Data Processing Agreement

BACKGROUND

The Customer, as used herein, refers to the Advertiser that is the contracting party to an Ai Media Group Internet Advertising Program – General Terms and Conditions (the "Terms of Service Agreement"), and an Ai Media Group Internet Advertising Order and Payment Authorization (the "IO"). If the Terms of Service Agreement and IO require Ai Media Group to process Personal Data on behalf of the Customer, the terms and conditions of this Data Processing Agreement shall apply.

This Data Processing Agreement (Agreement) sets out the additional terms, requirements and conditions on which Ai Media Group will process Personal Data when providing services under the Terms of Service Agreement pursuant to an IO placed by the Customer. This Agreement contains the mandatory clauses applicable to Personal Data subject to and required by:

Article 28(3) of the General Data Protection Regulation ((EU) 2016/679) (EU GDPR) for contracts between controllers and processors; Article 28(3) of the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) for contracts between controllers and processors

AGREED TERMS

1. Definitions and interpretation The following definitions and rules of interpretation apply in this Agreement.

1.1 Definitions: Ai Media Group Affiliate means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with Ai Media Group, where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise.

Applicable Data Protection Law means the data protection and privacy law, if it exists on the Effective Date of this Agreement, governing the processing, storage, transfer or other use of Personal Data and privacy of certain individuals including the California Data Privacy Legislation (as applicable to Personal Data of individuals located in California under certain circumstances), the European Data Protection Legislation (as applicable to Personal Data of individuals located in the EU), and the UK GDPR (as applicable to Personal Data of individuals located in the UK), and its associated regulations, if and when in force from time to time.

Business Purposes means the services to be provided by Ai Media Group to the Customer as described in the Terms of Service Agreement and any other purpose specifically identified in Schedule 1.

California Data Privacy Legislation means the California Consumer Privacy Act (California Civil Code Sec. 1798.100 et seq., also known as the California Consumer Privacy Act of 2018), the California Privacy Rights Act (California Civil Code Sec. 1798.120 et seq., also known as the California Privacy Rights Act of 2020, in effect beginning January 1, 2023), and its associated regulations, if and when in force from time to time.

Controller: has the meaning given to it in section 6, DPA 2018.

European Data Protection Legislation means: all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) (DPA 2018); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and all applicable data protection and privacy legislation in force from time to time in the EU including Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (EU GDPR); and Directive 2002/58/EC concerning the Processing of Personal Data and the protection of privacy in the electronic communications sector;

Data Subject: the identified or identifiable living individual to whom the Personal Data relates.

EEA means the European Economic Area.

Personal Data means any information relating to an identified or identifiable living individual that is processed by Ai Media Group on behalf of the Customer as a result of, or in connection with, the provision of the services under the Terms of Service Agreement; an identifiable living individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

Processing, processes, processed, process means any activity that involves the use of the Personal Data. It includes, but is not limited to, any operation or set of operations which is performed on the Personal Data or on sets of the Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring the Personal Data to third parties.

Personal Data Breach means a breach of security leading to the accidental, unauthorised or unlawful destruction, loss, alteration, disclosure of, or access to, the Personal Data.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

Records means has the meaning given to it in Clause 12.

Standard Contractual Clauses (SCC) means the standard contractual clauses for the transfer of Personal Data to third countries annexed to Commission Implementing Decision (EU) 2021/914 of 4 June 2021, as completed in Schedule 2, together with, where the UK GDPR applies, the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner (the UK Addendum), in each case as amended or replaced from time to time. The SCC shall only apply to the extent that the European Data Protection Legislation governs any Personal Data.

Term means this Agreement's term as defined in Clause 10.

UK GDPR means has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the DPA 2018.

1.2 This Agreement is subject to the terms of the Terms of Service Agreement, and is incorporated into the Terms of Service Agreement. Interpretations and defined terms set forth in the Terms of Service Agreement apply to the interpretation of this Agreement.

1.3 The Schedules and Appendixes form part of this Agreement and will have effect as if set out in full in the body of this Agreement. Any reference to this Agreement includes the Schedules and Appendixes

1.4 A reference to writing or written includes email.

1.5 In the case of conflict or ambiguity between: any provision contained in the body of this Agreement and any provision contained in the Appendixes, the provision in the body of this Agreement will prevail; the terms of any accompanying invoice or other documents annexed to this Agreement and any provision contained in the Appendixes, the provision contained in the Appendixes will prevail; any of the provisions of this Agreement and the provisions of the Terms of Service Agreement, the provisions of this Agreement will prevail; and if the European Data Protection Legislation is applicable, any of the provisions of this Agreement and any executed SCC, the provisions of the executed SCC will prevail.

2. Personal data types and processing purposes

2.1 The Customer and Ai Media Group agree and acknowledge that, under any Applicable Data Protection Law: the Customer is the controller and Ai Media Group is the processor. the Customer retains control of the Personal Data and remains responsible for its compliance obligations under Applicable Data Protection Law, including but not limited to providing any required notices and obtaining any required consents, and for the written processing instructions it gives to Ai Media Group. Schedule 1 describes the subject matter, duration, nature and purpose of the processing and the Personal Data categories and Data Subject types in respect of which Ai Media Group may process the Personal Data to fulfil the Business Purposes.

3. Ai Media Group's obligations

3.1 Ai Media Group will only process the Personal Data to the extent, and in such a manner, as is necessary for the Business Purposes in accordance with the Customer's written instructions. Ai Media Group will not process the Personal Data for any other purpose or in a way that does not comply with this Agreement or Applicable Data Protection Law. Ai Media Group must promptly notify the Customer if, in its opinion, the Customer's instructions do not comply with Applicable Data Protection Law.

3.2 Ai Media Group must comply promptly with any Customer written instructions requiring Ai Media Group to amend, transfer, delete or otherwise process the Personal Data, or to stop, mitigate or remedy any unauthorised processing.

3.3 Ai Media Group will maintain the confidentiality of the Personal Data and will not disclose the Personal Data to third parties unless the Customer or this Agreement specifically authorises the disclosure, or as required by domestic law, court or regulator. If a domestic law, court or regulator requires Ai Media Group to process or disclose the Personal Data to a third party, Ai Media Group must first inform the Customer of such legal or regulatory requirement and give the Customer an opportunity to object or challenge the requirement, unless the domestic law prohibits the giving of such notice.

3.4 Ai Media Group will reasonably assist the Customer, at no additional cost to the Customer, with meeting the Customer's compliance obligations under Applicable Data Protection Law, taking into account the nature of Ai Media Group's processing and the information available to Ai Media Group, including in relation to Data Subject rights, data protection impact assessments and reporting to and consulting with the regulator under Applicable Data Protection Law.

3.5 Ai Media Group must promptly notify the Customer of any material changes to Applicable Data Protection Law that may reasonably be interpreted as adversely affecting Ai Media Group's performance of the Terms of Service Agreement or this Agreement.

4. Ai Media Group employees

4.1 Ai Media Group will ensure that all of its employees: are informed of the confidential nature of the Personal Data and are bound by confidentiality obligations and use restrictions in respect of the Personal Data; have undertaken training on any Applicable Data Protection Law relating to handling Personal Data and how it applies to their particular duties; and are aware both of Ai Media Group's duties and their personal duties and obligations under any Applicable Data Protection Law and this Agreement.

5. Security

5.1 Ai Media Group must at all times implement appropriate technical and organisational measures against unauthorised or unlawful processing, access, copying, modification, reproduction, display or distribution of the Personal Data, and against accidental or unlawful loss, destruction, alteration, disclosure or damage of Personal Data including, but not limited to, the security measures set out in Schedule 3.

5.2 Ai Media Group must implement such measures to ensure a level of security appropriate to the risk involved, including as appropriate: the pseudonymisation and encryption of personal data; the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and a process for regularly testing, assessing and evaluating the effectiveness of the security measures.

6. Personal Data Breach

6.1 Ai Media Group will without undue delay notify the Customer if it becomes aware of: the loss, unintended destruction or damage, corruption, or unpracticality of part or all of the Personal Data. Ai Media Group will restore such Personal Data at its own expense as soon as possible. any accidental, unauthorised or unlawful processing of the Personal Data; or any Personal Data Breach.

6.2 Where Ai Media Group becomes aware of (a), (b) and/or (c) above, it shall, without undue delay, also provide the Customer with the following information: description of the nature of (a), (b) and/or (c), including the categories of in-scope Personal Data and approximate number of both Data Subjects and the Personal Data records concerned; the likely consequences; and a description of the measures taken or proposed to be taken to address (a), (b) and/or (c), including measures to mitigate its possible adverse effects.

6.3 Immediately following any accidental, unauthorised or unlawful Personal Data processing or Personal Data Breach, the parties will co-ordinate with each other to investigate the matter. Further, Ai Media Group will reasonably co-operate with the Customer at no additional cost to the Customer, in the Customer's handling of the matter, including but not limited to: assisting with any investigation; providing the Customer with physical access to any facilities and operations affected; making available all relevant records, logs, files, data reporting and other materials required to comply with any Applicable Data Protection Law or as otherwise reasonably required by the Customer; and taking reasonable and prompt steps to mitigate the effects and to minimise any damage resulting from the Personal Data Breach or accidental, unauthorised or unlawful Personal Data processing.

6.4 Ai Media Group will not inform any third party of any accidental, unauthorised or unlawful processing of all or part of the Personal Data and/or a Personal Data Breach without first obtaining the Customer's written consent, except when required to do so by domestic law.

6.5 Ai Media Group agrees that the Customer has the sole right to determine whether to provide notice of the accidental, unauthorised or unlawful processing and/or the Personal Data Breach to any Data Subjects, in-scope regulators, law enforcement agencies or others, as required by law or regulation or in the Customer's discretion, including the contents and delivery method of the notice.

7. Cross-border transfers of personal data

7.1 Customer consents to Ai Media Group (and its subcontractors) transferring and otherwise processing the Personal Data outside the EEA on the basis that the parties by signing up to this Agreement are also agreeing to enter into the SCC at Schedule 2. In addition to the parties' agreement to the SCC, and prior to the transfer of any Personal Data the parties shall make an assessment of whether the legal framework of the country outside the EEA where the processing is taking place and the security measures in place proves an adequate level or protection taking into account the types of Personal Data being processed. Together the agreement to the SCC's and the risk based assessment shall ensure the transfer between Customer and Ai Media Group is a valid cross-border transfer under the European Data Protection Legislation, and that Ai Media Group (and, where appropriate, the Customer) can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required by Article 46 of the UK GDPR and EU GDPR.

7.2 The parties will complete all relevant details in, the SCC contained in Schedule 2 and take all other actions required to legitimise the transfer.

7.3 If the Customer consents to appointment by Ai Media Group of a subcontractor located outside the EEA in compliance with the provisions of clause 8, then the Customer authorises Ai Media Group to carry out the risk based assessment of adequacy and enter into the SCC (Module Three, processor to processor) with the subcontractor in the Customer's name and on its behalf. Ai Media Group will make the executed SCC with the subcontractor available to the Customer on request.

8. Subcontractors

8.1 Other than those subcontractors as set out in Schedule 1, or otherwise agreed in writing by the Customer Ai Media Group may not authorise any other third party or subcontractor to process the Personal Data.

8.2 Those subcontractors approved as at the commencement of this Agreement are as set out in Schedule 1. Ai Media Group must list all approved subcontractors in Schedule 1 and include any subcontractor's name and location and the contact information for the person responsible for privacy and data protection compliance.

8.3 Where the subcontractor fails to fulfill its obligations under the written agreement with Ai Media Group which contains terms substantially the same as those set out in this Agreement, Ai Media Group remains fully liable to the Customer for the subcontractor's performance of its agreement obligations.

8.4 The Parties agree that Ai Media Group will be deemed to control legally any Personal Data controlled practically by or in the possession of its subcontractors.

8.5 The subcontractors listed in Schedule 1 include providers of artificial intelligence services ("AI Providers"). Ai Media Group uses AI Providers only to process Personal Data for the Business Purposes, and only under enterprise or API terms that (a) prohibit the AI Provider from using Personal Data, inputs or outputs to train or improve its models, (b) limit the AI Provider's retention of Personal Data to what is necessary to provide the service, and (c) contain data protection terms substantially the same as those set out in this Agreement. Ai Media Group will not submit Personal Data to consumer or personal AI accounts, and will not use AI Providers to make decisions based solely on automated processing that produce legal or similarly significant effects on Data Subjects.

9. Complaints, data subject requests and third-party rights

9.1 Ai Media Group must, at no additional cost to the Customer, take such technical and organisational measures as may be appropriate, and promptly provide such information to the Customer as the Customer may reasonably require, to enable the Customer to comply with: the rights of Data Subjects under any Applicable Data Protection Law, including subject access rights, the rights to rectify, port and erase personal data, object to the processing and automated processing of personal data, and restrict the processing of personal data; and information or assessment notices served on the Customer by the regulator under the Data Protection Legislation.

9.2 Ai Media Group must notify the Customer immediately in writing if it receives any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Data or to either party's compliance with Applicable Data Protection Law.

9.3 Ai Media Group must notify the Customer within seven days if it receives a request from a Data Subject for access to their Personal Data or to exercise any of their other rights under Applicable Data Protection Law.

9.4 Ai Media Group will give the Customer, at no additional cost to the Customer, its full co-operation and assistance in responding to any complaint, notice, communication or Data Subject request.

9.5 Ai Media Group must not disclose the Personal Data to any Data Subject or to a third party other than in accordance with the Customer's written instructions, or as required by domestic law.

10. Term and termination

10.1 This Agreement will remain in full force and effect so long as: the Terms of Service Agreement remains in effect; or Ai Media Group retains any of the Personal Data related to the Terms of Service Agreement in its possession or control (Term).

10.2 Any provision of this Agreement that expressly or by implication should come into or continue in force on or after termination of the Terms of Service Agreement in order to protect the Personal Data will remain in full force and effect.

10.3 If a change in any Data Protection Legislation prevents either party from fulfilling all or part of its Terms of Service Agreement obligations, the parties may agree to suspend the processing of the Personal Data until that processing complies with the new requirements. If the parties are unable to bring the Personal Data processing into compliance with the Data Protection Legislation within 30 days, either party may terminate the Terms of Service Agreement on not less than 20 working days written notice to the other party.

11. Data return and destruction

11.1 At the Customer's request, Ai Media Group will give the Customer, or a third party nominated in writing by the Customer, a copy of or access to all or part of the Personal Data in its possession or control in the format and on the media reasonably specified by the Customer.

11.2 On termination of the Terms of Service Agreement for any reason or expiry of its term, or upon Customer's request, Ai Media Group will, within the required time period (if any) set forth in the Applicable Data Protection Law, securely delete or destroy or, if directed in writing by the Customer, return and not retain, all or any of the Personal Data related to this Agreement in its possession or control, except for one copy that it may retain and use for six years for audit and regulatory only.

11.3 If any law, regulation, or government or regulatory body requires Ai Media Group to retain any documents or materials or Personal Data that Ai Media Group would otherwise be required to return or destroy, it will notify the Customer in writing of that retention requirement, giving details of the documents, materials or Personal Data that it must retain, the legal basis for retention, and establishing a specific timeline for deletion or destruction once the retention requirement ends.

12. Records

12.1 Ai Media Group will keep detailed, accurate and up-to-date written records regarding any processing of the Personal Data, including but not limited to, the access, control and security of the Personal Data, approved subcontractors, the processing purposes, categories of processing, any transfers of personal data to a third country and related safeguards, and a general description of the technical and organisational security measures referred to in clause 5.1 (Records).

12.2 Ai Media Group will ensure that the Records are sufficient to enable the Customer to verify Ai Media Group's compliance with its obligations under this Agreement and Ai Media Group will provide the Customer with copies of the Records upon request.

13. Audit

13.1 At least once a year, Ai Media Group will conduct site audits of its Personal Data processing practices and the information technology and information security controls for all facilities and systems used in complying with its obligations under this Agreement, including, but not limited to, obtaining a network-level vulnerability assessment performed by a recognised third-party audit firm based on recognised industry best practices.

13.2 Ai Media Group will promptly address any exceptions noted in the audit reports with the development and implementation of a corrective action plan by Ai Media Group's management.

14. Warranties

14.1 Ai Media Group warrants and represents that: its employees, subcontractors, agents and any other person or persons accessing the Personal Data on its behalf are reliable and trustworthy and have received the required training on Applicable Data Protection Law; it and anyone operating on its behalf will process the Personal Data in compliance with Applicable Data Protection Law; it has no reason to believe that any Applicable Data Protection Law prevents it from providing any of the Terms of Service Agreement's contracted services; and considering the current technology environment and implementation costs, it will take appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of Personal Data and the accidental loss or destruction of, or damage to, Personal Data, and ensure a level of security appropriate to: the harm that might result from such unauthorised or unlawful processing or accidental loss, destruction or damage; the nature of the Personal Data protected; and comply with all Applicable Data Protection Law and its information and security policies, including the security measures required in clause 5.1 where the European Data Protection Legislation is applicable.

14.2 The Customer warrants and represents that Ai Media Group's expected use of the Personal Data for the Business Purposes and as specifically instructed by the Customer will comply with the Applicable Data Protection Law.

15. Notice

15.1 Any notice or other communication given to a party under or in connection with this Agreement must be in writing and delivered to: For the Customer: the data privacy contact designated by the Customer in the IO or, if none is designated, the Customer's primary contact under the Terms of Service Agreement For Ai Media Group: privacy@aimediagroup.com, with copy to Ai Media Group, LLC, One Penn Plaza, Suite 6243, New York, NY 10119, Attn: Privacy Compliance Officer

15.2 clause 15.1 does not apply to the service of any proceedings or other documents in any legal action or, where applicable, any arbitration or other method of dispute resolution.

16. Governing Law/Choice of Forum. This Agreement will be governed by and construed in accordance with the laws of the jurisdiction governing the Terms of Service Agreement. The provisions of the Terms of Service Agreement concerning the forum for the resolution of disputes shall also govern with respect to any disputes arising out of or relating to this DPA. Notwithstanding the foregoing, to the extent the European Data Protection Legislation applies to the Personal Data of individuals located in the EEA, the provisions concerning governing law and choice of forum set forth in the SCC (Schedule 2) shall govern the portion of the dispute applicable to such Personal Data.

17. Construction; Interpretation. This Agreement and the Terms of Service Agreement are the complete and exclusive statement of the mutual understanding of the parties and supersede and cancel all previous written and oral agreements and communications relating to the subject matter hereof. Headings contained in this Agreement are for convenience of reference only and do not form part of this Agreement.

18. Severability. If any provision of this Agreement is adjudicated invalid or unenforceable, this Agreement will be amended to the minimum extent necessary to achieve, to the maximum extent possible, the same legal and commercial effect originally intended by the parties. To the extent permitted by applicable law, the parties waive any provision of law that would render any clause of this Agreement prohibited or unenforceable in any respect.

Schedule 1 Personal Data processing purposes and details

1. Introduction

Ai Media Group provides Customers with access to technology services that help marketing teams and their agencies create, plan, target, buy, serve, measure and/or optimise ads and campaigns.

In the course of providing those services, data relating to individuals is collected and managed by the Customer using the services provided by the AI Media platform and associated technology.

Ai Media also works with third party technology providers (sub–processors listed below), including providers of artificial intelligence services, to help ensure the collection, processing, analysis and storage of Personal Data is performed in compliance with Applicable Data Protection Law.

2. Sources Of Data and How Data Is Collected

3. What Data is Passed to AI Media and how is it stored.

The Personal Data passed to Ai Media Group is described in Section 2. It is stored and processed by the approved subcontractors listed in Section 6, protected by the security measures set out in Schedule 3, and retained as set out in Section 5.

4. Business Purpose

Personal Data is processed to enable Ai Media to report to Customer on the effectiveness of its digital advertising campaigns and to enable Customer and its marketing agency to identify target audiences who would be receptive to Customer's digital marketing campaigns and to enable Customers to select digital advertising that are effective in generating new business. Personal Data may also be processed using artificial intelligence services provided by the AI Providers listed in Section 6 to analyze campaign and attribution data, detect performance changes, generate reporting and recommendations for the Customer, and process and generate images for the Customer's campaigns.

5. Duration of Processing

6. Approved Subcontractors:

Schedule 2 Standard Contractual Clauses (APPLICABLE ONLY WHERE USE OF PERSONAL DATA IS GOVERNED BY EUROPEAN DATA PROTECTION LEGISLATION)

1. EU transfers

Customer (the data exporter) and Ai Media Group (the data importer) agree that Module Two (controller to processor) of the standard contractual clauses annexed to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 is incorporated into this Agreement by reference and applies to transfers of Personal Data subject to the EU GDPR, completed as follows: 1. Clause 7 (docking clause) does not apply. 2. Clause 9 (use of sub-processors): Option 1 (specific prior authorization) applies. The subcontractors listed in Schedule 1 are authorized, and any further sub-processor is subject to clause 8 of this Agreement. 3. Clause 11 (redress): the optional language does not apply. 4. Clause 13 (supervision): the competent supervisory authority is determined in accordance with Clause 13(a). 5. Clause 17 (governing law): Option 2 applies. The Clauses are governed by the law of the EU Member State in which the data exporter is established; where that law does not allow for third-party beneficiary rights, or the data exporter is not established in an EU Member State, they are governed by the law of Ireland. 6. Clause 18 (choice of forum and jurisdiction): disputes shall be resolved by the courts of the EU Member State whose law governs the Clauses under paragraph 5. 7. Annex I.A (list of parties): the data exporter is the Customer, acting as controller, and the data importer is Ai Media Group, LLC, acting as processor, with the contact details set out in clause 15 of this Agreement. 8. Annex I.B (description of transfer): as set out in Appendix 1 below and Schedule 1. Transfers are continuous for the Term. 9. Annex I.C (competent supervisory authority): as set out in paragraph 4. 10. Annex II (technical and organisational measures): as set out in Appendix 2 below and Schedule 3. 11. Annex III (list of sub-processors): as set out in Schedule 1, Section 6.

2. UK transfers

Where Personal Data subject to the UK GDPR is transferred, the UK Addendum is incorporated into this Agreement by reference. Table 1 is completed with the parties' details set out in this Agreement, Table 2 refers to the Clauses as completed in Section 1 above, Table 3 is completed by Appendix 1, Appendix 2 and Schedule 1, and in Table 4 neither party may end the UK Addendum under its Section 19.

3. Precedence

In the event of any conflict between this Agreement and the SCC or the UK Addendum, the SCC or the UK Addendum (as applicable) shall prevail.

Appendix 1 to the Standard Contractual Clauses (Schedule 2) – Annex I

This Appendix forms part of the Clauses and must be completed and signed by the parties

The Member States may complete or specify, according to their national procedures, any additional necessary information to be contained in this Appendix

The data exporter is Customer

Data relating to individuals is collected by the Customer using the services provided by AI Media and its sub processors, and that data is transferred to AI Media for analysis and processing.

Data importer is Ai Media Group Data Importer and its sub processors provides Customers with access to technology services that help marketing teams and their agencies create, plan, target, buy, serve, measure and/or optimise ads and campaigns.

Data subjects The personal data transferred concern the following categories of data subjects (please specify):

Individuals who interact with Customer's digital marketing on a web or mobile site or call a telephone number in Customer's digital marketing, and existing customers of contacts of the Customer whose details are held by the Customer.

Categories of data The personal data transferred concern the following categories of data (please specify): The types of data captured are determined by Customer and may include:

Name,

Email address

Date of birth

IP address (by default the IP address is stored anonymized)

other online identifiers;

Telephone/mobile number

Location Data. These values are not precise and cannot be used to identify a particular address or household.

The pixels also track and report track browsing behavior, the type of ads they click on, if they abandon a page or the buy flow, take a purchase action, fill out a lead gen form, etc.

Browser, Browser version, Device type, Operating system, the User-Agent

Date, time, time zone

Pages visited (Page URLs and Page Titles)

Screens visited

Referrer URL

Marketing campaign URL parameters

Physical address,

IP-address

Files clicked and downloaded

Links to an outside domain that were clicked

Screen resolution

Session recording storing the HTML page, and all mouse events (movements, scrolls, locations and clicks), and keypresses

Search terms used on your web sites search engine

Custom dimensions and custom variables

Custom events

Content pieces

JavaScript errors

User ID

Ecommerce Order ID, Order Date

Ecommerce Abandoned carts

Media titles and URLs

Participation in A/B tests

The types of personal data captured are determined by Customer and may include without limitation: Name, Email address, Date of birth, Telephone/mobile number, transaction history

Invoca's tag also tracks and report browsing behavior campaign, search keyword, page views. Information also captured when call routed to Customer agent through recording and monitoring of calls.

Special categories of data (if appropriate)

The personal data transferred concern the following special categories of data (please specify): The parties do not anticipate the transfer of special categories of data.

Processing operations The personal data transferred will be subject to the following basic processing activities (please specify): The data will be analyzed to establish which digital marketing had the most effective response to help the Customer marketing teams and their agencies create, plan, target, buy, serve, measure and/or optimize future ads and campaigns which may include identifying the digital profile of groups most responsive to the campaign and targeting future campaigns at a cohort with a similar digital profile. Processing may include analysis by the artificial intelligence sub-processors listed in Schedule 1.

Appendix 2 to the Standard Contractual Clauses at Schedule 2 – Annex II

This Appendix forms part of the Clauses.

Description of the technical and organizational security measures implemented by the data importer in accordance with Clause 8.6 of the SCC:

See information relating to the Security Measures at Schedule 3 to the Agreement

Schedule 3 Security measures

Ai Media Group currently observes the Security Measures described in this Schedule 3. All capitalized terms not otherwise defined herein shall have the meanings as set forth in the Customer Terms and Conditions.

a) Access Control

Preventing Unauthorized Product Access

Outsourced processing: Ai Media Group's date processing services are hosted by outsourced cloud infrastructure providers. Ai Media Group maintains contractual relationships with those suppliers which requires them to in order to provide the hosting services in accordance with the requirements of Data Protection Legislation. Ai Media Group relies on contractual agreements, privacy policies, and supplier compliance programs in order to protect data processed or stored by these suppliers.

Physical and environmental security: Ai Media Group hosts its product infrastructure with multi-tenant, outsourced infrastructure providers. The physical and environmental security controls are audited for SOC 2 Type II and ISO 27001 compliance, among other certifications.

Authentication: Ai Media Group implements a uniform password policy for its customer products. Customers who interact with the products via the user interface must authenticate before accessing non-public customer data.

Authorization: Customer Data is stored in multi-tenant storage systems accessible to Customers via only application user interfaces and application programming interfaces. Customers are not allowed direct access to the underlying application infrastructure. The authorization model in each of Ai Media Group's products is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user's permissions against the attributes associated with each data set.

Application Programming Interface (API) access: Public product APIs may be accessed using an API key or through OAuth authorization.

Preventing Unauthorized Product Use

Ai Media Group implements industry standard access controls and detection capabilities for the internal networks that support its products.

Access controls: Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure. The technical measures implemented differ between infrastructure providers and include Virtual Private Cloud (VPC) implementations, security group assignment, and traditional firewall rules.

Intrusion detection and prevention: Ai Media Group implements a Web Application Firewall (WAF) solution to protect hosted customer websites and other internet-accessible applications. The WAF is designed to identify and prevent attacks against publicly available network services.

Static code analysis: Security reviews of code stored in Ai Media Group's source code repositories is performed, checking for coding best practices and identifiable software flaws.

Penetration testing: Ai Media Group engages qualified penetration testing service providers to perform penetration tests at least annually. The intent of the penetration tests is to identify and resolve foreseeable attack vectors and potential abuse scenarios.

Responsible disclosure: Ai Media Group invites independent security researchers to report security flaws to privacy@aimediagroup.com, and may offer a reward for valid, responsibly disclosed reports. The program helps Ai Media Group engage with the security community and improve product defenses.

Limitations of Privilege & Authorization Requirements

Product access: A subset of Ai Media Group's employees has access to the products and to customer data via controlled interfaces. The intent of providing access to a subset of employees is to provide effective customer support, to troubleshoot potential problems, to detect and respond to security incidents and implement data security. Access is enabled through "just in time" requests for access; all such requests are logged. Employees are granted access by role, and reviews of high risk privilege grants are initiated daily. Employee roles are reviewed at least once every six months.

Background checks: All Ai Media Group employees undergo a third-party background check prior to being extended an employment offer, in accordance with and as permitted by the applicable laws. All Ai Media Group employees are required to conduct themselves in a manner consistent with Ai Media Group guidelines, non-disclosure requirements, and ethical standards.

Transmission Control

In-transit: Ai Media Group makes HTTPS encryption (also referred to as SSL or TLS) available on every one of its login interfaces and for free on every customer site hosted on the Ai Media Group products. Ai Media Group's HTTPS implementation uses industry standard algorithms and certificates.

At-rest: Ai Media Group stores user passwords following policies that follow industry standard practices for security. Ai Media Group has implemented technologies to ensure that stored data is encrypted at rest.

Input Control

Detection: Ai Media Group designed its infrastructure to log extensive information about the system behavior, traffic received, system authentication, and other application requests. Internal systems aggregated log data and alert appropriate employees of malicious, unintended, or anomalous activities. Ai Media Group's personnel, including security, operations, and support personnel, are responsive to known incidents.

Response and tracking: Media Group maintains a record of known security incidents that includes description, dates and times of relevant activities, and incident disposition. Suspected and confirmed security incidents are investigated by security, operations, or support personnel; and appropriate resolution steps are identified and documented. For any confirmed incidents, Ai Media Group will take appropriate steps to minimize product and Customer damage or unauthorized disclosure. Notification to Customer will be in accordance with the terms of the Customer Terms and Conditions.

Availability Control

Infrastructure availability: The infrastructure providers use commercially reasonable efforts to ensure a minimum of 99.95% uptime. The providers maintain a minimum of N+1 redundancy to power, network, and HVAC services.

Fault tolerance: Backup and replication strategies are designed to ensure redundancy and fail-over protections during a significant processing failure. Customer data is backed up to multiple durable data stores and replicated across multiple availability zones.

Online replicas and backups: Where feasible, production databases are designed to replicate data between no less than 1 primary and 1 secondary database. All databases are backed up and maintained using at least industry standard methods.

Ai Media Group's products are designed to ensure redundancy and seamless failover. The server instances that support the products are also architected with a goal to prevent single points of failure. This design assists Ai Media Group's operations in maintaining and updating the product applications and backend while limiting downtime.

*All data is retained for the duration of client's engagement with Ai Media Group. Once the relationship is terminated, data is retained per table as follows for reports and audit purposes.