INTRODUCTORY NOTES

B.O.W. - BUSINESS ON WEB, LLC dba YourBow (collectively, “ YourBow“, “we”, “us” or “our”) is a company formed under the laws of California, United States.

“You” or “User” refers to a person who visits and otherwise interacts with this website and with the websites of our clients and partners.

The following privacy policy (“Privacy Policy”) describes the our data protection practices when you visit or use our website, https://www.yourbow.com/(“YourBow Website“) and any of the YourBow clients’ websites, i.e. Publisher Websites that YourBow provides its advertising services or its technology to, as well as mobile-optimized version of such websites, apps, TVs, etc, (“Publisher Websites“), and any of the advertisers' websites that YourBow cooperates with, i.e. Partner Websites (“Partner Websites“), all collectively referred to as “ Websites“.

1.INFORMATION WE COLLECT

a.Information you give to us

·   We collect information you provide directly and willingly to us, such as when you contact us by “contact us” page, email or otherwise, and provide your name, phone number, email address, etc.

b.Information we collect automatically

·   Automatically collected information are information sent to us by device you use when you are visiting Websites. Please see what that information may include in the section “Information collected from third parties“.

c.Automatically Collected Information through use of Publisher or Partner Websites.

YourBow does not collect any personally identifiable information, except for the information user provides through direct input on the website.

As we cooperate with our partners and then provide technology and support for serving advertisements to our clients i.e. publishers, we may automatically or passively collect your information, through a variety of methods and technologies (including cookies, browsing history, web beacons and interactions with the website or app), when you visit Publisher or Partner Website and react to those ads. Information is initially collected by our clients/publishers partners/advertisers, and we have no direct connection with the people whose personal information is processed. This practice allows us and our partners to personalize advertising campaigns and provide advertisements that are more relevant to you, based on your interests and online activity. Hence, we process information on behalf and direction of our clients/publishers and partners/advertisers.

Automatically collected information are information sent to us by device you use when you are visiting Publisher or Partner Websites. This information may include:

(i) data from analytics tool, Google Analytics, which provides aggregated data on website traffic, user demographics, and user behavior.

(ii) IP address of the user's device, which can be used to determine the user's approximate location and internet service provider;

(iii) approximate geographic location of the user's device, often determined based on the user's IP address or through explicit location services if the user consents.

(iv) device information including device type and model, manufacturer, operating system type and version;

(v) user's web browser and session Information - details about the user's session on the website, such as when they visited, how long they stayed, and which pages they viewed;

(vi) information about how the user arrived at the website, such as through a search engine, a social media link, or a direct URL entry;

(vii)      data on which links, ads or buttons the user clicks on and other user interaction data, such as mouse movements, scrolling behavior, hover actions, the number of times user has seen the ad and information about interaction with the ad;

By consenting to Publisher or Partner Websites' cookie-related questions and continuing to use such services, the user is considered to have agreed to our collection, use, and disclosure of the information listed above. (unless user withdrew the consent).

With user’s consent, and for the purposes to personalize user experience and make the content or ads user sees more relevant to where they are and to offer targeted advertising based on current geographic location, we and our partners may collect approximate geolocation information. By consenting to Publisher or Partner Websites’s cookies-related questions and continuing to use such services, user agrees to our collection, use and disclosure of user’s geolocation information as described.

Publisher or Partner Websites allows users to choose between personalized and non-personalized ads. Data collected on the Publisher or or Partner Website will depend on those choices. As we do not control the data privacy or protection policies of our clients/publishers, partners and third parties, we are not responsible for their privacy practices. Please refer to Publisher or Partner Websites’ privacy policies for further details.

d.Information collected from third parties

We may also obtain user information from trusted sources, whereby this information is used to either validate or enhance the data they automatically collect. Validating could involve comparing and confirming certain details like a user's location, age, lifestyle information, or other demographic information, while supplementing means providing additional data that was not automatically collected.

As well as being used for internal business analysis or other business purposes, we use this methods to help us maintain the accuracy of the information we collect, tailor our communications to you so you can learn about products, services, and offers that are likely to be of interest to you. Trusted sources help publishers, advertisers and serving companies to identify and reach specific audiences that are likely to be interested in their products or services. Those trusted sources have privacy policies that differ from this Privacy Policy.

2. HOW USER’S INFORMATION IS COLLECTED

The collection of personal information can occur directly or indirectly, and the ability to identify individual users also depends on the specific practices of the pablisher, advertiser, ad serving company and the website.

1. Direct Collection of Personal Information:
• We directly collect personal information only when users of the YourBow website provide it voluntarily. As a advertising company that provides technology and support for serving ads to other websites/our clients/publishers, we do not directly collect personal information when users interact with those ads. Direct Collection is operated by the Publisher Websites or Partner Websites.
2. Indirect Collection of Information:
• We do collect information indirectly, through Publisher Websites and Partner Websites, using techniques like cookies, tracking pixels, and device fingerprinting.

-Cookies: When you visit a website, cookies can be placed on your device. These are small files that store data about your online behavior. They may record your browsing history, the pages you visit, the time spent on each page, and your interactions with ads.

-Tracking Pixels: These are tiny, invisible images embedded in web pages. They allow us to track your actions, such as when you visit a webpage, or interact with content.

-Device Fingerprinting: This technique involves gathering information about your device, like its operating system, screen resolution, and browser configuration. This information can be used to create a unique "fingerprint" for your device, which can be used for tracking.

·Identification of Individuals - non-personally identifiable information

-Despite collection of data, and building user segments based on the collected data, we cannot identify specific individuals behing this data.

-However, in some cases, when users provide personal information directly (e.g., signing up for a newsletter or making a purchase), it's possible to link their online behavior with their real identity.

-Sometimes, if a user logs into a website using a social media account or other identifiable credentials, it becomes easier to connect their online activities to their real-world identity.

3. CAPACITY

a. Direct Collection of Personal Information:

When you access, browse, or use the YourBow Website, for the purposes of data protection laws, YourBow is the data controller.

b.Indirect Collection of Personal Information:

On the other side, since YourBow provides technology and support for serving ads, which includes but is not limited to programming, tracking, recording, managing, publishing of advertisements on Publisher Websites (collectively, “Services”), provided that ’’non-personally identifiable information’’ is not applicable, we may collect personal information on behalf of our clients, i.e. Publishers, which means that in terms of data protection laws, regarding these purposes, we act as data processor.

If we collect personally identifiable information, we do it through tracking technologies like cookies and pixels on behalf of a Publisher Website (the data controller) also to serve targeted ads, whereby we are acting as data processors. The website owner, in this scenario, determines the purposes and means of data processing, and we process the data as instructed.

If you have questions or concerns about an ad on a Publisher Website or have a question about that website’s data collection, please refer to that website’s privacy policy.

4. ANONYMIZED DATA - NON-PERSONALLY IDENTIFIABLE INFORMATION (’’non-PII’’)

In the process of Indirect Collection of Information, most commonly personal information is anonymized in a way that it can no longer be linked to an individual and we are not able to identify individuals. We may collect, use, store and process this Anonymous Data for any purpose permitted under the law and disclose Anonymous Data to third parties at our sole discretion, without further notice to you.

However, we still follow best practices in data handling and take precautions whenever there is a chance of re-identifying individuals based on anonymized data.

5.HOW WE USE YOUR INFORMATION

As a matter of our legitimate interests and to perform our contract with publishers, we collect information for purposes, as follows:

    I. Provision of Ad Services and Customizing Advertising. As part of our business, we use information to personalize advertising campaigns and to provide advertisements that are more relevant to you, based on your interests and online activity on Publisher Website. This also implies Interest-Based Advertising where data is used to categorize users into interest segments, allowing advertisers to better target ads based on these interests. To better customize our ads, we also obtain additional information from third parties to supplement the information we collect.

II. Optimization and Testing. Information may be used in order to research and conduct troubleshooting, analysis and testing of how ads operate. Then we can optimize overall ad performance.

  III. Frequency Capping. We use Information to manage the frequency of ad impressions and ensure a balanced user experience and to improve provision of our services. For those purposes we monitor how often users have seen a particular ad and how many times user interacted with the ad.

IV. Ad Performance Analysis and Reporting. Information is used to measure the effectiveness of their campaigns by tracking user interactions and conversion rates. We then use those analyses and reporting to improve and develop our products and services.

V. Fraud Detection: Information is used to detect and prevent fraudulent activity in advertising, such as click fraud and ad bot traffic.

VI. Geotargeting, Demographic Targeting. For promoting local businesses and events, we use approximate location data for geotargeting where ads are tailored to a user's current geographic location. Demographic targeting focuses on specific groups of people based on characteristics like age, gender, etc. This helps us tailor messages and products to appeal to a more relevant audience, making marketing efforts more effective.

VII.     Cross-Device Tracking: We may link the online activities and behaviours of a single user across multiple devices, such as smartphones, tablets, desktop computers, and more, through various means like collecting unique identifiers, IP addresses and cookies. We may also cooperate with other entities that use these methods. Then we can use it for analytical purposes, optimization and to deliver a personalized user experience

 VIII. Security: To ensure the safety and security of users, our services, and business operations;

  IX. Legal obligations: We may retain and use personal information to the extent necessary to comply with our legal obligations and requirements, to enforce any applicable terms and conditions, to resolve disputes, and to protect or defend our services, our rights, and the rights of our clients, users, or others. In such a case, we will store user’s information in an aggregated and anonymized format.

6.TO WHOM WE SHARE OR DISCLOSE YOUR INFORMATION

We may share and disclose personal information with entities listed below:

·   >With our clients/publishers, on the basis of user’s consent, and in our legitimate interests to run our business.

As an essential part of our provision of services, we may share and disclose your information with our clients who use our services and technology, including information about your activity on their website. All transferees are covered by service agreements with our clients.

·   >With Ad Servers, Advertising Partners and service providers, on the basis of user’s consent and in our legitimate interests to run our business. >

We may share or disclose your information with Ad Servers, Advertising Partners and service providers that provide certain technology, tools and data analytics to us needed for our operations, thus assisting us in better provision of our services. Those providers may also include, without limitation Ad Networks, Data Management Platforms, Supply-Side Platforms, Content Delivery Networks, Fraud Prevention vendors. All transferees are covered by service agreements.

·   >With auditors, law firms, or accounting firms, in our legitimate interests or as required by law.

We can share or disclose your information with said professional advisors, whereby all transferees are covered by service agreements.

·   >With our affiliates, employees and independent contractors/entrepreneurs, in our legitimate interests.

These parties are considered a part of YourBow operating team, with whom we may share or disclose your information with. All transferees are covered by service agreements. When we disclose information to our employees ot to independent contractors, we only provide them with the information that they need to perform their specific function.

·   >With regulators and authorities, in our legitimate interests or as required by law.

We may share or disclose your information to comply with our legal obligations and requirements, to enforce any applicable terms and conditions, to resolve disputes, and to protect or defend our services, our rights, and the rights of our clients, users, or others.

·   >With third parties with user’s permission.

We may share or disclose your information with third parties to whom you asked us to send your information.

·   >With potential buyer, seller, new owner, or other pertinent third party, in our legitimate interests.

We can also share or disclose your information as part of the negotiation process or in connection with a corporate control change, such as a corporate reorganization, share sale, purchase or merger, asset transfer, bankruptcy, etc.

>Since the details about our clients/publishers and partners/advertisers and service providers constitute our confidential information, protected by a related confidentiality obligation, if you have questions about specifically with whom we share or disclose your information, do not hesitate to contact us and we will provide you with all necessary details.

7. HOW LONG USER’S PERSONAL INFORMATION IS STORED?

Personal information is stored for as long as is necessary to ensure the purpose for which the personal data was collected, namely:

• where there is a legally defined storage period, we store the information for that period and delete it permanently, within an additional period of one year;

• information processed on the basis of consent is stored as long as there is a consent, and in case of withdrawal of consent, if there is no other suitable legal basis for processing, it is deleted in the shortest reasonable time;

• for information processed on the basis of legitimate interest, we keep it as long as the legitimate interest exists, according to the industry-specific standards and practices. If the legitimate interest no longer exists or the data is no longer needed for its original purpose, it would be deleted in the shortest reasonable time, and at maximum within a period of 2 years from the termination of the legitimate interest.

8. WHERE WE PROCESSYOUR INFORMATION

You acknowledge that rersonal information you provide to us will be transferred to, and processed in California, the United States of America. Your personal information is also processed by staff, independent contractors/entrepreneurs, third party agencies, service providers operating outside the the United States of America, European Economic Area (“EEA”) and the United Kingdom (“UK”). In the event of data transferring to other countries, we will comply with applicable legal requirements that ensure that your data is adequately protected.

a.If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:

the country to which the personal data will be transferred has been granted a European Commission adequacy decision;

your identity cannot be determined from the data since it is anonymized;

·   we have implemented suitable protective measures for the data transfer. For instance, we have established EU standard contractual clauses and imposed additional precautions with the recipient, whereby they might include practices like pseudonymization.

9.LEGAL GROUNDS FOR OF PROCESSING

If you are a user located in the European Economic Area, legal bases for processing data under the General Data Protection Regulation (“GDPR”) are as follows:

·Legitimate Interest - encompasses reasonable interests in effectively managing and conducting our business activities to achieve our business purposes, such as providing high-quality products and services, ensuring operational efficiency, and maintaining a secure and satisfactory customer experience. In no case will we use your personal information in ways that are in conflict with your interests (unless we have your consent or unless we are otherwise required or permitted to by law).

·A consent - is when you agree to a certain use of your personal data.

·When it is required by law means when it is necessary to fulfill obligations imposed by the law or by regulatory authorities.

·Vital interest comes into play in emergency situations whereby this basis is reserved for exceptional circumstances where immediate action is required to prevent harm.

10.  EUROPEAN PRIVACY RIGHTS

• Right of Access: You have the right to obtain confirmation of whether we process your personal data and, if so, access to the details of that processing, including how it's used and shared.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format. You can also request that we transfer this data to a third party, subject to certain exceptions.
• Right to Rectification: You can request corrections to any inaccuracies in your personal data held by us, ensuring that your information is up to date and accurate.
• Right to Erasure (Right to Be Forgotten): In specific circumstances, you have the right to request the deletion of your personal data.
• Right to Restriction of Processing: You can request the temporary restriction of how we process your personal data, allowing us to store it but not use it for certain purposes, in certain situations.
• Right to Object: You have the right to object to our processing of your personal data, typically for reasons related to your specific situation.

·   Right to Object: When personal data is being processed for the purposes of direct marketing, the data subject has the right to object to the processing of their personal data, including any profiling associated with such direct marketing, at any time.

• Right to Withdraw Consent: If we rely on your consent for processing your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, you can contact us at dpo@yourbow.com. Requests to exercise these rights will be responded to without undue delay and within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests, whereby we will inform you of any such extension within one month of receipt of the request. We may request the provision of additional information if it is necessary to confirm your identity.Top of Form



Please be aware that some of these rights are conditional, applying only in specific situations, and their exercise may be subject to legal restrictions. For instance, if fulfilling your request would have a negative impact on the rights of others, compromise our trade secrets or intellectual property, or conflict with compelling public interests, or if legal mandates necessitate the retention of your personal information, certain rights may be limited.

Sometimes, we will need to keep processing your information for our legitimate interests or to comply with a legal obligation.

11.  CALIFORNIA RESIDENTS

Under the California Consumer Privacy Act (CCPA), as amended and expanded by the California Privacy Rights Act (CPRA), users have the following privacy rights:

·     Right to Know

a. You have the right to request information about the personal information collected, used, shared, sold or disclosed by us, as well as details about data practices, which includes:

-      the categories of personal information collected;

-      specific pieces of personal information collected;

-      the categories of sources from which the business collected personal information;

-      the purposes for which the business uses the personal information;

-      the categories of third parties with whom the business shares the personal information;

-      the categories of information that the business sells or discloses to third parties.

Please note that we are not required to provide the personal information to you more than twice in a 12-month period. Answering on your request is free of charge.

·     Right to Correction. 

You have the right to request that we correct inaccurate personal information that we maintain about you.

·     Right to Deletion. 

You have the right to request that we delete your personal information collected by us about you.

Please note that we are not reqired to comply with user’s request to delete personal information if maintenance of personal information is necessary to:

-Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

-Debug to identify and repair errors that impair existing intended functionality;

-Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

-Comply with the California Electronic Communications Privacy Act;

-Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

-Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

-Comply with an existing legal obligation; or

-Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. You have the right to limit our use and/or disclosure of sensitive personal information to that use/disclosure which is necessary to perform the services or provide the goods reasonably expected by an average user who requests those goods or services.

·     Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt out, which means you can request us to stop selling or sharing your personal information.

·     Right to Non-Discrimination

We cannot deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the CCPA/CPRA.

·     Authorized Agent

You can designate an Authorized Agent to act and make a request on your behalf regarding privacy rights. This makes it easier for users to exercise their privacy rights, especially when they may not have the time or expertise to navigate the process themselves. Please note that in this case, we may require more information from you, such as those for identity verification, to verify that you are the person directing the agent.

Children Less Than 16

We do not knowingly sell or share the personal information of a user less than 13 years of age. If you are under the age of 13, please do not submit any personal information through the websites, without permission of the parent or guardian. We kindly ask parent or guardian that believes the child under the age of 13 has provided personal information to us, to contact us promptly. 

We refrain from selling and shering the personal information of users under the age of 16 that we are aware of unless we obtain explicit consent, known as the "right to opt-in," from either the user aged 13 to 16 or the parent or guardian of a user under 13 years of age.

Sensitive Personal Information

We do not collect sensitive personal information from users using the websites. For instance, sensitive information includes social security number, financial account and debit card, or credit card number, precise geolocation information, genetic data, biometric information processed to identify a consumer, information about racial or ethnic origin, etc. If you elect to submit such information to us, it will be subject to this Privacy Policy.

Notice

A description concerning the categories of collected, sold, shared and disclosed personal information, along with their sources, then business or commercial purposes for collecting, selling, sharing, disclosing are identified above in section 1, section 2, section 3, section 4, section 5 and section 6 to this Privacy policy.

Exercising Your Rights

You may submit any request under the CCPA/CPRA (including Notice of Right to Opt-out of Sale/Sharing),just by emailing us at dpo@yourbow.com, without specific form. In order to exercise your rights relating the information maintained by Publisher Websites, please refer to particular publisher.

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period. We are not obligated to make a data access or data portability disclosure if we cannot confirm the identity of the person making the request as the individual about whom we collected information, or as someone duly authorized to represent that individual. This means that we will ask you for more information if it will be necessary to identify you.

Any personal information gathered from you for the purpose of identity verification in relation to your request will be exclusively utilized for verification purposes. We will provide a response to a verifiable consumer request within 45 days of receiving it. In case we need additional time (up to 90 days), we will notify you in writing, explaining the reason for the extension.

Contact us:

by email at dpo@yourbow.com

by telephone number, +1-510-870-2286

or write to us at:

B.O.W. - BUSINESS ON WEB, LLC dba YourBow

2109 Corte Ricardo

Pleasanton, CA, 94566

12.  MISCELLANEOUS TERMS

Applicable law. This Privacy policy is subject to the General Data Protection Regulation (GDPR) in the European Union, to the California Consumer Privacy Act (CCPA) and to the California Privacy Rights Act (CPRA) in the California, United States.

If there is a specific contractual relationship with us. If we provide you with any additional privacy-related notices or policies on the basis of separate agreements or terms and conditions you have signed or agreed to with YourBow, this Privacy Policy will be regarded as a complement to these additional privacy notices/policies and agreements.

Changes to this Privacy Policy. Please read this Privacy Policy carefully so that you can understand your rights in relation to personal information, and how we will collect, use and process personal information. Please check Privacy Policy regularly as we will update it from time to time, without prior notice, and in order to undertake new personal data practices or adopt new privacy policies. Updated version of this Privacy Policy will be effective immediately upon the posting.

User warning. Please do not access, browse or use Websites, our services and features therein, or otherwise provide your information to us if you do not agree with this Privacy Policy in general or any part of it. By using our services, you are explicitly consenting to our gathering, use, and processing of your personal data in accordance with this Privacy Policy. As we do not control the data privacy or protection policies of our clients/publishers, partners/advertisers and third parties, we are not responsible for their privacy practices. You acknowlidge that this Privacy Policy does not apply to, and we are not responsible for the privacy practices of third parties websites that you may access from the Publisher Website.

In case of any dispute arising out of or relating to this Privacy Policy, that cannot be satisfactorily resolved amicably and through good faith negotiations, parties will refer the dispute to a court. You hereby irrevocably consent to the personal jurisdiction of the state and federal courts located in Alameda County, California, for legal proceedings arising out of this Privacy Policy.

For you further clarification about this Privacy Policy or the privacy practices of the Websites, do not hesitate to contact us by email at dpo@yourbow.com

or by mail at:

B.O.W. - BUSINESS ON WEB, LLC dba YourBow

2109 Corte Ricardo