Consumer Rights under CCPA

Your California Privacy Rights Under the California Consumer Privacy Act (“CCPA”)

Consumer Rights under CCPA
‍A PDF version of VideoAmp’s “Consumer Rights under CCPA” can be found by clicking the following link: PDF Version of CCPA Policy.

If you are an individual who is a resident of California (a California “consumer”), you have the following rights under the California Consumer Privacy Act with respect to your “personal information” (as defined by CCPA):

Right to Know
You have the right to request that a “business” (as defined by CCPA) disclose to you, following your “verifiable consumer request” (as defined by CCPA):

The categories of personal information the business has collected about you
The categories of sources from which the personal information is collected
The business or commercial purpose for collecting personal information
The categories of third parties with which the business shares personal information
The specific pieces of personal information the business has collected about you
The categories of personal information about you that the business disclosed for a business purpose
If the business sells your personal information:
- The categories of personal information that the business sold about you
- The categories of third parties to which your personal information was sold, by category or categories of personal information for each category of third parties to which the personal information was sold
- The business or commercial purpose for selling personal information

Right to Delete
You have the right to request that a business delete, following your verifiable consumer request, the specific pieces of personal information such business has collected from you.

Right to Opt-Out
You have the right, at any time, to direct a business not to sell your personal information. This right is different from the “User Opt Out” described in the VideoAmp Privacy Policy under the header “What Choices Do You Have about the Collection, Use and Disclosure of Information by VideoAmp?” If you would like to opt out of VideoAmp’s targeted advertising, please refer to that section of the VideoAmp Privacy Policy.

Right to Non-Discrimination
You have the right not to be discriminated against by a business because you exercise any of your rights under CCPA, including by:

Denying goods or services to you
Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to you
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

CCPA Personal Information
To provide our services and the Company Features, we utilize (i) personal information collected directly by the Company Features (“Collected Data”), (ii) personal information provided to us by or on behalf of our Customers (“Customer Data”), (iii) personal information that we license from third parties (“Licensed Data”), and (iv) audience segments created by or on behalf of our Customers from Licensed Data (“Segment Data”). Even though Customer Data and Licensed Data are provided to us, for purposes of CCPA, we are considered to have “collected” such data.

We collect (and during the last 12 months have collected) the following categories of personal information, from the following categories of sources, and for the following business or commercial purposes:

Categories of Personal Information	Categories of Sources	Business/Commercial Purposes
Identifiers (such as a unique personal identifier, an online identifier (e.g., a cookie ID or a mobile advertising ID), or an internet protocol address)	Collected Data: we collect such information directly from consumers in the process of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered“data brokers” under California law) Segment Data: identifiers are included within such data, which is created by or on behalf of our Customers from Licensed Data (which we receive from data licensors (who may be considered “data brokers” under California law)), although we do not make any individual identifier(s) available to any such Customer	Collected Data: we use such information solely (i) to provide our services and Company Features to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a“service provider” (as defined by CCPA) under CCPA Customer Data: we use such information solely (i) to provide our services and CompanyFeatures to the particular Customer that provided us such information and (ii)as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) “selling” (as defined by CCPA) such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particular Customer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA
Characteristics of protected classifications under California or federal laws (such as gender, ethnicity, and age)	Collected Data: we collect such information directly from consumers in the process of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered “data brokers” under California law) Segment Data: such personal information is included within such data (which is created by or on behalf of our Customers from Licensed Data, which we receive from data licensors (who may be considered “data brokers” under California law)), although we do not make such data available to any such Customer in a form that we believe could reasonably be linked with an identified consumer or household	Collected Data: we use such information solely (i) to provide our services and Company Features to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a “service provider” (as defined by CCPA) under CCPA Customer Data: we use such information solely (i) to provide our services and Company Features to the particular Customer that provided us such information and (ii) as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) selling such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particular Customer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA
Commercial information (such as records of the products a consumer purchased)	Collected Data: we collect such information directly from consumers in the course of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered “data brokers” under California law) Segment Data: commercial information is included within such data (which is created by or on behalf of our Customers from Licensed Data, which we receive from data licensors (who may be considered “data brokers” under California law)), although we do not make such data available to any such Customer in a form that we believe could reasonably be linked with an identified consumer or household	Collected Data: we use such information solely (i) to provide our services and Company Features to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a service provider under CCPA Customer Data: we use such information solely (i) to provide our services and Company Features to the particular Customer that provided us such information and (ii) as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) selling such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers (that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particular Customer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA
Internet or other electronic network activity information (such as browsing history, search history, information regarding interactions with our Website and our advertising, and TV viewing data)	Collected Data: we collect such information directly from consumers in the course of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered “data brokers” under California law) Segment Data: Internet or other electronic network activity information is included within such data (which is created by or on behalf of our Customers from Licensed Data, which we receive from data licensors (who may be considered “data brokers” under California law)), although we do not make such data available to any such Customer in a form that we believe could reasonably be linked with an identified consumer or household	Collected Data: we use such information solely (i) to provide our services and CompanyFeatures to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a service provider under CCPA ‍ Customer Data: we use such information solely (i) to provide our services and Company Features to the particular Customer that provided us such information and (ii)as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) selling such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particular Customer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA
Geolocation data	Collected Data: we collect such information directly from consumers in the course of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered “data brokers” under California law) Segment Data: geolocation data is included within such data (which is created by or on behalf of our Customers from Licensed Data, which we receive from data licensors (who may be considered “data brokers” under California law), although we do not make such data available to any such Customer in a form that we believe could reasonably be linked with an identified consumer or household	Collected Data: we use such information solely (i) to provide our services and Company Features to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a service provider under CCPA Customer Data: we use such information solely (i) to provide our services and Company Features to the particular Customer that provided us such information and (ii) as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) selling such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particular Customer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA
Inferences (drawn from any of the other categories of personal information of the information to create a profile about a consumer reflecting, for example, a consumer’s product preferences)	Collected Data: we collect such information directly from consumers in the course of delivering an ad in connection with the Company Features Customer Data: we receive such information from our Customers Licensed Data: we receive such information from data licensors (who may be considered “data brokers” under California law) Segment Data: inferences are included within such data (which is created by or on behalf of our Customers from Licensed Data, which we receive from data licensors (who may be considered “data brokers” under California law)),although we do not make such data available to any such Customer in a form that we believe could reasonably be linked with an identified consumer or household	Collected Data: we use such information solely (i) to provide our services and CompanyFeatures to the particular Customer on whose behalf we collected such information and (ii) as otherwise permitted by a service provider under CCPA Customer Data: we use such information solely (i) to provide our services and Company Features to the particular Customer that provided us such information and (ii) as otherwise permitted by a service provider under CCPA Licensed Data: we use such information for our operational and commercial purposes, including (i) to provide targeted advertising, analytics, measurement, planning, and reporting services to our Customers and (ii) selling such personal information to (a) our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities (including targeted advertising) and (b) third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities (including targeted advertising) Segment Data: we use such information solely (i) to provide our services and Company Features to the particularCustomer who created such information or on whose behalf such information was created and (ii) as otherwise permitted by a service provider under CCPA

With respect to Collected Data, Customer Data, and Segment Data, we believe that we are a service provider acting on behalf of the particular Customer; and with respect to Licensed Data, we believe that we are a “third party” (as defined by CCPA), as we collect such information only from our data licensors (who may be considered “data brokers” under California law) and do not collect it directly from consumers.

Please see below under the header “Processing Your Requests” for information about the personal information collected in connection with consumer requests submitted to us under CCPA.

Disclosure of Personal Information
With regard to Collected Data, Customer Data, and Segment Data, we disclose (and during the last 12 months have disclosed) each of the above categories of personal information solely as directed by the applicable Customer.

With regard to Licensed Data, for purposes of the CCPA:

“Sales”: (i) we “sell” (as defined by CCPA) each of the above categories of personal information to our advertiser and agency Customers in connection with their (and, in the case of agency Customers, their respective customers’) marketing and advertising activities, and (ii) we sell (and have sold during the 12 months prior to the “Last Modified” date at the bottom of this Privacy Policy) each of the above categories of personal information third-party data brokers that may further sell such personal information to their customers in connection with such customers’ marketing and advertising activities; however, we do not knowingly sell the personal information of California consumers under the age of 16 without required affirmative authorization; and
“Disclosures for a Business Purpose”: we disclose (and have disclosed during the 12 months prior to the “Last Modified” date at the bottom of this Privacy Policy) each of the above categories of personal information for a “business purpose” (as defined by CCPA) to service providers that perform certain services on our behalf, such as hosting service providers, data analytics providers, advertising and marketing service providers, technology consultants, and consumer information verification providers.

Methods of Submitting Requests
If you are a California consumer, you may submit requests to exercise your “Right to Know” or your “Right to Delete” via any of the following methods:

By web form, available by clicking the following link: CCPA Request Web Form
By email, to: CCPAPrivacy@VideoAmp.com
By toll-free telephone, to: 1 (844) 954-1754

Processing Your Requests
The process we currently use to verify and process “Requests to Know” and “Requests to Delete” under CCPA requires us to recognize the requestor’s VideoAmp cookie ID (and if one cannot be found, to place a VideoAmp cookie ID onto the requestor’s browser), and we are not technically able to perform such process unless the requestor visits our web form (where we also collect additional information about the requestor’s TV viewing and household as part of our verification process for such requests). Therefore, if you submit such a request via either the telephone number listed above or the email address listed above, it will require more time and at least one more step than if you were to submit your request via web form. We will respond to both telephone and email requests by sending you a link to the web form. The web form will prompt you to confirm your request and submit the additional information described above.

Please note that the process we currently use to verify and process “Requests to Know” and “Requests to Delete” under CCPA also requires a service provider to recognize or place its cookie ID on your browser when you visit our web form; such service provider may use the information it collects during performance of this service (which collected information consists only of Identifiers (cookie IDs)) only on our behalf in connection with this process. We use the information that we collect to verify and process “Requests to Know” and “Requests to Delete” under CCPA (which information includes Identifiers (such as email addresses and cookie IDs) and Internet or other electronic network activity information (such as TV viewing information)) only in connection with such purposes and for security and/or fraud-prevention purposes.

If you are a California consumer, you have the right, at any time, to direct us not to sell your personal information; you may exercise such “Right to Opt Out” under CCPA by clicking the “Do Not Sell My Personal Information” link below, which takes you to the web form listed above, or via any of the other methods described above:

DO NOT SELL MY INFORMATION

The process we currently use to process “Requests to Opt-Out” under CCPA requires us to recognize the requestor’s VideoAmp cookie ID (and if one cannot be found, to place a VideoAmp cookie ID onto the requestor’s browser), and we are not technically able to perform such process unless the requestor visits our web form. Therefore, if you submit such a request via either the telephone number or the email address listed above, it will require more time and at least one more step than if you were to submit your request via the web form. We will respond to both telephone and email requests by sending you a link to the web form. The web form will prompt you to confirm your request. Please note that the process we currently use to process “Requests to Opt-Out” under CCPA also entails a service provider recognizing or placing its cookie ID on your browser when you visit our web form; such service provider may use the information it so collects (which consists only of Identifiers (cookie IDs)) only on our behalf in connection with our CCPA request processes. We use the information we collect to process “Requests to Opt-Out” under CCPA (which information includes Identifiers (such as email addresses and cookie IDs)) only in connection with such purpose.

Please note that, if you are opted out of targeted advertising on the web browser you are using when you visit our web form, or if your browser is configured to block cookies, we may not be able to process your “Right to Opt Out” request, since we may have no reasonable method of connecting your request to opt-out under CCPA with your Licensed Data. However, as (i) Licensed Data originates from TV viewing information and (ii) we receive Licensed Data from data licensors (who may be considered “data brokers” under California law) that have contractually agreed to comply with all applicable privacy laws and regulations, we believe that you should also be able to exercise CCPA rights, including the right to opt out under CCPA (i.e., to elect “Do Not Sell”), with respect to your personal information through your smart TV(s), MVPD device(s), and/or OTT box/device(s).

Authorized Agents
If you are a California consumer, you may use an “authorized agent” (as defined by CCPA) to submit a “Request to Know”, a “Request to Delete”, and/or a “Request to Opt-Out” under CCPA on your behalf. Your authorized agent will need to provide us with a copy of a written permission that is signed by you and indicates that you have provided such authorization. Also, as both (i) the process we currently use to verify and process “Requests to Know” and “Requests to Delete” under CCPA and (ii) the process we currently use to process “Requests to Opt-Out” under CCPA require (a) us to recognize the requestor’s VideoAmp cookie ID (and if one cannot be found, to place a VideoAmp cookie ID onto the requestor’s browser) and (b) the requestor to visit our web form, your authorized agent will also need to use your device in connection with any such CCPA request.

Recordkeeping Information
VideoAmp will maintain records of consumer requests made pursuant to CCPA and how we responded to those requests in accordance with CCPA.

CCPA Metrics for Calendar Year 2021

Pursuant to § 999.317(g)(1) of the CCPA Regulations the following metrics have been compiled:

Requests to Know:

Received	Complied	Denied	Average Response Time
24	0	24	6.5

Requests to Delete:

Received	Complied	Denied	Average Response Time
30	0	30	6.5

Requests to opt-out:

Received	Complied	Denied	Average Response Time
23	23	0	5.3

If you are a California consumer and have any questions or concerns about our privacy policies or If you are a California consumer and have any questions or concerns about our privacy policies or practices, please email us at CCPAPrivacy@VideoAmp.com.

Last Modified: July 13, 2022

Consumer Rights under CCPA

Your California Privacy Rights Under the California Consumer Privacy Act (“CCPA”)

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