Privacy Policy

Last Updated: March, 2022

Choozle, Inc. (“Choozle,” “we,” “our,” “us” or “company”) is an advertising services platform, enabling our corporate customers to reach relevant advertising audiences, and accurately measure advertising performance. We are committed to respecting the privacy and security of the information we collect directly from, or on behalf of, our corporate customers. The following privacy policy describes the information we collect and how we use it. By using this website (“Site,” “Platform,” “Website”) or the service offered through our Site or any mobile application (the “Service”), you consent to our Privacy Policy.

In addition to our corporate website privacy policy, we have added privacy information about our Advertising Services Platform (“Platform”) which you can skip to by [clicking here].

If you visited a website where a Choozle cookie has been referenced and would like to opt-out of relevant advertising from Choozle, [click here]

Quick links – Advertising Services

ADVERTISING SERVICES PLATFORM PRIVACY NOTICE AND OPT-OUT INFORMATION
INFORMATION WE COLLECT THROUGH OUR ADVERTISING SERVICES PLATFORM
HOW OUR ADVERTISING SERVICES USE COLLECTED INFORMATION
INFORMATION SHARING
YOUR RIGHTS AND CHOICES
HOW TO OPT OUT OF CHOOZLE ADVERTISING PLATFORM SERVICES

INFORMATION WE COLLECT
We gather information about how visitors use our Site as well as information from interested or current customers in order to provide our Services.

The following are the types of information we collect:

Information you give us: We receive the information you provide to us when you register for, or otherwise use, the Site such as your name, email address, business name, title, business URL, business industry, business type, phone number, address, credit card information and any feedback, questions, or recommendations you provide. If you provide information directly to us in other ways, such as by sending us an email or filling out a form, we may retain that information and add it with the other information we have collected from you. We may also collect information from you that is necessary for our legitimate interests, which will be disclosed to you at the time of collection. Choozle will use this information for the purposes of which it was collected.
Information from third parties: We may receive information about you from other sources, such from referrals, third-party sites or data services, or services that you link your Choozle account with, or otherwise. We may add this information to the information we have already collected from you.
Automatically collected information: To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) may collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, precise location data with GPS or lat/log, or a date and time stamp for your visit. We also use Cookies (as defined below) and navigational data to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Like most Internet services, we automatically gather this information and store it in log files each time you visit our Site or access your account on our network. We also could use data from mobile applications, including advertising IDs and mobile device IDs, to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Mobile advertising IDs or Mobile Device IDs are a unique identifier which can be used to identify a mobile device. Mobile applications and networks assign unique identifiers for mobile app developers can identify who is using their mobile apps as well as for advertising purposes.

HOW WE USED COLLECTED INFORMATION
By registering for our products and services, or engaging with our brand, you provide us consent to collect and use your personal information for the following purposes:

To operate and improve our Sites;
To fulfill your requests for certain products or services;
To provide you with content and information relevant to your interests in our product and services to facilitate and enhance your use of the platform;
To better understand your needs and provide you with more customized service;
To communicate with you about the Sites or our products and services;
To respond to any questions or concerns that you may have;
For market research, project planning, troubleshooting problems, detecting and protecting against errors, fraud, or other criminal activity;
For advertising and marketing purposes.

We may create anonymous or aggregate data from the information we collect. We may use that data for our own purposes or disclose it to third parties at our own discretion.

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INFORMATION SHARING
We may share collected information under the following situations;

To suppliers, service providers or contractors that provide services to us and are contractually bound to safeguard your personal information. These services include messaging services, credit card processors, website hosting and analytics. These recipients are required by contract to keep confidential the information received on our behalf, and may not use it for any purpose other than to carry out the services they are performing for us;
With advertising services to assist Choozle with our own corporate advertising efforts (see Your Rights and Choices below for more information);
To third parties in connection with any merger, acquisition, reorganization, change in capital structure or sale of all or substantially all of the assets of Choozle;
When we have a good faith belief that disclosure is necessary to comply with the law, protect or defend our rights or the rights of other users of our Sites or products or services, or act in an emergency to protect someone’s safety; or
Otherwise with your express consent.

Choozle confirms with all third-parties to ensure the data is managed in a lawful manner.

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YOUR RIGHTS AND CHOICES
We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us or would like to update or change your personal information or preferences, follow the instructions below to review, modify or delete your personal information.

To update or modify the information you have provided during registration, please log in and update your personal settings;
To unsubscribe from a promotional email, please follow the instructions or unsubscribe links available in any email you receive. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, or to ask you to rate a product you purchased;
You may request that your registration information be deleted by contacting us at privacy@choozle.com. However, we may maintain limited information about your sales transactions or service inquiries for legal, tax or necessary record keeping purposes;

Choozle also uses our own cookies, as well as cookies implemented by advertising services to assist Choozle with our own corporate advertising efforts. We may allow certain third party advertising services to collect data about your Choozle website viewing behavior and combine this data with information collected from other websites over time for purposes that include interest-based advertising. You can opt-out of these advertising efforts by visiting;

Advertising Industry Opt-Out Websites where Choozle is referenced:

The Network Advertising Initiative opt-out at www.optout.networkadvertising.org

The Digital Advertising Alliance (DAA) opt-out at www.optout.aboutads.info

The IAB Europe’s industry opt-out at www.youronlinechoices.eu

Choozle’s website advertising partners:

Facebook

Google

The Trade Desk

Choozle’s website analytics partners:

Hubspot

Matomo

Google

In addition, you can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser. We currently do not respond to browser-based “do not track” signals.
Links to Other Websites: The Site may contain links, content, and advertisements from third parties. Such links, content, and advertisements are not endorsements, authorizations or representations of our affiliation with that third party. We are not responsible for the privacy practices or the content of third parties, and we encourage you to carefully review the privacy policy of any website you visit.

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SECURITY AND DATA RETENTION
We have implemented commercially reasonable security measures, including physical, electronic, and administrative safeguards, to prevent unauthorized access to, loss, misuse, or alteration of the information collected through our Websites. We take reasonable steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We make no assurances in this policy about our ability to prevent such loss, misuse, to you or to any third-party arising out of any such loss, misuse, or alteration. If you have any questions about the security of our Sites you can contact us using the information provided below.

Retention: We retain the information you provide to us for as long as your account is active or as needed to provide you services or perform the purposes for which it was supplied. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We retain the automatically collected data from our Websites for up to 12 months. At any point up to the end of 12 months the data is de-identified or aggregated and stored for up to 3 additional years.

We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access. When updating or deleting your information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable laws.

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EU AND OTHER INTERNATIONAL VISITORS
Choozle is a global company headquartered in the United States. If you access the Platform or any other Sites managed by Choozle, be aware that your information may be transferred to, stored, and processed in the United States. We transfer personal information from the EU, UK or Switzerland to the US by implementing the Standard Contractual Clauses adopted by the European Commission.

We commit to resolve complaints about our collection or use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our use of your personal datashould first contact us at privacy@choozle.com. If Choozle does not resolve your complaint, you may submit your complaint to your local data protection authority.

As it relates to personal data collected on this site for Residents of the European Union, Switzerland or United Kingdom, you are granted:

(a)the right to access, modify or delete your personal data;

(b)the right to restrict or object to certain processing activities,

(c)the right to withdraw consent.

If you are an EU, Swiss or UK resident you may request access to any personally identifiable data that is collected through the Choozle Site or Services by contacting us at privacy@choozle.com.

We process personal information under the legal basis of performance of contract, consent and legitimate interest. Where any processing of personal information is solely dependent upon your consent, you have the right to withdraw such consent at any time. The provision of personal information by you will be for contractual, marketing, analytical purposes, or other purposes as referred to in this Policy. When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. Residents of the European Economic Area (EEA), in conjunction with the General Data Protection Regulation (GDPR), may opt out of our cookie-based marketing efforts by using the IAB Europe’s industry opt-out at www.youronlinechoices.eu. Additional specific requests of data collection, management or use may be directed to us at privacy@choozle.com.

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CALIFORNIA PRIVACY STATEMENT
The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information including:

(a)The right to know about the personal information a business collects about them and how it is used and shared;

(b)The right to delete personal information collected from them (with some exceptions);

(c)The right to opt-out of the sale of their personal information. In the prior year, Choozle has not engaged in any activities that would be considered a ‘sale’ of your personal information as defined by the CCPA. Even so, we advise you to review the choices we provide in this policy related to the use of advertising cookies by third party services; and

(d)The right to non-discrimination for exercising their CCPA rights.

Please submit your requests to privacy@choozle.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request and include the name of the Site with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

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CHANGES TO OUR POLICY
We may revise this policy at any time. Any changes and/or updates to the policy will be updated directly on this page. Material changes to this policy will be enacted on a going-forward basis.

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CONTACT US
We welcome your questions, comments, and concerns about privacy. Please contact us by mail or email at:
Choozle, Inc. 3513 Brighton Blvd #510, Denver, CO 80216
privacy@choozle.com

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ADVERTISING SERVICES PLATFORM PRIVACY NOTICE AND OPT-OUT INFORMATION
Choozle provides a digital advertising software platform that leverages detailed consumer data to power programmatic advertising campaigns across display, video, mobile, audio, connected tv, digital out-of-home, and other mediums. Our service allows our clients to collect information about their current or potential customers using cookies, pixel tags, web beacons, web bugs, televisions or OTT devices, and other collection technologies. While we do not collect this information on our site, we want you to be aware of how our services can be used to collect your information using publically available data and other collection technologies.

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INFORMATION WE COLLECT THROUGH OUR ADVERTISING SERVICES PLATFORM
Information collected through our service: We and our clients collect, organize, and use information reflecting your interactions with a variety of websites, media types and social networks. This information may include items such as;

the date and time you visited a website;
your browser information;
your IP address
your precise location data (with mobile operating system consent);
your TV/CTV/OTT viewing behavior;
your browsing behavior;
your age and gender;
any interests you express or imply at social networking sites or other websites you visit.

Choozle or its clients may recognize your computer over time by setting a unique browser cookie or receive a mobile advertising or device ID from your operating system, which your browser or operating system relays to our servers when you visit websites or apps that are affiliated with our partners or clients. We and our clients may also supplement the information we collect with additional information we obtain from other companies, which may include information derived from personal information prior to its use. We analyze the information we collect or obtain from third parties and organize it into pseudonymous user profiles, groups, and audiences, based on factors such as age, gender, geography, interests, offline and online actions.

The behavioral categories we use to customize the ads you may see or for related purposes do not use personally identifiable information (PII) that directly identifies you such as your name, address, e-mail address, phone number. Our technology and services are designed to limit our use of consumer data to pseudonymous or non-personal information.

Information provided by clients or third parties: Our clients and/or third parties may provide us with various data sets that typically reside within their customer relationship management databases, which may include;

(a)Contact information such as names, emails, addresses, or phone numbers.

(b)Location information, such as zip code or the approximate geographic area derived from your IP address or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

(c)Pseudonymous matched or linked data that enables our clients to match users across channels. The matched or linked data comes from third party data providers, brands, and websites with the rights to share consumer data for marketing purposes. We combine and measure these data sets against each other to ensure a high level of accuracy.

Please note that we license Choozle to third parties, such as website publishers, advertising agencies and marketers. A third-party licensee using Choozle may elect to collect, manage, and use other types of data through Choozle, which may include personal information (where permissible). Please consult the privacy policies of the websites you visit to become familiar with their privacy practices.

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HOW OUR ADVERTISING SERVICES USE COLLECTED INFORMATION
We and our clients and partners design and deliver customized advertising campaigns or other relevant content across digital channels. We and our clients may also use this data for related purposes such as to conduct research regarding the results of our online advertising campaigns or to better understand the interests or activities of website visitors.

As noted, we primarily use cookies and mobile advertising identifiers to facilitate relevant ads. In addition, we may work with match partner websites to send us unique identifiers that have been de-identified from an email address or other personal information using a hashing algorithm. We then search our database of client data to determine whether any of our clients is requesting to match data for that particular pseudonymous identifier. If a match occurs, we attempt to associate a cookie with that pseudonymous data and any other information we have matched about the identifier in order to serve the individual with relevant messages or advertisements.

We may also use this data for measurement purposes such as understanding how digital advertising impacts purchasing on their Site or other sales channels.

We may also help clients create an ‘identity graph’ by “matching” or “mapping” users together that they have already “seen” across multiple web and mobile platforms, on a pseudonymous basis. This identity graph may then be used to enable cross-platform or cross-device relevant advertising to the same, or similar, individuals.

This collected data may be used for personalized Advertising or Ad Delivery and Reporting which is further defined under the NAI’s Viewed Content Advertising Guidance. As required under the NAI Code, the Choozle discloses standard interest segments that are based on health-related information or interests and political information or interests that it makes available in the Platform where permitted by law and self-regulatory rules. This information is used in the personalization of advertising efforts. Choozle confirms that any data used or collected by Choozle and our partners is obtained from responsible sources that provide users with appropriate levels of notice and choice.

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INFORMATION SHARING
As noted below in ‘Your Rights and Choices’, Choozle may share information about your visits to a website with numerous third party advertising services, including social media platforms. Some of these services are listed below, and you can opt-out of data sharing and their associated data use at any time. In addition to the services below, we may also work with various services to deliver relevant ads, which may include sharing information with various ad networks, ad delivery services, ad verification services, or ad exchanges . You may opt-out of many of these services through the industry-wide opt-out choices below.

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YOUR RIGHTS AND CHOICES
As part of Choozle’s commitment to respect privacy concerns and implement industry-recognized standards, Choozle complies with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising, which are designed to inform consumers about data collection and advertising practices across multiple websites and to provide consumers the ability to opt-out.

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HOW TO OPT OUT OF CHOOZLE ADVERTISING PLATFORM SERVICES
If you would like to opt-out of Choozle’s advertising services, or services associated with our advertising partners, you may visit:

The Network Advertising Initiative opt-out at www.optout.networkadvertising.org
The Digital Advertising Alliance (DAA)’s YourAdChoice opt-out at http://optout.aboutads.info
For those in Europe, you can opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu
The Trade Desk opt out at https://www.adsrvr.org
The Liveramp opt out at https://liveramp.com/opt_out/
The Oracle opt out at https://www.oracle.com/legal/privacy/privacy-choices.html
The Amazon Ads opt out at https://www.amazon.com/adprefs

Note that after choosing to opt-out, if you use a different computer or a different browser, or if you delete or block browser cookies, you may need to repeat the opt-out steps. Most Web browsers also enable you to block browser cookies. You can refer to your web browser’s documentation to get more information on how to block or delete cookies directly through your browser settings.

You can also configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser.

In addition, we provide you links where you can opt-out with your mobile ID by specific companies as this is handled separately from web-based browsers. This opt-out process will need to be done on your mobile device as it is unique to your device.

You can review the process on mobile ID opt-out via Network Advertising Initiative here: https://www.networkadvertising.org/mobile-choice

You can review the process on mobile app opt-out via the Digital Advertising Alliance (DAA) here: www.youradchoices.com/appchoices

In addition, we provide you links where you can opt-out of connected TV advertising as this is handled separately from web-based browsers. This opt-out process will need to be done on your connected tv device as it is unique to your device.

You can review the process on connected tv opt-out via Network Advertising Initiative here: https://www.networkadvertising.org/internet-connected-tv-choices/

To learn more about our involvement with and adherence to industry standards, please contact us at privacy@choozle.com.

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Effective date March 10, 2022

Privacy Policy

Quick links – Website

Quick links – Advertising Services