CCPA / CPRA Compliance

1. Overview

This page describes how IMC, Inc. and its affiliates ("IMC," "we," "us," or "our") comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), and other applicable U.S. state privacy laws. This page serves as our California Notice at Collection and supplements our Privacy Policy.

The CCPA grants California residents ("consumers") specific rights regarding their personal information and imposes obligations on businesses that collect, use, or disclose personal information of California residents. IMC is committed to honoring these rights and providing transparency about our data practices.

2. Scope and Applicability

This page applies to personal information that IMC collects from California residents in their capacity as consumers, as defined by the CCPA. It covers personal information collected through our websites, advertising technology platform, and in the course of our business operations. This page does not apply to: (a) personal information collected from individuals acting in their capacity as employees, job applicants, or contractors of IMC (which is subject to separate notices); (b) personal information collected in business-to-business transactions to the extent exempted by the CCPA; or (c) information that is not "personal information" as defined by the CCPA, including publicly available information, de-identified information, and aggregate consumer information.

3. Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

4. Sources of Personal Information

We collect personal information from the following categories of sources:

• Directly from you (e.g., when you create an account, contact us, or submit a form);
• Automatically from your device (e.g., through cookies and similar technologies when you visit our websites or interact with digital properties using our platform);
• From our clients (publishers and media buyers) who use our advertising technology;
• From third-party data partners, identity providers, and verification services;
• From publicly available sources.

5. Business and Commercial Purposes

We collect and use personal information for the following business and commercial purposes:

• Providing, operating, and improving our advertising technology services;
• Serving, delivering, targeting, and personalizing advertisements;
• Measuring advertising effectiveness, attribution, and campaign analytics;
• Detecting and preventing fraud, invalid traffic, and security threats;
• Processing transactions and managing client accounts;
• Communicating with you about our services, events, and marketing;
• Performing internal research, analytics, and product development;
• Complying with legal obligations and enforcing our agreements;
• Auditing related to counting ad impressions and verifying positioning and quality of ad impressions;
• Short-term, transient use, including non-personalized advertising;
• Maintaining the quality and safety of our services and verifying and maintaining the quality of our services.

6. Disclosure, Sale, and Sharing of Personal Information

As described in our Privacy Policy, we disclose personal information to various categories of recipients in connection with our advertising technology services. Under the CCPA, some of these disclosures may constitute "sales" or "sharing" of personal information:

We also disclose personal information to service providers and contractors who process data on our behalf under written contracts that restrict their use of the data to the services they provide to us. These disclosures are not considered "sales" or "sharing" under the CCPA.

7. Your California Privacy Rights

As a California resident, you have the following rights under the CCPA:

• Right to Know / Right to Access: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclosed, sold, or shared it.
• Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (e.g., where retention is necessary to complete a transaction, detect security incidents, comply with a legal obligation, or exercise free speech).
• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing.
• Right to Opt Out of Sale/Sharing: You have the right to direct us to not sell or share your personal information. You may exercise this right by contacting us at privacy@imc.ad or by using a legally recognized universal opt-out mechanism such as the Global Privacy Control (GPC).
• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use and disclosure of your sensitive personal information to uses that are necessary to perform our services or provide goods, or as otherwise permitted by the CCPA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge you different prices, provide a different level or quality of service, or suggest that you will receive a different price or level of service.

8. How to Exercise Your Rights

To exercise your rights under the CCPA, you may:

• Email us at privacy@imc.ad with the subject line "CCPA Request";
• Submit a request through our contact page;
• Write to us at: IMC, Inc., Attn: Privacy Team, 100 West Commons Blvd, New Castle, DE 19720, United States.

We will verify your identity before processing your request. For requests to know or delete, we will ask you to provide information that allows us to reasonably verify that you are the person about whom we collected personal information (or an authorized representative). The verification process may vary depending on how you submit your request and the type of information involved. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

You may designate an authorized agent to make a request on your behalf. If you use an authorized agent, we may require: (a) signed written permission from you authorizing the agent; (b) verification of the agent's identity; and (c) direct confirmation from you that you authorized the agent to act on your behalf.

9. Sensitive Personal Information

We may collect precise geolocation data (which is considered "sensitive personal information" under the CCPA) only where the publisher's digital property has enabled location services and the end user has granted permission. We use precise geolocation data only for the purpose of delivering location-based advertising and deriving regions for ad performance reporting. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA, and we do not use sensitive personal information to infer characteristics about consumers.

10. Retention of Personal Information

We retain each category of personal information for no longer than is reasonably necessary for the disclosed purpose of collection. For specific retention periods, please see Section 15 of our Privacy Policy.

11. Financial Incentives

We do not offer financial incentives, price differences, or service differences in exchange for the retention or sale of personal information. If we offer any such programs in the future, we will provide a separate notice describing the material terms and how to opt in or out.

12. Minors

We do not knowingly sell or share the personal information of consumers under the age of 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. If we learn that we have collected personal information from a minor under 16 without appropriate consent, we will take steps to delete that information.

13. Annual Request Metrics

In accordance with the CCPA, we publish annual metrics regarding consumer requests received during the previous calendar year. These metrics will be updated annually and will include the number of requests to know, requests to delete, requests to correct, and requests to opt out that we received, complied with (in whole or in part), and denied, along with the median and mean number of days to respond.

14. Other U.S. State Privacy Laws

In addition to the CCPA, several other U.S. states have enacted comprehensive consumer privacy laws, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. If you are a resident of one of these states, you may have similar rights to those described above, including the right to access, delete, and correct your personal information, and the right to opt out of targeted advertising, the sale of personal information, and profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise your rights under any applicable state privacy law, please contact us using the methods described in Section 8 above. If we deny your request, you may have the right to appeal our decision by contacting us at privacy@imc.ad. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

15. Contact Us

For questions about this CCPA Compliance page or to exercise your California privacy rights: