixel tags (also known as web beacons and
clear GIFs); and
-to enable our publisher members to offer, and our advertising partners to deliver, interest-based advertising.
(To learn more about your advertising choices, see Consumer Privacy and Your Choices

Sharing Your Information
We share your information collected in connection with the Distributed Media Lab Services that we provide to our
publisher partners in the same ways that we share your information collected in connection with the Site, and in
the following additional ways:
-with Distributed Media Lab publisher partners to allow them to analyze the effectiveness and performance of
our Distributed Media Lab Services;
-with our media buyer clients who use it in a number of ways including to allow them to make decisions
regarding buying advertising inventory, and to analyze the effectiveness and performance of their advertising
campaigns via our Distributed Media Lab Services;
-and with our third-party service providers for measurement, fraud prevention and verification purposes. For a
list of the third-party service providers we use in connection with the Distributed Media Lab Services, please
contact us at:

Your Choices
You may access, update, or remove certain information that you have voluntarily submitted to us through the
Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may
require additional information from you to allow us to confirm your identity. Please note that we will retain
and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our
agreements. California residents and data subjects in Europe have additional rights as set forth in the sections
entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or
delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately.
Your ability to limit cookies is subject to your browser settings and limitations.

You can reset your device advertising ID at any time through your device settings, which is designed to allow
you to limit the use of information collected about you. For information on how to do this on Apple devices,
or For information
on how to do this on Android devices, visit You can stop all collection of information via an app by
uninstalling the app.

The location data collected through an app depends on your device settings and app permissions. You can exercise
choice over the location data collected through many apps by (i) for GPS data, disabling location in your device
settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any
Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning
option in your device settings. You can stop collection of all location data via an app by uninstalling the app.
You can opt-out of your data being used by Google Analytics through cookies by visiting and downloading
the Google Analytics Opt-out Browser Add-on.

In connection with Distributed Media Lab Services, publishers and advertisers engage in interest-based
advertising, which is the collection of information about viewing behaviors, over time, from one or more devices
for the purpose of using such information to deliver advertising more likely to be of interest to the person
using the device(s). We require our publishers and advertisers to comply with the Digital Advertising Alliance
Ad Choices program (the “Ad Choices Program”) an industry self-regulatory program that allows consumers to opt
out of the use of cookie and non-cookie-based information for the purpose of delivering interest-based
advertising. You can read more about the program and how to opt-out of interest-based advertising{' '}

Because we want to make it easy for consumers to exercise their choice, and for that preference to be
persistent, we also honor the Do Not Track (DNT) signal, which can be turned on or off in your browser. When the
DNT signal is on, we will treat your device as if you have opted out via the Ad Choices program. Please note
that each of our publisher partners may or may not elect to comply with DNT, as may be described in each
publisher’s privacy policy.

Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain
types of their information are shared with third parties and, in some cases, affiliates, for those third
parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide
California customers certain information upon request or permit California customers to opt in to, or opt out
of, this type of sharing.

Distributed Media Lab may share personal information as defined by California’s “Shine the Light” law with third
parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a
California resident and wish to obtain information about our compliance with this law, please contact us as set
forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in
the first line of the description and include your name, street address, city, state, and ZIP code. Please note
that Distributed Media Lab is not required to respond to requests made by means other than through the provided
e-mail address or mail address.

Your European Privacy Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have
collected about you through the Service. You also have the right to data portability and the right to restrict
or object to our processing of personal data we have collected about you through the Service. In addition, you
have the right to ask us not to process your personal data (or provide it to third parties to process) for
marketing purposes or purposes materially different than for which it was originally collected or subsequently
authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you
have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify
which right you intend to exercise. We will respond to your request within 30 days. We may require additional
information from you to allow us to confirm your identity. Please note that we store information as necessary to
fulfil the purposes for which it was collected, and may continue to retain and use the information even after a
data subject request for purposes of our legitimate interests, including as necessary to comply with our legal
obligations, resolve disputes, prevent fraud, and enforce our agreements.

Distributed Media Lab acknowledges that you have rights in connection with Publisher Data. If your information
has been processed by Distributed Media Lab on behalf of a publisher partner and you wish to exercise any rights
you have with such information, please inquire with our publisher partner directly. If you wish to make your
request directly to Distributed Media Lab, please provide the name of the Distributed Media Lab partner on whose
behalf Distributed Media Lab processed your information. We will refer your request to that publisher partner,
and will support them to the extent required by applicable law in responding to your request.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory

Children’s Privacy
We do not intentionally gather personal information from visitors to the Site or Services who are under the age
of 13. If we learn that a child under 13 submits personal information to us, we will attempt to delete the
information as soon as possible. If you believe that we might have any personal information from a child under
13, please contact us at:

International Visitors
If you are a non-U.S. user of the Site or Services, by visiting the Site or Services and providing us with
information, you acknowledge and agree that your personal information may be processed for the purposes
identified in this policy. In addition, your personal information may be processed in the country in which it
was collected and in other countries, including the United States, where laws regarding processing of personal
information may be less stringent than the laws in your country. By providing your information, you consent to
such transfer.

Data Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect
your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of
your information.

This policy may be updated from time to time by us. We will notify you of any changes to our policy by posting
the new policy and changing the “Last Updated” date above. We recommend you consult this page regularly for any

Contact Us
If you have any questions about privacy and your choices, please contact us via email:
Attention: Chief Privacy Officer