For the purpose of this Notice, unless otherwise specified, “Personal Information” means any information relating to an identified or identifiable individual. In connection with the provision of our product and services, including our website https://www.dynamicyield.com (the “Website”), we obtain Personal Information relating to you from the various sources described below.

If you do not provide your Personal Information when requested, you may not be able to use our Website if that Personal Information is necessary to provide you with our Website or if we are legally required to collect it. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

1. Personal Information Provided by You
• Registration Information. As part of our registration process (e.g., when requesting a demo), we collect your phone number, full name, e-mail address, and details regarding the company you work for if required to provide you with our product and services.
• Other information you choose to provide. You may choose to provide us with other information. We collect your Personal Information when you purchase our services (including financial information), respond to communications from us, contact our support, communicate with us via email, our Website and through any online platform. We may also record telephone conversations, subject to the consent of the participants in the call.
2. Personal Information We Obtain from Your Interaction with our Website
• Device Information. We collect Personal Information from your device, such as IP address and other online identifiers (i.e., online data collected from your devices, applications and protocols which leave traces which may be used to identify you).
• Usage Information. We collect information that we or our technology providers may automatically collect when you visit, access, or use the Website, such as your internet service provider, domain server, type of computer, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections/features of our Website you visit/utilize, number of links you click while on the Website, search terms, and operating system. We may also collect statistical and other data related to your use of our Website or other services as well as information on Website usage patterns.

To collect the above information, we may use session identifiers, web beacons, cookies, JavaScript tags, and other tracking technologies. A cookie is a piece of data stored on your hard drive that contains information about your online behavior, as well as your device. You can learn more on the cookies we use and control your preferences through our Website's cookie management tool – Cookie Settings.

We use this information to improve our online products and services by assessing how many users access or use our online products and services, which content, products and features of our online products and services most interest our visitors, what types of offers our customers like to see and how our online products and services perform from a technical point of view.

We, our service providers and partners may also collect information about you in connection with our marketing activities. The information collected for these purposes may include identifiers and your contact information (e.g., name, email address, telephone number), device information (e.g., username, password, IP address), Internet or other electronic network activity information, geolocation data, and inferences drawn from Personal Information.

We, our service providers and partners may also collect information about you to provide you with content and advertising tailored to your individual interests based on inferences drawn from Personal Information. The information collected for these purposes may include Internet or other electronic network activity information, such as details about things like the particular pages you view on our Website and the actions you take on our Website.

We, our service providers and partners may collect certain information about you via automated means such as social media tools to connect you to your social media accounts. These features may allow you to sign in through your social media account, share a link or post directly to your social media account. When you visit a website that contains such tools, the social media or other service provider may learn of your visit. However, your interactions with these tools are governed by the privacy policies of the corresponding social media platforms. As we do not control these third-parties’ data handling practices, we recommend that you review their privacy policies, terms or use and license agreements (if any). For further details, please consult Section 7 (“Features and Links to Other Websites”) of this Privacy Notice.

We may use Personal Information we obtain about you for the purposes set out below. Depending on the country in which you are located, we will only process your Personal Information, where permitted under applicable laws, and when we have a legal basis for the processing as identified in the table below. However, please note that even though the chart below does not list consent as a legal basis for each processing activity, in some countries consent is the only or most appropriate legal basis for the processing of Personal Information, and in those countries, we rely on consent.

We may share your Personal Information with the following recipients for the purposes set out below:

• Subsidiaries and Affiliates. We share your Personal Information with our subsidiaries and affiliates that are part of the Mastercard group of companies, for the purposes described in this Notice.
• Third-Party Business Partners. We partner with a variety of businesses to market or sell our products or services (for example we can disclose your Personal Information to advertising partners, analytics providers). If you have opted out of our ability to use your e-mail address, we may share your decision to opt out with third parties to comply with your decision.
• Social Networks. Our Website may include links to other third-party websites, social media tools, widgets or plug-ins, permitting us to share web content with Social Networks when you directly engage with those platforms. For further details, please consult Section 7 (Features and Links to Other Websites).
• As Required By Law. We share your Personal Information if required by law in order to prevent, investigate, or take action regarding illegal activities or to respond to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims. We also disclose your Personal Information to any government or law enforcement authority or regulatory agency in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security.
• Sale of Business. We share your Personal Information as part of or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares or stock and/or assets or other corporate change, including, during the course of any due diligence process.
• Third-Party Service Providers. For the purpose of providing and operating the Website and other services, we share your Personal Information with trusted third-party service providers that require access to such data for the purpose of providing the related services to us, such as ISPs, OS/platform, storage and analytics providers.

Subject to applicable law, you have the right to:

• Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company.
• Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
• Opt-out from receiving marketing communications by clicking on the unsubscribe link contained in such communications.
• Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Those rights may be limited in some circumstances by local law requirements.

If you reside in the United States, you may have additional rights as described in our “U.S. Privacy Addendum”.

To update your preferences, ask us to remove your information from our mailing lists or submit a request to exercise your rights under applicable law, contact us as specified in the "How to Contact Us" section below.

We maintain appropriate administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. The types of measures we take vary depending on the type of data, and how it is collected and stored. We restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you.

We will retain your Personal Information for as long as necessary to operate our Website and to provide our products and services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

We are a global business. We may transfer the Personal Information we collect about you to recipients in countries other than your country, including the United States. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Notice, or as disclosed to you at the time of data collection.

We comply with applicable legal requirements, including obtaining consent where required, when transferring Personal Information to countries other than the country where you are located. In particular, we have established and implemented Binding Corporate Rules (“BCRs”) that have been recognized by EEA data protection authorities as providing an adequate level of protection to the Personal Information we process globally. A copy of our EEA BCRs is available (here). We equally rely on UK BCRs to transfer Personal Information outside of the United Kingdom. A copy of our UK BCRs is available (here.)

We may also transfer Personal Information to countries for which adequacy decisions have been issued (see list of countries for which the European Commission has issued an adequacy decision here (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en); see list of countries which the Swiss Federal Council has determined to provide for adequate data protection legislation here (https://www.fedlex.admin.ch/eli/cc/2022/568/en#annex_1)), use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses or their equivalent under applicable law, or rely on other data transfer mechanisms where applicable. Depending on your country, you may contact us as specified in the “How to Contact Us” section below to obtain a copy of the safeguards we use to transfer Personal Information outside of your jurisdiction.

When we conduct international transfers of Personal Information, we will always ensure to comply with requirements stipulated under applicable laws.

Our Website may display links to the sites of other companies, including those of our enterprise clients. We are not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies by visiting their respective websites, apps, etc.

1. Personal Information Collection and Disclosure

For the purposes of this notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is publicly available, deidentified, or aggregated (as those terms are defined in the CCPA) or otherwise excluded from the scope of the CCPA

Personal Information does not include information that is:

• Lawfully made available from government records.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected and disclosed for a business purpose in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category

Identifiers Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Categories of Personal Information in Cal. Civ. Code Section 1798.80 Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or Other Electronic Network Activity Information Examples: Browsing history, search history, IP address, browser type, operating system and information regarding a consumer’s interaction with an internet website, application or advertisement.

Geolocation Data Example: General location data such as your city, state, country or IP Address.

Sensory Information Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Inferences Drawn from Personal Information Examples: Preferences or other consumer characteristics and interests.



2. Use of Personal Information
   

   We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

   1. Providing Services: Providing our services.
   2. Communicating: Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing support.
   3. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
   4. Personalization: Personalizing your experience on our services, such as presenting tailored content.
   5. Facilitating Payments: Facilitating transactions and payments.
   6. Deidentification and Aggregation: Deidentifying and aggregating information collected through our services and using it for lawful purposes.
   7. Safety Issues: Responding to trust and safety issues that may arise.
   8. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
   9. Auditing Interactions: Auditing related to your interaction with our services and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with other standards.
   10. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
   11. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
   12. Transient Use: Short-term, transient use.
   13. Contracting Vendors: Contracting with vendors and service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytics services, or providing similar services on behalf of the business or service provider.
   14. Research: Undertaking internal research for technological development and demonstration.
   15. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
   16. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
   17. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

3. Collection of Personal Information
   

   In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

   • You/Your Devices: You or your devices directly.
   • Users: Other users of our services.
   • Affiliates.
   • Advertising Networks.
   • ISPs: Internet service providers.
   • Analytics Providers.
   • OS/Platform Provider: Operating systems and platforms.
   • Social Networks.

4. Disclosures of Personal Information

In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties:

1. Advertising Providers: Advertising technology companies, such as advertising networks.
• Personal Information we share: Identifiers; Device Information; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Internet or Other Electronic Network Activity Information; Geolocation Data.
2. ISPs: Internet service providers.
• Personal Information we share: Identifiers; Device Information; Internet or Other Electronic Network Activity Information; Geolocation Data.
3. Analytics Providers.
• Personal Information we share: Identifiers; Device Information; Internet or Other Electronic Network Activity Information; Geolocation Data.
4. OS/Platform Providers: Operating systems and platforms.
• Personal Information we share: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Information or Other Electronic Network Activity Information.
5. Social Networks.
• Personal Information we share: Identifiers; Device Information; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Information or Other Electronic Network Activity Information.
6. Affiliates.
• Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Information or Other Electronic Network Activity Information; Geolocation Data; Sensory Information.
7. Vendors: Vendors and service providers.
• Personal Information we share: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Information or Other Electronic Network Activity Information; Geolocation Data; Sensory Information.
8. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
• Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Information or Other Electronic Network Activity Information; Geolocation Data; Sensory Information.
5. Your Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your email address.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information or “share” Personal Information with third parties for targeted advertising, and we do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Submit Requests. To exercise your rights under the CCPA, please send an email to privacy@dynamicyield.com or through the contact page: https://www.dynamicyield.com/contact/

Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please send an email to privacy@dynamicyield.com and attach a written authorization signed by the resident.

This Notice may be updated periodically to reflect changes in our Personal Information practices. We will notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. If we update this Privacy Notice, in certain circumstances, we may seek your consent.