Last updated: 25^th August 2023

This privacy policy applies to Affinity Global Inc. and its programmatic yield improvement products named ‘Yield Solutions’ (collectively, “Yield Solutions,” or “we”, “us”, “our”).

Yield Solutions offers services through its products viz. Smart floor, HVR, Space, Header bidding which aim to optimise publisher revenue. We help publisher to flourish their business and reap incremental advertising revenue.

This Privacy Policy describes how Yield Solutions collects, uses and discloses information, and what choices you have with respect to the information.

Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your acceptance of our use of your personal data as set out in this Privacy Notice.

Services

Yield Solutions engages with third-party publishers to serve ads on their digital properties on behalf of its demand-side advertising partners. Yield Solution products help Publishers to generate more revenue by combining AI powered technology & best ad operations experts.

It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.

Domains and Websites covered under this Policy

For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.yieldsolutions.com as well as the other websites that the Affinity Group operates and that link to this Policy.

Information We Collect

Information collected automatically: In certain cases, we automatically collect personal data when you use our website/services. This data is recorded in log files or other such files. Examples of such data include IP addresses.

Website Visitor’s Data When you view an advertisement distributed through Yield Solutions on any digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us.

• IP data is temporarily collected for processing.
• Geography (country),
• Device Type (Desktop / Mobile)

Log Data Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address

Information provided by you: We collect personal data when you use our website/services or provide the personal data directly to us. For creation of user accounts, you provide your name, email address, password, telephone number and correspondence address. You also provide billing details for invoicing purposes.

Contact Us Data When you enquire about our products and services, we collect and store this data to communicate with you and respond to your enquiry.

Other Data Publishers and Advertisers provide data that is necessary to create user accounts. For creation of user accounts, you provide your name, email address, password, telephone number and correspondence address. You also provide billing details for invoicing purposes.

Cookies

We collect data through cookies: Yield Solutions uses cookies to identify and track visitors, their usage of website, and their website access preferences. Yield Solutions website visitors can control cookies through Cookies Settings.

The categories of cookies used are:

1. Strictly necessary cookies - These cookies are needed to run our website, keep it secure, and comply with regulations that apply to us.
2. Performance/analytics cookies - We may use performance/analytics cookies on our website. These cookies collect information about how visitors use our website and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is used to improve how our website functions and performs
3. Marketing Cookies - We may use cookies storage required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.

Yield Solutions uses cookies to identify and track visitors, their usage of website, and their website access preferences. Yield Solutions visitors can control cookies through Cookies Preferences.

Click here to view the Cookie Preferences.

For more details about how we use these technologies, please see our Cookie Policy.

How We Use Your Data

How we use your personal data will depend on which Services you use and how you use those Services.

We use the ‘Website user’s Data’ that we collect about your device to:

• Display advertisements on your device
• Optimise yield revenue for publishers
• Integration with partners
• Ad refresh / replace by Affinity sponsored ads
• Internal reporting / reporting to publishers & bidders
• Auction available spaces and assign space to highest bidder
• Bidder Analysis / Reporting to publishers
• To detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
• Internal reporting
• Other Data’ is used by us to provide our services and to communicate with you by responding to your requests, comments and questions.

Lawful basis for processing

We process your personal data only when we have a lawful basis. We process your personal data only when we have a lawful basis.

Presently, we use the following:

1. Consent – We process your data if you have given your consent freely for the same. Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time. Please contact us using the details in the ‘Contact us’ section of this notice.
2. Performance of contract – We process your data when it’s necessary for the performance of the contract. For example, if the processing is necessary to fulfil our commitments under the applicable terms of service.
3. Legal Obligation – We process your data if the use of your information is necessary for compliance with legal obligations.
4. Legitimate Interest – We may also process your data on the grounds of legitimate interest for a particular processing activity. For example, to safeguard our services, to understand our user preferences etc. Where you have consented to a particular processing, you have a right to withdraw the consent at any time.

Where you have consented to a particular processing, you have a right to withdraw the consent at any time.

Users under 16 years of age

The Sites and Services do not knowingly collect personal information from users under the age of 16

If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Data Retention Policy

1. Your data (viz. IP addresses) is not stored by us after the same has been used for purposes mentioned in this privacy policy. Some data may be required for future processing and the same is stored in anonymized format. Such data is not relatable back to you once it is anonymised.
2. Website visitor’s Data:

   We will retain information collected in the context of our Marketing Platform for a period of up to 3 years, unless otherwise required by law or applicable contract.

   We may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations.

   After the applicable retention period, we may only retain and use your data:

   1. in an aggregated or anonymized format;
   2. to comply with its our legal obligations;
   3. to resolve disputes and enforce agreements.

   Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

3. Other Data

   Yield Solutions may retain other information pertaining to you for as long as necessary for the purposes described in this Privacy Policy.

Your Rights

Data Subjects have certain rights in respect of their personal data. The rights given with respect to your personal data include:

• The Right of Access: You have the right to access personal data and supplementary information. You can ask us for a copy of your personal information.
• The Right to Rectification: You can ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
• The Right to Erasure: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you) without undue delay.
• The Right to Restriction of Processing: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if you think your personal information is inaccurate or unlawfully held).
• The Right to Data Portability: You have the right to data portability which provides the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit the same to another controller.
• The Right to Object: You have the right to object to the processing of personal data.
• Automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you (data subject).
• The right to withdraw consent: You have the right to withdraw your consent at any time with effect for the future. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
• The right to lodge a complaint: You have the right to lodge a complaint with the supervisory authority if you are dissatisfied with the way we handle or process your personal data.

Whenever you use our services, we aim to provide you with easy means to access, modify, delete, object to or restrict the use of your personal information.

We strive to give you ways to access, update/modify your data quickly, or delete it unless we have to keep that information for legal purposes. These rights can be exercised by contacting us using the details set out in the "Contact Information" section below.

Website user’s rights We provide same rights to the users of our services. We receive requests related to Website user’s rights from our publishers and advertisers.

Account Closure We keep some personal data even after account closure. Once you choose to close your account, we generally delete your personal information within 3 years of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.

Your information shared with others

Recipients of your data Yield Solutions may share the Website user’s data we collect or receive about you as described in this Policy as follows:

• Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings
• Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment services and measurement companies who help us with attribution and tracking of advertisements distributed through us (“Marketing Partners”).
• Service Providers. We may share personal information we collect about you with our third- party service providers. The categories of service providers to whom we entrust personal information include: IT and related services such as cloud-based data centres, analytics service providers; service providers for fraud detection; CRM and email marketing services.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Cross-Border Data Transfers Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region

Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centres in Europe and India as well as Affinity data centre in USA. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.

Yield Solutions offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our publishers and advertisers that operate in the European Union, and other international transfers of data. These clauses are contractual commitments between parties transferring personal data (for example, between Yield Solutions and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.

Security Measures to Protect your Data

Security Measures We implement security controls to prevent breaches and unauthorised access to your data.

We maintain reasonable and appropriate security measures to protect Website user’s data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Examples of security measures include physical access controls, restricted access to data, monitoring for threats and vulnerabilities etc.

Protection of personal information Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information

Yield Solutions takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

Contact Information You can contact us about this privacy policy or use of our services.

If you have questions or complaints regarding this Policy, you may contact us through email at compliance@affinity.com. You may contact us at our mailing address below.

20 N. Wacker Drive, 12th Floor, Chicago, IL 60606.

If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are aware of how and why we are using such information.

Privacy policy change Yield Solutions may change this Privacy Policy from time to time, at our sole discretion.

Yield Solutions encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.

ANNEXURE

Jurisdiction-specific provision:

California Privacy Rights Act(CPRA) This CPRA Privacy Policy describes Yield Solutions practices regarding the collection, use, and disclosure of the personal information of California residents, describes the rights of California residents under the California Privacy Rights Act (“CPRA”), and explains how California residents may contact Yield Solutions to exercise those rights. This CPRA Privacy Policy only applies to the personal information of California residents.

CPRA Categories of Personal Data

Categories of Personal data	Personal data collected
Identifiers	Name, postal address, phone number, email address etc. for individual who are signing up as our partners and customers. IP address Device identifiers such as iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for vendors, Google Advertising ID (GAID), or Android ID for Android devices Unique hash value if Device Id is not shared
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, signature, tax identification number (i.e. National Insurance Number), Government ID number etc. for individual who are signing up as our partners and customers.
Financial Information	Bank details, payment information of our partners.
Commercial Information	N/A
Protected Classification characteristics under California or federal law.	N/A - We do not collect information such as Gender, Age, national origin, marital status etc.
Biometric information	N/A - We do not collect Biometric information
Internet or other similar network activity.	Log data, session information, Cookie Id.
Geolocation data	Such as your location information generated based on your IP address etc. IP address Location information such as country code we infer from your device’s IP address We do not collect the precise location of the Website visitors
Sensory data.	For direct & programmatic campaigns, users choose to give consent and engage with the respective ad creatives.
Professional or employment-related information.	Employment status, previous employment details, salary details etc only for job applicants.
Inferences drawn from other personal information.	N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	From job applicants only such as educational details, history, degree etc.

No Sale of Personal Data: Yield Solutions has not sold Personal Data in the preceding twelve (12) months.

Right To Opt-Out Of The Sale Of Personal Data: Yield Solutions does not sell your personal data.

If in case, Yield Solutions ever changes its policy and choose to sell Personal Data, you would have the right to opt-out of the sale of your Personal Data by clicking on the “Do not sell my personal data” link.

Sensitive data: We do not generally seek to collect sensitive data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with California Privacy Rights Act("CPRA") requirements. If in case, Yield Solutions ever chooses to use Sensitive Personal Data, you would have the right to limit the use of your sensitive personal Data.

The term "sensitive data" refers to the various categories of personal data identified by CPRA as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Disclosures of Personal Data for a Business Purpose: In the preceding twelve (12) months, Yield Solutions has not disclosed Personal Data for business purposes.

Your Rights The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.

• Access to Specific Information You have the right to request that Affinity disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

• Deletion Request Rights You have the right to request Affinity delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Right to Correct Inaccurate Personal Information You have a right to request for correction of Inaccurate personal information. We shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer.

• Right to Know What Personal Information is Sold or Shared and to Whom You have a right to request us information about what personal information is sold or shared by us and with whom. Once request received, we shall disclose the following:

  • The category or categories of consumers’ personal information it has sold or shared, or if we have not sold or shared consumers’ personal information, it shall disclose that fact.
  • The category or categories of consumers’ personal information it has disclosed for a business purpose, or if we have not disclosed consumers’ personal information for a business purpose, it shall disclose that fact.

• Right to Opt Out of Sale or Sharing of Personal Information You have a right to opt out of sale or sharing of personal information if we sell or share such personal information. We shall prohibit from selling or sharing the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides consent, for the sale or sharing of the consumer’s personal information.

• Right to Limit Use and Disclosure of Sensitive Personal Information You have a right to request us to limit Use and Disclosure of Sensitive Personal Information. Upon such request we shall prohibit, from using or disclosing the consumer’s sensitive personal information for any other purpose after its receipt of the consumer’s direction unless the consumer subsequently provides consent for the use or disclosure of the consumer’s sensitive personal information for additional purposes.

• Right of No Retaliation Following Opt Out or Exercise of Other Rights – Non-Discrimination We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

  You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Response Timing and Format We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CONTACT FOR MORE INFORMATION If you have any questions or concerns about Yield Solutions’s privacy policy and practices, please contact us by email at compliance@affinity.com, or by mail at:

20 N. Wacker Drive, 12th Floor, Chicago, IL 60606.

Privacy policy change We will review and update this CPRA Privacy Policy periodically and will note the date of its most recent revision at the top of this CPRA Privacy Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes prior to such changes taking effect, if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how Yield Solutions is protecting your information.