About Us

Locala provides a location-based digital platform for advertisers (e.g., retail chains, restaurants, and car
dealerships). Our platform enables clients to evaluate store performance, identify potential customers, show ads to
existing and prospective customers, and measure ad effectiveness. In providing this platform, we sometimes act as a
data processor to our clients (in which case this policy does not apply). In other cases—such as when we help
clients target ads to their customers—we act as a controller, and this policy applies.

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Collection of Information

We may collect information about you through our partners that license data to us or directly, such as when you
visit a website or mobile app that calls our servers to show an ad. This information includes:

• Device Identifiers and Activity Information: identifiers assigned to your device and network
  (e.g., IP address and mobile advertising identifiers), along with information about ads or content you view or
  click on websites or in mobile apps and the time of such activity.
• Precise Geolocation Information: latitude and longitude of your device (as permitted by your
  device settings). We associate precise geolocation with specific areas/locations to infer presence at a place at
  a given time.
• Information from Other Sources: information from other services (including data brokers), which
  may include precise geolocation and online activity.
• Information We Derive: inferences drawn from the information collected (e.g., visits to a type
  of store suggesting interest in a type of business).

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Use of Information

We use the information we collect to deliver personalized advertising, including assisting clients in showing ads
to people who have visited their establishments or who may be likely to visit, and to measure ad performance
(including through precise geolocation). We also use the information to:

• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious,
  deceptive, fraudulent, or illegal activity, and help protect the rights and property of Locala and others;
• Improve our products and services and develop new offerings; and
• Comply with our legal and financial obligations.

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Targeted Advertising

We use the information we collect to help our clients deliver advertising targeted to you (sometimes called
“targeted advertising”). You can opt out of our use of information to show interest-based ads by visiting
Your Privacy Choices
(see the link in the site footer).

You can also learn more about interest-based ads, or opt out of having your web browsing information used for
behavioral advertising by DAA participants, at
aboutads.info/choices.

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Disclosure of Information

We disclose the personal information we collect in the following scenarios:

• Vendors and Service Providers: to entities that perform services on our behalf.
• Law Enforcement and Legal Process: in response to requests where required or permitted by law,
  including to meet national security or law enforcement requirements.
• To Protect Rights: if we believe your actions violate our terms or the law, or to protect the
  rights, property, and safety of Locala, the public, or others.
• Professional Advisors: to legal, financial, insurance, and other advisors.
• Corporate Transactions: in connection with, or during negotiations of, mergers, asset sales,
  financing, or acquisitions.
• Corporate Affiliates: within the Locala group (parents, affiliates, subsidiaries).
• With Your Consent or Direction: when you consent or direct us to share.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We
maintain and use such information only in a de-identified fashion and will not attempt to re-identify it, except
as permitted by law.

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Data Retention

We store precise location information for four (4) months unless we need to retain it longer (e.g., to meet legal obligations).

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Your Choices

Precise Geolocation Information

When you use certain mobile apps, they may ask permission to collect precise geolocation information. If you
provide consent, your location information may be shared with us by the app developer or another partner. You can
stop collection at any time by changing your device preferences. Please review the settings and privacy policies
of the apps you use.

Cookies and Similar Tracking Technologies

Locala and our clients/partners may use cookies and similar technologies. You can usually adjust your browser
settings to remove or reject cookies.

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Additional Information for Specific Jurisdictions

Individuals Residing in Certain U.S. States

Some U.S. states have privacy laws granting residents certain rights and requiring specific disclosures (“State
Privacy Laws”). If you reside in California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New
Hampshire, New Jersey, Oregon, Texas, Utah, Virginia, or any other state with an applicable privacy law, this
section applies to you. This section also serves as our California notice at collection.

Additional Disclosures

Above we explain how we collect, use, and disclose
information about you, as well as our targeted advertising practices. As required by some
State Privacy Laws, the table below presents this information in another format.

We retain personal information as described above.

Your Rights under State Privacy Laws

Opt Out of Sales, Sharing, and Targeted Advertising

Some activities described in this policy (e.g., personalizing ads) may constitute “targeted advertising” (and, in
some states, “sales” or “sharing”). You may opt out of Locala’s use of your information for these activities—
including any use of precise geolocation for such purposes—by following the prompts behind
Your Privacy Choices
(link in our site footer).

Access, Correction, and Deletion

You may have the right to request access (including in a portable format), deletion, and correction. To exercise
these rights or ask questions about our processing, email
privacy@asklocala.com or call toll-free (800) 607-7838. To authenticate
your request, we may ask for proof that the device at issue belongs to you. If your request concerns processing by
our clients, they are solely responsible for responding; we will forward your request to them.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

Appeals

If we deny your request, you may appeal by contacting us at
privacy@asklocala.com. If you have concerns about the result of an
appeal, you may contact your state attorney general.

Authorized Agents

Authorized agents seeking to submit opt-out requests may contact
privacy@asklocala.com. California residents may designate an authorized
agent to submit access, deletion, or correction requests. We may require proof of authority (e.g., power of
attorney or signed permission) and may contact the consumer to verify identity or confirm authorization.

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Contact Us

If you have questions about this Privacy Policy, contact us at
privacy@asklocala.com.

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