Services Privacy Policy

OVERVIEW

This privacy policy governs the services provided by the National Cable Communications LLC dba Ampersand (“Ampersand”) through its AND Platform to its clients (“Services Privacy Policy”). This Services Privacy Policy describes how Ampersand collects, uses, shares and secures information on its AND Platform (the “Services”). The AND Platform is directed at our commercial clients and may not be used for personal or household use.

The AND Platform allows Ampersand clients to plan, execute, and measure their audience-based multi-screen TV campaigns by leveraging viewing insights. Ampersand’s clients and other third parties may use or interact with the AND Platform. They are subject to contractual terms and other limitations Ampersand has put into place. This Services Privacy Policy only describes Ampersand’s practices and does not apply to any third parties.

Please visit our privacy policy if you are interested in learning more about how Ampersand collects data through its websites and its career privacy policy for how it collects data from job applicants.

WHAT INFORMATION DO WE COLLECT AND USE?

Ampersand may collect or receive data in connection with its Services, including, without limitation, as follows (“Data Insights”):

• Identifiers: if available, a unique, randomized identifiers that enable Ampersand to recognize a household or device across different content.

• Device identifiers: a pseudonymized identifier such as mobile advertising IDs (e.g., iOS IDFA and Android AAID), IP address, OTT/CTV IDs, gaming console IDs, cookie IDs, proprietary IDs.

• Location: precise geographic location, if available from the device, and provided by the publishers, and/or imprecise location as derived from IP address or provided by the publisher.

• ZIP +4: Publicly available household postal codes; used to identify a household address, which devices and segments are associated to for “household-level” targeting.

• Ad information: information about the ads that were shown, such as what type of ad and where and when they were shown (day and time).

• Inferences or audience segmentation provided from third parties or clients, such as preferences, characteristics, and behaviors.

• Information about ads served or delivered, including the type of ad, where the ad was served and whether you visited the advertiser’s website or downloaded the advertiser’s app.

• Other information shared in connection with this data.

Ampersand does not collect or receive information that directly identifies an individual such as name, email address or phone number but may collect information related to a particular household. Ampersand also prohibits its clients from introducing information that directly identifies a particular person onto the AND Platform and does not allow its clients to reidentify any individuals from the aggregate reports they receive.

However, some data of the data that Ampersand receives, such as IP address, randomized identifiers, and precise geolocation, may be considered personal data under certain laws. Also, although Ampersand does not collect information that directly identifies an individual, it is possible that the data could be matched to directly identifying personal information.

In addition, clients may introduce other pseudonymized data to the AND Platform which is then used to improve client’s advertising. This may include information such as demographic information or interest information. Interest information reflects a household or individual’s interests. Demographic information could be information about age, income level, or other demographic characteristics. The client may have this data or may acquire it from other third parties or data aggregators.

Last, we will collect identify information, such as name, work email address, and username, from our clients and their registered users of the AND Platform. The collection, use and deletion of this information from Platform users will be covered by the Authorized User Privacy Policy.

HOW DOES AMPERSAND USE THIS INFORMATION?

• Ampersand allows its clients to use the AND Platform for advertising related purposes, including to plan and measure their audience-based multi-screen TV campaigns by leveraging proprietary Data Insights to effectively meet their advertising goals. Clients may also use the AND Platform for frequency capping (limiting the number of times a household sees an advertisement), geo-targeting advertisements, ad measurement, aggregated reports and statistics, and for other purposes related to the sale, delivery or measurement of advertisements.

• Ampersand may use Data Insights to analyze, create, and provide reports on advertising campaigns.

• Ampersand may use the information and data from and in the AND Platform to analyze use of the AND Platform, including unauthorized use of the AND Platform.

• Ampersand may use the information and data from the AND Platform to debug errors in its system.

• Ampersand may use the AND Platform users’ information to communicate with its clients and their users, administer the AND Platform, and for other purposes permitted by our clients.

TO WHOM DOES AMPERSAND DISCLOSES INFORMATION?

Ampersand may disclose to the Data Insights that it collects or receives to clients and third parties as follows:

• Operation of the Platform: To clients and their designees for the advertising purposes set forth above.

• Service Providers: Ampersand may disclose this information to third parties where necessary to provide the AND Platform features and functionality. Third-party service providers perform certain services on Ampersand’s behalf, such as processing, storing, maintaining and transmitting the Data Insights. These third-party service providers are contractually restricted from using the Data Insights for any other purpose and required to comply with all applicable laws with respect to Data Insights they receive.

• Business transfers: If a third party acquires all or substantially all of Ampersand’s assets, the information and data insights may be transferred to such third party as part of Ampersand’s business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against Ampersand, all such information may be considered one of Ampersand’s assets and may be sold or transferred to third parties.

• Disclosure of Data Insights for legal purposes and protection of Ampersand and others: Ampersand reserves the right to share Data Insights with third parties if required to do so by law, or if Ampersand believes such action is necessary in order to: (1) conform to the requirements of the law or comply with legal process served upon Ampersand; (2) protect or defend Ampersand legal rights or property, the AND Platform, or the AND Platform users; or (3) investigate, prevent, or take action regarding illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person.

• Government Agencies: Ampersand will disclose Data Insights to third parties if required to do so by law.

• As Otherwise Permitted by Law: Ampersand may disclose Data Insights to third parties as otherwise permitted by applicable law.

SECURITY

HOW WE PROTECT THE SECURITY OF YOUR PERSONAL INFORMATION

Ampersand will take reasonable steps to protect the security and integrity of any individually identifying information stored within the AND Platform. However, due to the inherent nature of the Internet as an open global communications vehicle, Ampersand cannot guarantee that information, during transmission through the Internet or while stored on its system or otherwise in its care, will be safe from intrusion by others, such as hackers. Ampersand will have no liability for disclosure of data in the AND Platform due to errors or unauthorized acts of third parties during or after transmission.

PRIVACY POLICY UPDATES

This Privacy Policy was updated on the “Effective Date” date noted below. Ampersand reserves the right to change, modify, or amend this Services Privacy Policy from time to time to reflect changes in our privacy practices.

CONTACT US

HOW TO CONTACT NCC MEDIA REGARDING YOUR PRIVACY CONCERNS AND QUESTIONS.

If you have any questions or comments regarding our privacy practices, you may contact us at privacy @ ampersand.tv.

Effective Date: November 4, 2021