PRIVACY POLICY

Last modified: November 24, 2020

Introduction
Chalk Digital, Inc., d.b.a. Chalk Digital (“We” or the “Company”) operates the website at www.chalkdigital.com (our “Website”) and a mobile advertising platform (together with the Website, the “Service”).
This Privacy Policy (this “Policy”) describes our practices for the collection and use of the information we may collect from visitors to our Website, advertiser customers of the Service, or end-users of mobile apps and websites that display ads from our Service. It does not apply to information collected by us offline or through any other means, including on any other website operated by any third party; or us or by any third party (including our affiliates and subsidiaries).
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and the Service. By accessing or using this Website or the Service, you agree to this Policy. We may make changes to this Policy from time to time (see Changes to our Privacy Policy). Your continued use of this Website or the Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@chalkdigital.com.

End-User Information
What We Collect

When you use a mobile app or visit a website that displays ads distributed through the Service, we may collect information about your device and the ads that are displayed or that you click on. Examples of this information are (but not limited to):
• Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser (e.g. Chrome, Safari), and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or unique device identifier (a number uniquely allocated to your device by your device manufacturer);
• Log information, including the app or website, visited, the time and your time zone, network connection type (e.g., WiFi, cellular), and cookie information;
• The geo-location of your device (using GPS or other geo-location data), when location services have been enabled for the mobile app or website displaying the ad from our Service;
• Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or purchased the product or service advertised; and
• Non-personally identifying information that our advertisers or other third parties have collected and shared with us to help make the ads served to you more relevant.

What We Do Not Collect
We do not collect personal information like name and physical address of the website visitor or the end user we serve an ad to, except when the user provides this information to us directly (Please read section Information We Collect Directly).

How We Use User Data
We use end-user information to provide and improve our Service. For example, we use it to serve ads, to prepare reports about ads and their effectiveness, to place ads more effectively and appropriately based on an end user’s location or inferring an end user’s interests from a website and mobile app activity, and to optimize and improve our technologies and delivery of our Service.

Sharing of End User Information
We may share with our advertiser customers aggregated information about end-user activity regarding the ads placed by our advertiser customers, such as the number and types of end-users that viewed or clicked on ad, their device IDs, if requested. This information will not include any personally identifiable information.We use third party data in certain cases, but third-party data providers do not have access to any of our end user data that we used to build our models.

Through third-party data providers we may collect information from and about Website visitors and advertising customers of the Service, including information:
• By which you may be personally identified, such as name, postal address, email address, telephone number, third party login information, or payment method information (“personal information”);
• That is about you but individually does not identify you; and
• About your internet connection, the equipment you use to access our Website and usage details.
We never share this data with anyone for any purpose or share our end-user data with third parties.

Chalk uses Google Marketing Platform’s remarketing pixel to gather information on the audience who visited Chalk and other websites.

Information We Collect Directly
We collect this information directly from you when you provide it to us, or as we process your transactions, for example:
• Information that you provide by filling in forms on our Website, including information provided at the time of registering to use our Website, placing orders for advertising or other services, or requesting further services relating to the Website or your use of the Website;
• Records and copies of your correspondence (including email addresses), if you contact us;
• Your responses to surveys that we might ask you to complete for research purposes; and
• details of transactions you carry out through our Website and of the fulfillment of your orders.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website; and
• information about your computer and internet connection, including your IP address, operating system and browser type.
The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Website and to deliver better and more personalized service, including by enabling us to:
• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Website according to your individual interests; and
• recognize you when you return to our Website.

We may use third-party analytics services to provide us with analytic data collection and reporting. We will not provide any personally identifiable information to such third parties.

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
• To present our Website and its contents to you.
• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form or registration form) or adjust your user preferences in your account profile, or by sending us an email stating your request to privacy@chalkdigital.com. If we have sent you a promotional email, you may select the “unsubscribe” link at the bottom of the email and follow the opt-out instructions. This opt-out does not apply to information provided to the Company as a result of a product or service purchase, product service experience, or other transactions.

Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at privacy@chalkdigital.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
All Users, Including End Users and Website Users

How We Respond to “Do Not Track” Signals
Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using one of these settings on a device, we will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Your web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, we will not use web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.
The activities of any third parties are subject to their own privacy policies and are not covered by this policy.

Data Collection Technologies
The technologies for data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Other Technologies. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on our Website or on other websites or mobile applications are served by third-parties, including advertisers, ad networks and servers, content providers, application providers and Google. These third parties may use cookies alone or in conjunction other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We also use Google’s  remarketing, feature in Google Ads that allows Chalk to reach people who previously visited the website and match the right people with the right ad-message.

Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates;

• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about end users or our Website users is among the assets transferred;

• To fulfil the purpose for which you provide it;

• For any other purpose disclosed by us when you provide the information; or

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request;

• To enforce or apply our terms of use Terms and conditions and other agreements, including for billing and collection purposes; or

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.
Choices About Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We will use commercially reasonable efforts to safeguard the information that you submit to us.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

How long do we keep the information for?
If a user sees an ad delivered via Chalk’s platform, we retain the information relating to the user’s device, location, the ad and the click for a duration of 18 months for reporting purposes. For data related to any ad request, we retain the data for a period of up-to 30 days.

After the 30-day period, we may retain and use ad request data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, to resolve disputes and to enforce agreements.

Opting out of the Digital advertising service powered by Chalk Digital
Chalk Digital has created a technology that enables advertisers to place advertisements for their product or services on websites and mobile apps where you may visit. Cookies and other non-cookie technologies such as web beacons or tags, statistical identifiers and/or mobile advertising ID (e.g., Apple’s IDFA) are used to measure the effectiveness of these ads and to determine the display of content and advertising to you based on your interests both on third-party sites and mobile apps where you may visit. To support this interest-based advertising solution, we, and companies who we have contracted with, may use non-personally identifiable information about your visits to our and other Web sites. The information collected does not enable any third-party to identify or contact you individually, without appropriate notice or consent. Although it is our hope that you find the display of advertising to you based on your non-personally identifying browsing interests valuable, if you would prefer not to participate in the services offered through these solutions, you can always opt-out of this activity by visiting https://geoad.chalkdigital.com/#/mobile/opt/page
Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.
If you prefer not to receive interest-based- mobile advertising from Chalk Digital, you can opt out of this advertising at any time by going to the Opt-Out page and submitting your device ID. To do that please go to https://geoad.chalkdigital.com/#/mobile/opt/page
Please note that if you opt-out of the interest-based ads, the user will see ads, but they will not be relevant.

Opting out of Third Party tracking

When you visit a website utilizing any browser, you automatically share information with that website, such as cookies, your IP address, and other information. If the website contains content provided by a third party website some information about you may be automatically sent to the content provider. When you utilize the “Do-Not-Track” feature in your web browser, that browser will send a “Do-Not-Track” request to the websites you visit and to the third party content hosted on those sites to let the sites know that you would prefer not to be tracked. Websites may continue to engage in tracking activities even though you have expressed this preference.

User can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. Users can also  opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using their device’s settings.

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make what we, in our sole discretion, believe is a material change to this Policy, we will notify our registered Website users by email to the email address specified in each user’s account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

For any further queries please write to us at info@chalkdigital.com