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Tagger Media User Privacy Policy

Effective as of February 7, 2022.

This “User Privacy Policy” (or “Privacy Policy”) describes the privacy practices of Tagger Media Inc. and our subsidiaries and affiliates (collectively, “Tagger”, “we”, “us”, or “our”) with respect to our processing of personal information about you. For the purposes of this Privacy Policy, “you” means any user who uses any of the services that we offer, including visitors to our website and mobile application, users of Tagger Media Analytics Platform and any other services we may offer from time to time (collectively, “Services”). This Privacy Policy applies to all users, including those users who use the Services via their employer or another company.

This User Privacy Policy provides information about the types of personal information we hold about you in connection with us and how we collect, use and share it. It also tells you about your rights and how they can exercise those rights. We provide important information for users located in the European Union, European Economic Area, and United Kingdom (collectively, “Europe” or “European”) in the Notice to European Users section of this policy. We provide important information for users who are residents of California in the Your California Privacy Rights section of this policy.

Please note that this User Privacy Policy does not apply to individual authors of content, or creators, in connection with our creator platform. You can find the Creator Privacy Policy here: https://www.taggermedia.com/privacy-policy-creator This User Privacy Policy also does not apply to any personal information in connection with which Tagger acts as a processor or service provider on behalf of our customers or others. For example, once you enter a contract or otherwise engage with one of our customers, the processing of your personal information by our customer is outside of our control and subject to our customer’s privacy policies, practices and any contract or other arrangement you or we may have with the customer. Should you have any questions or concerns concerning the processing of your personal information by one of our customers, please direct your inquiries to that customer.

Table of Contents

Personal Information We Collect

We may collect the following types of personal information about you in the following ways:

Services

If you register as a user of any of our Services, we may ask you to provide:

When providing information about yourself, pay special attention to the proper protection of username and password. If you are not an administrative user for your account, the same information about you may be provided by a colleague or other third party. We may also collect other information directly from you, from time to time.

If you contact our support services, we will collect the information we need to categorize your question and respond to it. We also use this information to track potential issues with our Services and customize our support responses to better serve you.

We collect information about you when you use any part of our Services. For example, if you are logged in to Tagger Media Analytics Platform, we will collect information as to how often it is used, what queries are created or amended, what mentions are looked at and other information about how you interact with our Analytics Platform. We may also collect information about how you interact with messages we send to you. We will not collect sensitive or excessive information from you. If you notice that sensitive information is collect from you, check it – maybe someone is impersonating our services.

We also infer information about you based on the information you have provided or made available to us. This may include personalizing your experience of using our Services, suggesting different Services you may be interested in trying, or other inferences about you.

We are constantly trying to improve our Services to you. This means that we are introducing new features of our Services regularly, some of which may result in the collection of new information from you. In this case, we will regularly inform you about it.

Tagger Media does not are processing special categories of personal data as defined by Article 9 of GDPR but if we are processing – does it not intentionally. Tagger Media does not process special categories of personal data as defined by Article 9 of GDPR.

Website

In addition to the information that you provide to us, we may also collect information about you during your visit to our Services. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Services. Some of the tools we use to automatically collect information about you may include:

Customer Data We Collect as a Service Provider/Processor. Our customers may supplement the personal information we make available to them via services with personal information about you that they have procured independently (“Customer-Procured Data”). Our customers input such Customer-Procured Data into our services, and we only use Customer-Procured Data to provide our webpage and services to that customer. However, this data is provided in the discretion of our customers and Tagger has no control over the input of such data. Such data may include additional (but non-public) information within the categories of data identified above.

In respect of this Customer-Procured Data, to the extent received solely from our customers and not otherwise, we act as a processor or service provider on behalf of our customers for their respective Customer-Procured Data. Our processing of any such personal information is outside the scope of this User Privacy Policy and is subject to our customers’ own privacy policies and practices and any contract or other arrangement you or we may have with such customer.

How We Use Your Personal Information

We may use your personal information for the following purposes and as otherwise described in this Privacy Policy:

To operate services and our business and to serve our customers. We use your personal information to operate services and our business and to provide our services to our customers, including to:

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and the personal information of other individuals. We may use this anonymous, aggregated or de-identified data and share it with our customers and other third parties for our lawful business purposes, including to analyze and improve our services and to promote our business.

Compliance and protection. We may use your personal information to:

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How We Share your Personal Information

To the extent permitted by applicable law and our contractual obligations, we may share your personal information with the following parties or as otherwise described in this User Privacy Policy or at the time of collection:

Your Choices

All users, regardless of where they live, have the following rights:

If you are a resident of a jurisdiction that affords you additional rights by law with respect to your personal information, you may also have some or all of the following rights:

Certain of these rights, as applicable, are described in the Your California Privacy Rights and Notice to European Users sections, below. You can exercise any of the above rights by emailing privacy@taggermedia.com or as otherwise provided in the Your California Privacy Rights and Notice to European Users sections, below, to the extent applicable.

Security practices

The security of your personal information is important to us. We employ a number of technical, organizational, physical and contractual safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about transfers of personal information outside of Europe.

Children

We do not knowingly collect personal information from children. We define "children" as follows:

If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. If you are a parent or guardian of a child and believe we have collected the personal information of your child without your consent, please contact us to have this information deleted.

Changes to this User Privacy Policy

We reserve the right to modify this User Privacy Policy at any time. If we make material changes to this User Privacy Policy, we will notify you by updating the date of the policy and posting it on our website at https://www.taggermedia.com. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if we have your contact information). Any modifications to this User Privacy Policy will be effective upon our posting or as otherwise indicated at the time of posting. In all cases, your use of services after the effective date of any modified User Privacy Policy indicates your acceptance of the modified terms of the policy.

How to Contact Us

Please direct any questions or comments about this User Privacy Policy or privacy practices to privacy@taggermedia.com. You may also write to us via postal mail at: 2001 Wilshire Blvd. Suite 301, Santa Monica, CA 90401

Your California Privacy Rights

This section describes how we collect, use, and share Personal Information of users that are California residents in connection with our services in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) / The California Privacy Rights Act (“CPRA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA/CPRA but does not include information exempted from the scope of the CCPA/CPRA. Your California privacy rights. California residents have the rights listed below under the CCPA/CPRA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by calling us toll free at 1-(888) 201-4517, or via email to privacy@taggermedia.com.

Exercising your right to opt-out of certain sharing of your Personal Information. We share Personal Information with our customers as described in this User Privacy Policy. Because the CCPA/CPRA defines the term “sale” very broadly, such sharing could be considered a “sale” under the CCPA/CPRA. You can request to opt-out of behavioral advertisement and the sharing of your Personal Information here: Do Not Sell Or Share My Personal Information.

Exercising your right to limit the use of your Personal Information. You can request to limit the use of your Personal Information here: Limit The Use Of My Sensitive Personal Information.

Verification of your Requests; Authorized Agents. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, you will need to provide us with the following information about you: Full name, e-mail and links to social media handles. Depending on the nature and scope of your request, we may also need to request additional information from you, which we will use only for the purposes of verification. Upon receipt of your request, we will notify you if we need additional information from you to verify your request. We do not charge a fee to process or respond to your 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.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide the information we request to verify your identity and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this User Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this User Privacy Policy in more detail. Information you voluntarily provide to us, such as in the content of your posts, content from chats you engage in with our customers or others, or data input into free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the chart below, we disclose Personal Information as described in the How we share your personal information section, above.

Statutory category / Personal information we collect in this category Source of PI Business/commercial purpose for collection Categories of third parties to whom we “disclose” PI for a business purpose Categories of third parties to whom we “sell” PI
Identifiers
  • Identification data
  • You
  • Third-party sources
  • Service delivery
  • Compliance & protection
  • With your consent
  • Service providers
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Others, with your consent or at your direction
California Customer Records (as defined in California Civil Code §1798.80)
  • Identification data
  • Professional contact data
  • You
  • Third-party sources
  • Service delivery
  • Compliance & protection
  • With your consent
  • Service providers
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Others, with your consent or at your direction
Internet or other similar network activity
  • Browsing history
  • Search history
  • Information on a consumer's interaction with a website
  • Application, or advertisement
  • You
  • Third-party sources
  • Service delivery
  • Compliance & protection
  • With your consent
  • Service providers
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Others, with your consent or at your direction

Your California privacy rights. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to privacy@taggermedia.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals in Europe. Personal information. References to “personal information” in this User Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Controller and representatives. Tagger Media Inc. is the controller of your personal information covered by this User Privacy Policy for purposes of European data protection legislation. Our representative in the European Union is European Data Protection Office (EDPO). You can contact EDPO regarding matters pertaining to the GDPR:

Our representative in the UK is EDPO UK Ltd. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

Data Protection Officer (“DPO”). We have appointed a DPO. Our DPO can be contacted at privacy@taggermedia.com.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this User Privacy Policy are described in the table below.

Purpose Category(ies) of personal information involved Why do we do this Our legal basis for this use of data

To operate the Platform and our business and to serve our customers.

  • Identification data
  • Professional contact data
  • Browsing history
  • Search history
  • Information on a consumer's interaction with a website
  • Application, or advertisement
  • To operate, maintain, administer and improve the Platform
  • Legitimate Interests
  • We have a legitimate interest in providing and improving services. We consider and balance any potential negative impact on you and your rights before we process your information. We do not use your personal information for these activities where our interests are overridden by the impact on you.

To create anonymous, aggregated or de-identified data.

  • See above
  • To analyze the use of the Platform and make improvements
  • Legitimate Interests
  • We have a legitimate interest in providing and improving services. We consider and balance any potential negative impact on you and your rights before we process your information. We do not use your personal information for these activities where our interests are overridden by the impact on you.

Compliance and protection.

  • Identification data
  • Professional contact data
  • Browsing history
  • Search history
  • Information on a consumer's interaction with a website
  • Application, or advertisement
  • Chat data and other correspondence
  • To keep our Platform and associated systems operational and secure
  • To enforce the terms and conditions that govern the Platform
  • Compliance with a legal obligation
  • Legitimate Interests
  • We have a legitimate interest in providing and improving services. We consider and balance any potential negative impact on you and your rights before we process your information. We do not use your personal information for these activities where our interests are overridden by the impact on you.

Use for new purposes

We may use your personal information for reasons not described in this User Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information

We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through services, webpage, or otherwise to us. If you provide us with any sensitive personal information when you use services, you must consent to our processing and use of such sensitive personal information in accordance with this User Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through services.

Profiling and automated decision making

Profiling is the automated processing of personal information to evaluate certain things about an individual. Automated decision-making means decisions made solely by automated means without any human involvement. We do not currently use profiling or automated decision-making mechanisms when processing your personal information.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:

You may submit these requests by email to privacy@taggermedia.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Cross-Border Data Transfer

If we transfer your personal information out of Europe to a country not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of personal information protection, the transfer will be performed subject to appropriate safeguards and otherwise in accordance with European data protection laws. You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

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