We Take Your Privacy Seriously - View Our Privacy Policy Vydia

Last Revised: November 26, 2024

Overview

This Vydia Privacy Policy (“Privacy Policy”) is designed to help you understand the types of personal information we at Vydia, Inc. (“Vydia”, “us”, “we”, or “our”) collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your personal information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your personal information. Personal information is typically data that identifies an individual or relates to an identifiable individual. The definition of personal information (used interchangeably with “personal data”) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. We appreciate you taking the time to read this Policy and understand our data and privacy related practices.

By continuing to use our Services, you acknowledge this Privacy Policy, and agree to our Terms and Conditions (“Terms”) If you are not comfortable with any part of this Policy or do not agree with the Terms, please immediately discontinue access or use of our Services.

We may provide additional “just-in-time” disclosures or additional information about our personal information collection, use and sharing practices. These notices may supplement this Policy, clarify our privacy practices in the circumstances described, or provide you with additional choices about how we process your personal information. Also, we may make changes to this Policy from time to time. We will notify you of any material changes to this Policy and will update the Last Revised date at the beginning of this Policy. We encourage you to look for updates and changes to this Policy when you access our Services.

You may access the specific sections of our Privacy Policy by selecting any of the sections listed below.

Applicability and Scope
Personal Information We Collect
How We Use Your Personal Information
How We Disclose Your Personal Information
Cookies and Other Tracking Technologies
Links to Third-Party Sites or Features
How We Protect Your Personal Information
Retention
Children’s Privacy
Transfer of Personal Information to Other Countries
Your Privacy Choices and Rights
Additional Disclosure to California Residents
Additional Disclosure for Data Subjects in the European Economic Area, the United Kingdom, and Switzerland
How To Contact Us

1. Applicability and Scope

This Privacy Policy applies to all personal information that we collect during any written, electronic, and oral communications online or offline when you:

interact with our websites located at
www.vydia.com, and any other websites, pages, features or content we own or operate that link to this Privacy Policy (collectively, the “Site(s)”);
as a subscriber to our service, you use our content management platform (the “Dashboard”);
use our mobile applications branded as “Vydia” (the “App(s)”);
attend one of our events or interact with us at an event; or
interact with other products or services that direct you to this Privacy Policy (collectively, including the Sites, the Dashboard and the Apps, the “Service(s)”).

Our Services include links to other websites and other content from third party businesses. Vydia does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these
third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit so you understand how your information is being processed.

2. Personal Information We Collect

Vydia collects certain personal information about you and your use of our Services. The personal information that we collect depends on your interactions with us, and the choices you make.

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal information when you voluntarily provide it to us:

Web Forms. We may collect your name, phone number, email, profession, country, states, company name, creator name or stage name, and other information about your artist profile and music catalog when you request invites to join our platform, request additional information about
our Services, or would like to get in touch with us for other matters. Personal information that you provide by web forms will be used only for such purposes as are described at the point of collection, such as to evaluate your application, send information to you or respond to your questions or
comments.
Customer Service. When you engage with our support team, we may collect your name and contact information, records, copies of your correspondence (including email addresses), and any additional information you choose to share with us. Partner Directory. When you navigate through
the “Vydia + Partner Directory” to contact service providers for labels, managers, artists, and other industry professionals, we may collect your name, company, title, email address, and phone number.
Professional Materials. We periodically offer content in the form of e-books, guides and free courses that might be useful to school professionals. In order to view these contents, we may ask you to provide your name, email, role, school information and country information.
Testimonials. Upon obtaining permission, we may post your testimonials, written, graphic or video, on our website. If you wish to update or delete your testimonial, you can contact us at [email protected].
Surveys and Contests. From time-to-time, we may invite you to participate in surveys or contests. Participation is voluntary. These surveys are organized for the purposes of our marketing efforts. When an individual participates, we request certain personal information such as
name and email address. This is necessary to ensure that responses are categorized properly and are not duplicated. Depending on the nature of the survey or contests, we also use this information to send the survey results to the participants, or, if applicable, to notify contest winners and
award prizes. We also use the information in aggregate form, for analytics purposes, to understand our market, to monitor site traffic or app usage, or to modify our offering to meet the needs or interests of visitors. If we use a third-party service provider to conduct these surveys, the
information collected by the service provider may be subject to both the service provider’s privacy policy and ours. We will provide information about the applicable privacy policies with the survey rules and will seek your explicit consent to these rules when required by law. You should read
the terms of the survey or contest to understand the extent to which the service provider is allowed to use or reuse the information collected.
Account Registration. If you wish to evaluate or purchase any of the Services we offer, including access to the Dashboard and the App, you will need to sign up for an account. As part of the registration process, we may collect your name, email address, phone number, and mailing
address.
Payment Information. We may collect your payment information when you purchase our premium feature, such as the paid storage plan, or participate in our monetization services. We rely on our third-party service providers (such as Braintree, PayPal or Tipalti) (“Payment Processors”) to process payments for such premium features and to issue you applicable share of revenue from monetization of your content. When you make a payment, the payment information is transmitted directly to the Payment Processor, and we do not have access to it, and take no responsibility for it.
Our Payment Processor will provide to us your name, mailing address, phone number, email address (if PayPal is used to process the payment), card type (i.e., Visa, Amex, etc.), the credit card’s last four digits, and your tax information (such as a W9) so we can comply with applicable legal
obligations to “know our client” (sometimes referred to as “KYC”) and other legal obligations that apply to us.
Third Party Platform Content Management. As a registered user, if you would like to use our content management services to manage your content on third party platforms and social media services (such as YouTube and Facebook) (“Third Party Platforms”), you will need to authorize
the Third Party Platform to grant us access to: your account information and profile data on the Third Party Platform; all existing and future content you have or will upload and their associated metadata, performance data, metrics, and insights; and access token to your account on Third Party
Platforms.

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as when you interact with the Sites or use the Services. We may collect the following types of information automatically
from you:

Usage Data. When you browse our Sites, we may automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access
our servers, and other diagnostic data.
Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID.
Location Information. When you use our Services, we may infer the approximate physical location and geographic regions of your device from your IP address. For information about your options in relation to sharing location information, please review the Your Choices and Rights
section below.

Information We Collect From Third Parties. Unless prohibited by applicable law, we may obtain information about you from third party sources such as public data bases, and other publicly available sources. These sources may include:

Third Party Platforms. If you use our content management services to manage your content those platforms, we may receive profile data that the Third Party Platform provides to us with your consent, in accordance with the settings that you chose on that Third Party Platform, such as the email
address you have on file with the Third Party Platform. You can edit or remove the permissions you have granted us to use information from your connected social media accounts by using the application privacy settings on your social media account. See the following for instructions on how to
change or remove third party access on each platform:
Twitter: https://help.twitter.com/en/managing-your-account/connect-or-revoke-access-to-third-party-apps
Facebook: https://www.facebook.com/help/262314300536014/
Digital Service Providers. Our registered users may request (as part of the Services) that we deliver their content to our third-party media partners and service providers (e.g., Spotify) (“Digital Service Providers”). We collect information from such Digital Service Providers about plays of your content on the Digital Service Providers’ respective services. We collect all information in each statement provided to us by each Digital Service Provider. We retain
the following information in our database: (1) Stream-count; (2) Revenue; (3) Region/country; (4) Device/source, and (5) Per stream revenue (i.e. revenue / stream-count).

The table below describes the categories of personal information we collect, disclose for a business purpose, and “share” (as the term is defined by applicable law). Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect
with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information for money. We also do not allow third parties to use your personal information for their own direct marketing purposes, but as indicated below we do share certain
information with advertising networks:

Category of Personal Information	Category of Recipients
	Disclosures for a Business Purpose	Sharing for Cross-Context Behavioral Advertising
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Social networks	Advertising networks
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.	Business partners Payment processors and financial institutions Other Service Providers	Not Shared.
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.	Affiliates or subsidiaries Business partners Other Service Providers	Not shared.
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliates or subsidiaries Business partners Data analytics providers Joint marketing partners Payment processors and financial institutions Other Service Providers Social networks	Advertising networks
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Affiliates or subsidiaries Business partners Data analytics providers Operating systems and platforms Other Service Providers Social networks	Advertising networks
Geolocation data	Other Service Providers	Not shared.
Audio, electronic, visual, thermal, olfactory, or similar information	Affiliates or subsidiaries Business partners Other Service Providers	Not shared.
Inferences drawn from any of the information listed above	Affiliates or subsidiaries Business partners Data analytics providers Other Service Providers Social networks	Advertising networks

We may aggregate or de-identify the information described above. To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal
obligations.

3. How We Use Your Personal Information

We use your personal information for the following business and commercial purposes, unless restricted by applicable law:

To Provide Our Services. We may use your personal information to provide you with our Services that you request, such as creating and maintaining user accounts, verifying a user’s identity, assisting a user that misplaces or forgets login or password information, and finalizing
purchase orders. For example, when you register for our Services, we may require your payment information to process your registration.
To Provide You with Service-Related Communications. We may use your personal information to communicate with you. We may send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information
about Privacy Policy updates, security updates, tips or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account
or the Services.
To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, ensure compliance with
education and student information protection laws, to manage risk as required under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.
To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our Terms or other legal rights,
including those arising from any contracts entered into between you and us, including for billing and collection.
To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud and abusive use of our Services, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system
security, and combat spam, malware, malicious activities or other security risks.
To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
To Provide Marketing Communication. We may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you subscribe to our marketing communications. We will occasionally send you information on products, services and
promotions. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages or contacting us via the methods specified in the “How to Contact Us” section below.
To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Site is used,
how many visitors we receive, and where they click on the Site may help us improve our existing Services and to build new Services. Please see our “Cookies and Other Similar Tracking Technologies” section for more information.
To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to more easily interact with our Services across platforms and devices.
To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

4. How We Disclose Your Personal Information

We take care to allow your personal information to be accessed only by those who need access to be able to perform their duties, and to be shared only with third parties who have a legitimate purpose for accessing it. We may disclose your personal information as described below.

With Our Service Providers. We may share your personal information with third-party service providers acting on our behalf to help us operate our Services. Service providers provide us with support services such as credit card processing, website hosting, community and feedback management,
surveys and research services, analyzing data, market consulting, and network maintenance. We strive to contractually prohibit these service providers from retaining, using, or disclosing your confidential personal information for any purpose other than performing agreed upon services for us.
Within Our Corporate Organization. We may share your personal information within our organization, including sharing with our parent company, affiliates and subsidiaries, to provide you with the Services and take actions based on your request, such as our parent company, subsidiaries, and
corporate affiliates, joint venturers, or other companies under common control with us. We may permit these entities to use your information for their own marketing purposes. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may
opt-out by emailing us at [email protected] or calling us at +1 (646) 661-2484.
During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a
corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
For Legal Compliance & Safety. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners
or other regulators; (c) exercise, establish or defend our legal rights; (d) respond to infringement notification in accordance with the process set forth in our Terms and Conditions in order to investigate and address the potential infringement, or (e) protect your, our, or others’ rights,
property or safety.
With Third Party Marketing Partners. Subject to applicable law, from time to time, we may share your personal information with selected third-party marketing partners that we believe offer products or services that may be of interest to you. In countries where such activities do not require
prior explicit consent, we may provide personal information of individuals to third party marketing companies, affiliates, advertising agencies, and data aggregation companies. These partner firms use this information to provide individuals with information on products and services that may be
of interest. In countries, such as in the European Economic Area, where such activities are restricted, we conduct these activities in accordance with applicable local laws. To learn more about your choices and rights, please review the “Your Choices and Rights” section below.
With Third Party Media Partners. If you have an account with us and elect to sign up for the distribution services feature of the Services, we may provide our third-party media partners with access to your information so that they can review your content through the Vydia publisher dashboard on
the Services. These third-party media partners will only have access to your information through the Services for purposes of evaluating your content and determining whether to publish your content.
With Your Consent. We may share your personal information with other companies if you give us permission or direct us to share your information.

5. Cookies and Other Tracking Technologies

We and third parties on our behalf, may use cookies or similar tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Sites, to help us customize your experience and better
manage content on our Sites, including to:

Analyze our web traffic using an analytics package
Identify whether you already visited our Sites
Store information about your preferences
To recognize when you return to our Site

In some countries, the law requires us to provide you with detailed information about the cookies that may be set when you visit our Site. The law may also require that we obtain your consent to the use of certain types of cookies. Please read our Cookie Policy for more details. Managing Cookies. If
you want to exercise your rights regarding personal information collected via cookies and similar tracking technologies, please see the “Your Privacy Choices and Rights” section below.

6. Links to Third-Party Sites or Features

Our Services may contain links to other third-party websites, social media tools, widgets or plug-ins for your convenience and information. We also offer features permitting you to share content with or link to third parties social media providers. To the extent any linked websites or features are
not owned, controlled by, or affiliated with Vydia, we strongly suggest that you review their own privacy notices or policies prior to visiting or using any linked third-party sites and features. When you visit a website with a social media button, your browser establishes a direct connection to
that social media provider allowing them to directly collect information about your visit. If you have an account with the social media provider, the provider may also link your visit to your account, even if you are not logged into this account. We are not responsible for the content, policies, or
the privacy practices of any third-party sites or features that are not affiliated with Vydia.

7. How We Protect Your Personal Information

We implement industry standard security measures intended to protect against the loss, misuse, and alteration of the information under our control. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Vydia cannot guarantee or warrant the
security of any information you transmit on or through the Website or the Services and you do so at your own risk. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by
law. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us
as indicated in the “How to Contact Us” section. Additionally, you must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will assist you in updating your account details.

8. Retention

We will retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Privacy Policy. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as
it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, please
contact [email protected]. Please note that, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Children’s Privacy

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 13. If you are under 13, please do not attempt to fill out our forms or send any personal information about yourself to us. If you are aged between 13 and 16 (or the applicable age
of majority) may not use the Services without involvement of a parent or guardian. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the How to Contact Us section
below. If we become aware that a child under 13 has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our systems, unless we have a legal obligation to keep it.

10. Transfer of Personal Information to Other Countries

Vydia’s business operates on a global scale. When you access or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we may transfer your personal information to the United States for further processing. We will take appropriate contractual or other steps to protect the relevant personal information in accordance
with applicable laws.

11. Your Privacy Choices and Rights

We offer all individuals, regardless of residency, certain privacy choices. Residents of some territories (such as the European Economic Area or California) are afforded various additional privacy rights under applicable law.

Your Choices

We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the “How to Contact Us” section at the end of
this Notice. Where provided by law, you may withdraw your consent previously provided to us, and we will apply your preferences going forward.

Correct or Update Your information. If you are a Registered User, you may make changes to the information you have provided in connection with your account by logging in to your account and changing the applicable information from the Dashboard. You may also contact us as
specified in the “How to Contact Us” section at the end of this Notice.
Marketing Communications. You can choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing emails, or by contacting us as specified in the “How to Contact Us” section below. Please include your name, email address and postal address if you send us your request by email or postal mail.
Text/SMS Communications. You may opt out of receiving text message communications on your mobile device by sending a text message with the word “STOP” to the short code in which you received the message. You will receive one additional text message, confirming
that your request has been received. Vydia does not charge you to unsubscribe. Depending on the terms of your mobile phone contract, you may incur charges for receiving and sending text messages on your mobile device. Vydia is not responsible for these charges. Message frequency varies per
month. Consent is not a condition of purchase. Autodialed marketing messages will be sent to the mobile number you provide at opt-in. Message and data rates may apply. For help, text HELP to the short code in which you received the message.
Location Information. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or the device manufacturer. You can
re-enable the collection of geolocation information, at any time, by turning on location services on your device.
Managing Cookies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference through our cookie preferences manager or by modifying your web browser setting to either refuse some or all cookies or notify you and ask for your permission when a website tries to set a cookie. Please refer to our Cookie Policy for more details on (1) how to implement browser level
controls; (2) exercising your choice regarding analytics cookies, and (3) exercising your choice or opting out of interest-based advertising cookies.

Your Privacy Rights

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have
absolute discretion in providing you with those rights.

Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal
information.
Right to Correct/Rectification. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate.
Right to Delete/Erasure. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service
requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate
grounds for keeping your personal information.
Right to Portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights.
No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
Right Not to Provide Consent or to Withdraw Consent. We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness
of the processing based on consent before its withdrawal. If you fail to provide certain personal information when requested, we may not be able to provide you certain services or functionality.
Right to Restriction. You may have the right to request that we restrict our processing of your personal information in certain circumstance. For instance, this right is available if you contest the accuracy of the personal information, or you objected to our processing.
Right to Object to Processing. You may have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent, or legitimate interests. However, we may continue
to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to Opt-Out of Targeted Advertising. You have the right to opt-out of the sharing of your personal information for behavioral advertising purposes. Like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your IP address
or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. You have the right to direct us not to share or use your personal information for targeted advertising purposes by adjusting your preference through our
cookie preferences manager. Please note that if you change browsers or devices, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt-out of sharing and sales by using an opt-out preference signal for each participating browser
system that you use. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site at
https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Please note that the opt-out choice will only apply to your use of our Sites through the current
browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Sites to completely opt-out using this method. Please note that you may still receive
generalized ads after opting out of targeted advertising.

These rights are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another’s privacy; (iii) to protect our
rights and properties; or (iv) where the request is frivolous or vexatious, or for other reasons. In some jurisdictions, if you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.” As noted above, depending on where you reside or are
located at the time your personal information is collected, you may be able to assert certain rights with respect to your personal information. To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have
a law providing such rights, or it does not apply to our operations. If you are located in another country, please contact us.

Jurisdiction	Applicable Rights
European Economic Area, United Kingdom and Switzerland (for individuals located in these jurisdictions when their personal information is collected)	(a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (f) Right to Opt-Out of Automated Decision-making or Profiling; (g) Right Not to Provide Consent or to Withdraw Consent; (h) Right to Restriction; and (i) Right to Object to Processing
California Residents	(a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; (f) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency); (j) Right to Opt-Out of Sale; and (k) Right to Opt-Out of Targeted Advertising
Colorado Residents, Connecticut Residents, Virginia Residents Utah Residents Texas Residents (Eff. Jul. 2024), Oregon Residents (Eff. Jul. 2024), Montana Residents (Eff. Oct. 2024), Delaware Residents (Eff. Jan. 2025), New Hampshire Residents (Eff. Jan. 2025), New Jersey Residents (Eff. Jan. 2025), Indiana Residents (Eff. Jan. 2026)	(a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; (f) Right to Opt-Out of Automated Decision-making or Profiling; (j) Right to Opt-Out of Sale; and (k) Right to Opt-Out of Targeted Advertising.
Iowa Residents (Eff. Jan. 2025)	(a) Right to Know/Access; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; (j) Right to Opt-Out of Sale; and (k) Right to Opt-Out of Targeted Advertising.
Tennessee Residents (Eff. Jul. 2025)	(a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; and (j) Right to Opt-Out of Sale.

Submitting a Request to Exercise Your Rights

To assert your privacy rights, please email
[email protected]. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may conduct the
verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the
authorized agent signed written permission to do so.

12. Additional Disclosure to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Laws”) requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of
this Privacy Notice.

California Sensitive Information Disclosure

We collect the following categories of sensitive personal information (as defined under California law): A consumer’s account log-in information in combination with any required security or access code, password, or credentials allowing access to an account; and precise geolocation. This information
is collected in order to process transactions, comply with laws, provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for
purposes of cross-context behavioral advertising.

Your Right to Limit Use of Sensitive Information

If you are a California resident, to the extent your sensitive personal information (as that term is defined under California privacy law) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. We
do not process any sensitive personal information to infer characteristics about you without your consent.

Shine the Light

If you are a California resident, you have the right to ask us for a notice describing what, if any, categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the
categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information.

Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

13. Additional Disclosure for Data Subjects in the European Economic Area, the United Kingdom, and Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area (“EEA”), the United Kingdom, and Switzerland (collectively, the “European Countries”) at the time of data collection. Pursuant to the European Union’s General Data Protection
Regulation, and the UK General Data Protection Regulation (collectively, the “GDPR”), for the sake of clarity, references to personal information in this Privacy Policy concern personal data in the sense of the GDPR. We may ask you to identify which country you are located in when you use or access
some of the Services, or we may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Privacy Policy, the terms in this section shall apply to individuals in European Countries. The Controller for the processing
described in this Privacy Policy is: Vydia, Inc., 228 Park Ave S., Suite 19266, New York, New York 10003-1502,
[email protected].

Legal Bases for Processing Your Personal Information

The legal bases under the GDPR for our processing of personal data of individuals, which are located in European Countries at the time of collection, for each of the processing activities described above in Sections 2 and 3 is identified in the chart below.

Processing Activity	Legal Bases for Processing
Section 3(c) To Maintain Legal and Regulatory Compliance Section 3(e) To Detect and Prevent Fraud and Security Risks Section 4(d) For Legal Compliance & Safety	Based on our legal obligations. Article 6(1) lit.(c) GDPR.
Section 3(a) To Provide Our Services Section 3(b) To Provide Services-Related Communications Section 3(d) To Enforce Compliance with Our Terms, Agreements and Policies Section 3(f) To Provide Customer Support and Respond to Requests Section 4(a) With Our Service Providers Section 4(b) Within Our Corporate Organization Section 4(e) With Third Party Marketing Partners	Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR.
Section 3(h) To Research and Develop Our Services Section 3(i) To Personalize Your Experience Section 3(j) To Facilitate Corporate Acquisitions, Mergers and Transactions Section 4(c) During Business Transaction or Other Asset Transfers	Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR.
Section 3(g) To Provide Marketing Communication Section 3(k) With Your Consent Section 4(f) With Third Party Media Partners Section 4(g) With Your Consent	Based on your consent. Article 6(1) lit.(a) GDPR.

Right to Lodge a Complaint to Your Local Data Protection Authority

If you reside in certain territories (such as the European Economic Area, Switzerland, the United Kingdom), you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here:
https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO).

International Transfer of Your Personal Information

We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively “European Personal Information”), to the extent
the recipients of the European Personal Information are located in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the
jurisdiction of the party receiving the information, or derogations in specific situations.

14. How To Contact Us

We welcome your questions, comments and concerns about privacy. You can contact Vydia online at
https://vydia.com/contact/, by phone at +1 (646) 661-2484, by email at [email protected] or by postal mail at Vydia, Inc., 228 Park Ave S., Suite 19266, New York, New York 10003-1502, USA.

Privacy Policy