Medialyzer and our group companies (“we”, “us”, “our”) take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

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We collect, use and are responsible for certain personal data about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union and Kişisel Verilerin Korunması Kanunu which applies in Turkey and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

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Overview of Processing

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We collect and use limited personal data about individuals who visit our website, who contact us for any reason, who attend our events and otherwise engage with us, who contract with us as customers for the use of our products and services (specifically the Tvlyzer platform) (together our “platform”), who visit the websites and/or applications of our customers (or their clients) and who otherwise use our platform. This table gives an overview of individuals we collect personal data about, and the personal data we typically collect. The information in this table is not exhaustive, and more detailed information may be contained in the following sections of this policy.

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Medialyzer TV Tracking

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Medialyzer TV Tracking Platform allows businesses to deliver relevant online advertising at the right moment. For companies that want to advertise online, our Platform helps get their ads in front of the people when a specific event is occurring in the offline world. For consumers, we provide ads that are relevant to the current offline context. In short, we try to make online advertising more efficient and pleasant for everyone. In order to do all this, we collect and analyze offline contextual information about TV ads airing. Then, every time the contextual rule defined by our client is true, we send a signal to the ad tech provider to start the synced campaign. When the rule is false, we send a signal to pause the synced campaign. Thus, we are not involved in the user targeting nor any remarketing process.

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Individuals and Personal Data Collected

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Agency and brand customer contacts for our customers who wish to use our products for the purpose of analyzing and optimizing their TV advertising spend.Customer contact information, including name, title, business address, email address and telephone number.

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Information about visitors to our website.:

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Information about your visit to our website, includingthe full Uniform Resource Locators (URL) clickstream to, through and from oursite (including date and time), products you viewed or searched for, pageresponse times, download errors, length of visits to certain pages, pageinteraction information (such as scrolling, clicks, and mouseovers), andmethods used to browse away from the page and any phone number used to call ouror their customer service number.Any other information you provide to us throughour website, including via our contact form or live chat function.

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Information about end users who visit the websites and applications of our agency customers, or their clients, or our direct brand customers.

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IP address; cookie ID or advertising ID; and any otherpersonal data that our customers wish us to collect about their (or theirclients’) end users (including, for example, user ID).Any other information our customers or theirclients collect from or about you and provide to us.We will assume that the online identifier dataprovided to us by our agency customers (and their clients, if applicable), orby our direct brand customers, is done so on the basis that the entityproviding your personal data has your consent or another valid reason toprocess your data. The standard terms and conditions we ask all our customersor those contracting with us to sign include representations that any personaldata provided to us is done so legitimately.

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Customers and other individuals or entities who sepersonal data we hold in our marketing database.

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Your contact information, including email address, telephone number and company details, and (if applicable) your responses to surveys, competitions and promotions provided from you through your use of our website contact form, live chat service, attendance at events including talks, presentations and seminars, downloading content on our website. We also may receive personal data through our third party data partners.See below “How Your Personal Data Is Collected”

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Authorized users of our customers that access our platform.

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Activity of a platform user, including mouse scrolls and clicks; keystrokes entered; and/or pages viewed or visited, including the duration of such visits.Device information such as:Browser InformationOperating system informationMobile device information (e.g., device identifier, mobile operating system, etc.)Page accessedGeographic locationTime of visit (by day, week, and duration)Whether the visitor is a new or return visitorOther such information as may be delivered or shared by the applicable browser or access software or device.This platform user information is transmitted in encrypted form.This personal data is required to provide products and services to you, your agents and/or clients or to those who purchase our products or engage our services whose websites you may visit. If you wish to use our products or services and do not provide personal data we ask for, it may delay or prevent us from providing those products or services.

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How Your Personal Data Is Collected

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We collect some of this personal data directlyfrom you—in person, by telephone, text or email and/or via our websiteincluding our contact form. However, we also collect information:
from our customers or their clients, whom we getaccess to their Google Analytics, Adjust or any other web/mobile analyticsplatform in order to enable the collection of information and statistics onindividuals visiting and using our customer’s or its clients’ website and/orapplications, so that we can model, analyse and measure its or their TVadvertising performance
from you, directly, including through your use ofour website contact form, attendance at events including talks, presentationsand seminars, downloading content on our websitefrom cookies on our website—for more informationon our use of cookies, please see below (“Cookies”)Cookies

Medialyzer site. Our site uses cookies todistinguish you from other users of our site or the sites of our customers ortheir clients. This helps us to provide you with a good experience when youbrowse our site and also allows us, our customers and their clients to improveour site. A cookie is a small file which asks permission to be placed on yourcomputer’s hard drive. Once you agree, the file is added and the cookie helpsanalyse web traffic or lets you know when you visit a particular site. Cookiesallow web applications to respond to you as an individual. The web applicationcan tailor its operations to your needs, likes and dislikes by gathering andremembering information about your preferences.
We use traffic log cookies to identify which pagesare being used. This helps us to analyse data about web page traffic andimprove our site in order to tailor it to your needs. From our perspective, weonly use this information for statistical analysis purposes and then the datais removed from the system.

Overall, cookies help provide you with a betterwebsite, by enabling us to monitor which pages you find useful and which you donot. A cookie in no way gives access to your computer or any information aboutyou, other than the data you choose to share. You can choose to accept ordecline cookies. Most web browsers automatically accept cookies, but you canusually modify your browser setting to decline cookies if you prefer. This mayprevent you from taking full advantage of the website.
Some of the cookies that an authorized user of ourplatform may find on its browser (depending on settings) after navigating toour platform are as set out below. Additional cookies may be added, and we mayupdate or remove the cookies below from time to time.


COOKIE

EXPIRES

TYPE OF COOKIE

PURPOSE

_ga

2 years from set/update
First Party Persistent
This cookie is typically written to the browserupon the first visit. If the cookie has been deleted by the browser operator,and the browser subsequently visits medialyzer.com, a new _ga cookie is writtenwith a different unique ID. In most cases, this cookie is used to determineunique visitors to medialyzer.com and it is updated with each page view.Additionally, this cookie is provided with a unique ID that Google Analyticsuses to ensure both the validity and accessibility of the cookie as an extrasecurity measure.

Google’s privacy policy is available at: https://www.google.com/policies/privacy/ and the type of cookies they use are listed here: https://policies.google.com/technologies/types





Medialyzer’s attribution services involvemeasuring an advertiser’s end users’ response to TV advertising on variousmediums, including website and app. Medialyzer relies on certain types of datato provide these services, depending on the type of response being measured.The cookies that an advertiser’s end user may find on its browser (depending onsettings) after navigating to one of our advertiser’s websites or applicationsare as set out below. Additional cookies may be added, and we may update or removethe cookies below.



COOKIE

EXPIRES

TYPE OF COOKIE

PURPOSE

_pk_uid

2 years

Third party persistent
Cookie which allows the TV Squared collector toidentify individual users, in order to establish lag between responseactivities, and to confirm continuity of campaigns being responded to.
_pk_id.{variable id} or _tq_id.{variable id}
2 years

First party persistent
Aids reporting of site visits and actions foranalytical reporting to TV Squared.

_pk_ses

30 mins

First party session
Used to confirm an individual user in relation toan individual session, i.e. how long the user is on the website.


Medialyzer’s opt-out mechanism. The advertiser, asthe owner or manager of its website and applications, is responsible forinforming its end users about all data being collected (including data fromMedialyzer) and for collecting appropriate consents from end users, inaccordance with applicable data and privacy laws.
Additional guidance. End users may also wish tomanage their cookies on a wider basis through their browser or operating systemsettings on their computer or device. They can find out instructions on how todo this through the browser or operating system they are using.
The Digital Advertising Alliance(www.digitaladvertisingalliance.org) and Network Advertising Initiative(www.networkadvertising.org) also provide helpful resources for end users inrelation to opting out of interest-based ads, re-setting advertising IDs, andlimiting ad tracking.



How and Why We Use Your Personal Data
Under data protection law, we can only use yourpersonal data if we have a proper reason for doing so, e.g.:
to comply with our legal and regulatoryobligations;
for the performance of our contract with you oryour agent or client, or to take steps at your or your agent or client’srequest before entering into a contract;
for the performance of our contract with ourcustomers whose websites you may visit;
for our legitimate interests or those of a thirdparty; or
where you have given consent to us, our customersor our customers’ clients.
A legitimate interest is when we have a businessor commercial reason to use your information, so long as this is not overriddenby your own rights and interests.

The table below explains what we use (process)your personal data for and our reasons for doing so:


WHAT WE MAY USE YOUR PERSONAL DATA FOR
OUR REASONS

To provide products or services to you, your agentor your clients, including to provide you with details of any changes to ourservices and to allow you to participate in interactive features of ourservice, if you choose to do so.

For the performance of our contract with you, youragent or your clients or to take steps at your request before entering into acontract

To provide products and services to our customersor their clients whose websites you may visit.
For our legitimate interests or those of a thirdparty e.g. the performance of our contracts with our customers or their clients.
Analyse and obtain information regarding howcustomer’s authorized users are interacting with our platform.
To improve the performance of the platform forcustomers and their authorized users.

To prevent and detect fraud against you orMedialyzer

For our legitimate interests or those of a thirdparty, i.e. to minimise fraud that could be damaging for us and for you.
Conducting checks to identify our customers, theiragent and/or their clients and verify their identity.
Screening for financial and other sanctions orembargoes

Other processing necessary to comply withprofessional, legal and regulatory obligations that apply to our business, e.g.under health and safety regulation or rules issued by our professionalregulator.

To comply with our legal and regulatoryobligations.

Gathering and providing information required by orrelating to audits, enquiries or investigations by regulatory bodies.
To comply with our legal and regulatoryobligations.

Ensuring business policies are adhered to, e.g.policies covering security and internet use.

For our legitimate interests or those of a thirdparty, i.e. to make sure we are following our own internal procedures so we candeliver the best service.

Operational reasons, such as improving efficiency,troubleshooting, data analysis, testing, research, statistical and surveypurposes, training and quality control.

For our legitimate interests or those of a thirdparty, i.e. to be as efficient as we can so we can deliver the best service foryou at the best price.

Ensuring the confidentiality of commerciallysensitive information.

For our legitimate interests or those of a thirdparty, i.e. to protect trade secrets and other commercially valuableinformation.

To comply with our legal and regulatoryobligations.

Statistical analysis to help us manage ourbusiness, e.g. in relation to our commercial or financial performance, customerbase, product range and use or other efficiency measures.
For our legitimate interests or those of a thirdparty, i.e. to be as efficient as we can so we can deliver the best service atthe best price.

To ensure the safety and security of our systems,including preventing unauthorised access and modifications to systems.
For our legitimate interests or those of a thirdparty, i.e. to prevent and detect criminal activity that could be damaging forus and for you.

To comply with our legal and regulatoryobligations.

Updating and enhancing customer records.
For the performance of our contract with you, youragent or your clients, or to take steps at your request before entering into acontract.

To comply with our legal and regulatoryobligations.

For our legitimate interests or those of a thirdparty, e.g. making sure that we can keep in touch with our customers aboutexisting orders and new products.

Statutory returns.
To comply with our legal and regulatoryobligations.

Ensuring safe working practices, staffadministration and assessments.

To comply with our legal and regulatoryobligations.

For our legitimate interests or those of a thirdparty, e.g. to make sure we are following our own internal procedures andworking efficiently so we can deliver the best service.
Marketing our services and those of selected thirdparties to:

—existing and former customers;
—third parties who have previously expressed aninterest in our services; and

—third parties with whom we have had no previousdealings.

For our legitimate interests or those of a thirdparty, i.e. to promote our business to existing and former customers.
Credit reference checks via external creditreference agencies.

For our legitimate interests or those of a thirdparty, i.e. to ensure our customers are likely to be able to pay for ourproducts and services.

External audits and quality checks, e.g. for ISOor Investors in People accreditation and the audit of our accounts.
For our legitimate interests or a those of a thirdparty, i.e. to maintain our accreditations so we can demonstrate we operate atthe highest standards.

To comply with our legal and regulatoryobligations.



The above table does not apply to special categorypersonal data, which we will only process with your explicit consent.
Promotional Communications
We may use your personal data to send you updates(by email, text message, telephone or post) about our products and services,including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing yourpersonal data for promotional purposes (see above “How and Why We Use YourPersonal Data”). This means we do not usually need your consent to send youpromotional communications. However, where consent is needed, we will ask forthis consent separately and clearly.

We will always treat your personal data with theutmost respect and never sell or share it with other organisations outside theMedialyzer group for marketing purposes, without your consent or the consent ofyour agent or client as appropriate.

You have the right to opt out of receivingpromotional communications at any time by:

contacting us at info@medialyzer.com; orusing the ‘unsubscribe’ link in emails.We may ask you to confirm or update your marketingpreferences if you instruct us to provide further products or services in thefuture, or if there are changes in the law, regulation, or the structure of ourbusiness.

Who We Share Your Personal Information With
We routinely share personal information with:
companies within the Medialyzer groupthird parties we use to help deliver our productsand services to you, your agent, your clients and our customers whose websitesyou may visit, e.g. business partners, suppliers, sub-contractors and paymentservice providers
other third parties we use to help us run ourbusiness, e.g. marketing agencies, website hosts and analytics and searchengine providers
third parties approved by you, your agent or yourclient as appropriate, e.g. social media sites you choose to link your accountto or third party payment providers
We only allow our business partners,subcontractors and other suppliers or service providers to handle your personaldata if we are satisfied they take appropriate measures to protect yourpersonal data. We also impose contractual obligations on them relating toensure they can only use your personal data to provide services to us and toyou. We may also share personal data with external auditors.
We may disclose and exchange information with lawenforcement agencies and regulatory bodies to comply with our legal andregulatory obligations.

We may also need to share some personal data withother parties, such as potential buyers of some or all of our business orduring a re-structuring. Usually, information will be anonymized but this maynot always be possible. The recipient of the information will be bound byconfidentiality obligations.

Where Your Personal Data Is Held
Information may be held at our offices and thoseof our group companies, third party agencies, service providers,representatives and agents as described above (see above: “Who We Share YourPersonal Data With”).

How Long Your Personal Data Will Be Kept
We will keep your personal data while we areproviding products or services to you, your agent, your clients or ourcustomers whose websites and/or applications you may visit. Thereafter, we willkeep your personal data for as long as is necessary:
to respond to any questions, complaints or claimsmade by you or on your behalf;
to show that we treated you fairly; andto keep records required by law.We will not retain your personal data for longerthan necessary for the purposes set out in this policy. Different retentionperiods apply for different types of personal data.


Your Rights

You have the following rights, which you canexercise free of charge:



ACCESS.

The right to be provided with a copy of yourpersonal data (the right of access).

RECTIFICATION.

The right to require us to correct any mistakes inyour personal data.

TO BE FORGOTTEN.
The right to require us to delete your personaldata—in certain situations.

RESTRICTION OF PROCESSING.
The right to require us to restrict processing ofyour personal data—in certain circumstances, e.g. if you contest the accuracyof the data.

DATA PORTABILITY.
The right to receive the personal data youprovided to us, in a structured, commonly used and machine-readable formatand/or transmit that data to a third party—in certain situations.
TO OBJECT.

The right to object:
—at any time to your personal data being processedfor direct marketing (including profiling); and
—in certain other situations to our continuedprocessing of your personal data, e.g. processing carried out for the purposeof our legitimate interests.

NOT TO BE SUBJECT TO AUTOMATED INDIVIDUALDECISION-MAKING.

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.


If you would like to exercise any of those rights, please:

email us - info@medialyzer.com - andlet us have enough information to identify you(e.g. your full name, address and customer reference number);let us have proof of your identity and address (acopy of your driving licence or passport and a recent utility or credit cardbill); and
let us know what right you want to exercise and the information to which your request relates.Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Keeping Your Personal Data Secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and follow industry standards for information security.
We also have procedures in place to deal with anysuspected data security breach. We will notify you and any applicable regulatorof a suspected data security breach where we are legally required to do so.
How to Complain

We hope that we can resolve any query or concernyou may raise about our use of your information.
The General Data Protection Regulation also givesyou right to lodge a complaint with a supervisory authority, in particular inthe European Union (or European Economic Area) state where you work, normallylive or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Policy
This privacy notice was last updated on the dateset-out above. We may change this privacy notice from time to time.
How to Contact Us
Please contact us by email if you have anyquestions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Contact address: Privacy Team, Medialyzer MedyaTeknolojileri A.Ş., Levent Mah. Altzeren Sk. No:21 Beşiktaş, İstanbul

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Email address: info@medialyzer.com

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