1. INTRODUCTION

SenseLab SAS ("SenseLab", "we", "us" or "our") develops eye-tracking solutions and measurement solutions for online advertising. We specifically use the following domains and subdomains :

We provide independent digital media measurement, data and analytics about advertisement (or "ad") and impression delivery, to help advertisers and advertising inventory sellers (together "Customers") confirm accurate delivery characteristics, including brand safety, viewability metrics, contextual and environmental parameters (for example, the website on which an ad appears, and where it appears on the webpage), ad impression characteristics, and provide insights that allow our Customers to make informed decisions about the placement of their creative and brand.

SenseLab uses various technologies to collect information about online advertising, website traffic, mobile app traffic, and connected device traffic in order to deliver advertising transparency and accountability products and solutions to our Customers (collectively, "Solutions").

We treat any data that relates or is linked to an identified or identifiable individual as "Personal Information" regardless of that individual's location. As it relates to our Solutions, SenseLab limits any information we collect to information that does not allow the identification of an individual without additional information. For example, SenseLab processes your Internet Protocol ("IP") address, which is a number that is automatically assigned to a computer when the Internet is used. While SenseLab treats such information as Personal Information, in accordance with best practices and applicable laws, we never combine that information with any other data that would enable us to identify the individual to whom it relates.

This notice of privacy practices (the "Solutions Privacy Notice") is intended to inform individuals whose data may be processed through our Solutions ("End User(s)" or, "you" and "your") of: (1) the types of information SenseLab may gather about you or your device when an advertisement that is analyzed by us is delivered to you on a website you are viewing or in an app you are using, (2) our privacy practices, how we may use, share, and otherwise process information that is deemed Personal Information, and (3) what your rights are with regards to such Personal Information. This Solutions Privacy Notice also explains what non-personal information ("Technical Information") we collect about the ads that we track and how we use that Technical Information to power our Solutions.

This Solutions Privacy Notice covers all SenseLab Solutions and subsidiaries, unless a separate Solution-specific notice is posted on the relevant website.

2. ROLE, PURPOSE AND LEGAL BASIS OF PROCESSING

SenseLab's fraud prevention ("Fraud Prevention") and geography compliance authentication ("Geo Authentication") Solutions require the processing of Personal Information. SenseLab operates Fraud Prevention as a "controller" and Geo Authentication as a "processor". With respect to the California Consumer Privacy Act ("CCPA"), our designation may vary depending on the specific relationship with each Customer. As it relates to Fraud Prevention we may serve as a "business" or a "non-third party". As it relates to Geo Authentication we serve as a "service provider".

SenseLab's legal basis for processing Personal Information through our Solutions is the legitimate interest of: (i) our Customers to avoid ad-related fraud and present geographically accurate and compliant information to End Users, (ii) the End Users in receiving fraud-free and geographically accurate and compliant information, and (iii) the general public in the continued availability of a free internet.

SenseLab participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. SenseLab's identification number within the framework is 1142.

SenseLab's other Solutions (such as viewability, context authenticity, brand safety, media quality, ad experience, premiumness) do not require the processing of Personal Information.

3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSES?

SenseLab, to carry out its business purposes of providing, maintaining and improving its Solutions collects and uses certain categories of Personal Information and Technical Information. The categories of Personal Information and Technical Information processed through the SenseLab Solutions are outlined below. To the extent Personal Information is required for the operation of one or more features of a SenseLab Solution, such Personal Information will be used only for the specific purposes outlined below, unless otherwise required by law. Additionally, in some circumstances, it may be necessary to process the Personal Information in conjunction with some Technical Information for SenseLab's Solutions to properly function. In any such scenarios, the combined data is considered Personal Information and protected accordingly.

We never combine, analyze or enrich the Personal Information and Technical Information we process with additional information with the goal of identifying the End Users.

We never track you or your online activities across apps and websites or over time, we do not rely on persistent technologies such as third-party cookies and we never create profiles or audience groups to target individuals.

  1. Categories of Technical Information collected and used to power the SenseLab Solutions: