ElementX Privacy Policy

1. Introduction

This Privacy Policy describes the types of personal information that Element X Digital PTE. Limited (referred to as "ElementX", "EX2", "we", "us" or "our" in this Privacy Policy. Please note that Element X and EX2 will be used interchangeably henceforth.) collects from and about you, how we may use and disclose such personal information, and your choices and legal rights with respect to such personal information.

When you engage with ElementX, you agree to our collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree, please do not use our website or engage with ElementX services.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at privacy@elementx.co or write to our Head of Operations, Jils Joseph at ElementX, 60 Paya Lebar road, #07-54, Paya Lebar Square, Singapore 409051

2. What personal information does ElementX collect about me?

We collect personal information from and about you as described in this section. For purposes of this Privacy Policy, "personal information" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes "personal data" or similar terms used in applicable data protection laws.

A. ElementX Services

There are several sources of personal information we collect in order to provide ElementX services to our customers:

• Third Party Data Providers: ElementX collects personal information about you from third-party data providers based on your engagement with third-party apps or advertisements. Our third-party data partners provide your personal information to us only where you have consented to such collection and disclosure to us.
• Ad Exchanges: ElementX collects personal information about you when we bid on behalf of our customers to show you advertising based on your interests and preferences. We use the personal information we receive in a bid request for advertising placement, measurement, and audience profiling purposes, consistent with any consent instructions we receive from publishers or their agents or representatives.
• Pixel: ElementX collects personal information on our customer websites or advertisements integrated with our pixel. We use our pixel to identify you and your browsing session, and to provide measurement insights to our customers. Our customers are responsible for collecting consent for the use of cookies and pixels on their websites or advertisements where required by applicable law.
• Trusted Sources: ElementX collects personal information from trusted third-party sources, such as data brokers, to help us identify you and your browsing session. In certain jurisdictions, we may collect your personal information from third-party sources and link this information to the information that we collect to help us identify you.
• Aggregate Data: ElementX uses aggregate information that we receive from publicly available sources, social media companies, census data providers, public directories, or other data brokers to build our products and services. We link aggregate information or trends to personal information we have collected about you as part of the services we offer to our customers.

What is the business or commercial purpose for collecting personal information?

• Targeted advertising services. We help our advertising and publisher customers provide more relevant advertising and content that is aligned with users' interests. We may group users into audiences, such as sports fans, car enthusiasts, movie goers, travelers, etc., and measure the effectiveness of campaigns.
• Cross-device advertising. In some cases, we can infer that two different devices are used by the same user, we can then use that information to deliver targeted advertising across multiple devices.
• Data intelligence services. We provide personal information, including precise geolocation information, that we collect along with aggregate reports and actionable insights to our customers. We provide customers with trend and statistical analyses, such as for identifying and optimizing trade areas and business locations, and for helping our customers make informed business decisions about consumer behavior with trend and movement information. We provide actionable insights, patterns and commonalities to enable our customers to evaluate products and services they offer, such as enabling engagement with audiences and improving user experience of their apps and websites.
• Improving our services. We use your personal information to improve the way we work, improve our services, and provide additional services such as insights.

B. ElementX Website and Marketing Communications

There are several sources of the personal information we collect from and about you as a customer or potential customer:

• Website & Marketing: ElementX collects personal information when you visit our website, read our marketing communications, or engage with our brand as a customer or potential customer. We collect personal information directly from you when you choose to share personal information with us. We also automatically collect personal information when you visit and browse our website. We collect personal information in this context to help visitors to our website, customers, and potential customers understand our products and services.
• Lead Sources: ElementX collects personal information about you from trusted sources to help reach potential customers. We use lead generation services to help reach potential customers.
• Cookies: We may place cookies and use similar online tracking technologies on our website, and in email communications, and with your permission where required by applicable law. A cookie is a text file containing an identification number which, when the website is used, is transmitted to the user's computer together with the other data actually requested and stored there. The file is kept there for later access and serves to authenticate the user. You can choose to disable cookies, but this may limit your use of certain features or functions on our website or service.

C. Combination of Personal Information

We may combine the personal information we receive from and about you from various sources, including personal information that identifies you personally or is associated with your device or internet activity.

D. ElementX as a Service Provider

ElementX empowers our customers to collect and analyze personal information and send or display targeted messaging and advertising. For example, ElementX's customers may collect personal information directly from you on their websites or apps and leverage ElementX services to analyze the personal information or use the personal information for other business or commercial purposes. When we handle this personal information merely as a vendor operating on behalf of our customers (or as a "processor" or "service provider" as these terms are used in applicable privacy laws), we do not describe these activities in this Privacy Policy.

4. What lawful basis do you rely on for using my personal information?

Whenever ElementX relies on your consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time. You may do so by emailing us at privacy@elementx.co. We may take steps to verify your identity before complying with your request, including asking you a series of questions about your previous interactions with us. Any such withdrawal of consent will not affect the lawfulness of processing conducted before the withdrawal.

5. With whom do you share my personal information?

We may disclose each category of your personal information to the following categories of recipients:

• ElementX Group Companies: ElementX will disclose your personal information within the ElementX group of companies for the purposes identified above.
• Our Service Providers: ElementX will disclose your personal information with companies that help us run our business or provide business, technical, administrative, analytics, or marketing support by processing personal information on behalf of ElementX for the purposes identified above.
• Government, Law Enforcement Agencies or Regulatory Bodies: ElementX may disclose your personal information to applicable government, legal agencies or regulatory bodies in order to comply with applicable laws and investigations or to respond to a court order, judicial or other government subpoena.
• Acquiror or Merger Entity: ElementX may transfer information, including any personal information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
• Additional Data Sharing: ElementX may also disclose your personal information to other third parties with your consent or if it believes that it will protect ElementX, you or any other person or third party or as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

In addition, we may disclose the categories of personal information that we collect in connection with the ElementX website or our marketing efforts (as described above in Section 2(A)) to the following categories of recipients:

• Our Marketing and Advertising Partners: We disclose your personal information to third parties for marketing and advertising purposes, including social media platforms, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.
• Your Employer: If you are using an email address that is associated with a business domain (e.g., yourname@businessname.com) to access the website, we may provide your personal information to that business to solicit business.

Finally, we may additionally disclose the categories of personal information that we collect in connection with offering the ElementX services (as described above in Section 2(B)) to the following categories of recipients:

• ElementX Customers, for the provision of the Services: ElementX will disclose your personal information, including precise geolocation information, to our customers subject to our Sensitive Data Policy, including for purposes of serving targeted advertising, measurement, matching, audience profiling, generating reports, and otherwise providing our services. We contractually require our customers to comply with applicable data protection laws and advise our customers of prohibited uses of our platform, services, and products, which include (a) employment, credit, or health care eligibility, (b) insurance eligibility, underwriting, or pricing, or (c) unlawful tracking or surveillance of individuals.
• Our Business Partners: We disclose your personal information to other companies with whom we partner that support our provision of services to our customers.

We may disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your personal information.

Certain disclosures may be considered "sales" or "shares" of personal information under applicable U.S. state privacy laws. Details on how to exercise your legal rights with respect to such "sales" or "shares" can be found in the "Your Privacy Rights and Choices" section below.

Please note that we may de-identify or aggregate personal information so that it will no longer be considered personal information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.

6. Links to third-party websites, applications and services

The website provides links to third-party websites, applications, including social media pages, integrated social media tools or "plug-ins," such as social networking tools. We do not own or have any control over the privacy practices of these third parties, and they are not covered by this Privacy Policy.

If you decide to use any of the links available on the website, you should review their privacy notices to learn about their data practices. If you use these tools to share personal information or you otherwise interact with these features, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with us and the general public.

7. How long do you keep my personal information for?

We retain personal information for as long as necessary for the purposes for which it was collected or as otherwise required by applicable legal, accounting or regulatory requirements. What this means in practice will vary among different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information.

8. How is my personal information protected?

The security of your personal information is important to us. ElementX has implemented security measures to protect the information in our care. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

9. Accessing your personal information

If you provide your personal information and you wish to update, correct, or delete inaccuracies within that information, you may contact us as at privacy@elementx.co We will respond to your request within a reasonable timeframe.

10. Information relating to children

ElementX does not knowingly collect or sell/share personal information from anyone under the age of 18 through the website or our products and services. If you are below the age of 18 years, you should not use this website or our products and services or provide any information about you to us. If we are made aware that we have received personal information from someone under 18 years of age, we will use reasonable efforts to immediately remove that information from our records.

11. Where do you store and transfer my personal information?

We store your personal information on our servers and third-party servers which are based throughout the world.

For individuals in the EEA, UK and Switzerland, we may need to transfer your personal information outside of the EEA, UK and / or Switzerland to provide our products and services.

Whenever we transfer your personal information outside of the UK, Switzerland and / or the EEA, we ensure it receives additional protection as required by law, including by entering into approved standard contractual clauses.

For residents in Singapore, every time your data is shared with us, we ensure that the transfer is according to the requirements prescribed under the domestic regulations, to ensure that the standard of protection we provide to your personal data is comparable to the protection under the PDPA, unless exempted by the PDPC. For more information on this, please contact us at privacy@elementx.co

12. Your Privacy Rights and Choices

You have the ability to make certain choices about how we use your Personal Information, as follows:

A. Opt-out of Sales/Sharing and Targeted Advertising

We use and disclose to third parties personal information for their analytics and advertising purposes. Accordingly, you may have the right to opt out of the "sale" or "sharing" of your personal information, or the use and disclosure of your personal information for "targeted advertising" (as these terms are defined in applicable law).

To exercise your right to opt out, please click the "Do Not Sell or Share My Personal Information" button at the bottom of our website homepage, or you can email us at privacy@elementx.co.

Submitting an opt-out request does not require you to create an account with us.

Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including ElementX. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.

You may opt-out of interest based advertising by ElementX's third party partners by clicking here.

B. Limit the Use or Disclosure of your Sensitive Personal Information

As described above in Section 3, we collect and process "sensitive personal information" (as this term is defined in applicable law) that we collect from and about you. You may request to limit the use and disclosure of this sensitive personal information solely for ElementX's business purposes (and not for any other purposes) at any time by clicking the "Do Not Sell or Share My Personal Information" link here. When you submit a request to limit how we use or disclose your sensitive personal information, we will not use your sensitive personal information for the purpose of inferring characteristics about you.

C. Data Subject Privacy Rights

In accordance with applicable data protection law, you may have certain rights in relation to your personal information, including:

• Right to Access: You have the right to request access to, or copies (and transmission) of, the personal information we hold about you and the purposes for which we are using it. In some jurisdictions, this right extends to know the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties to whom we disclose personal information.
• Right to Rectify: You have the right to correct inaccurate personal information that we have collected from and maintain about you, subject to appropriate verification.
• Right to Erase: You have the right to erase personal information pertaining to you, under certain conditions. We will assess any deletion request after verifying your identity and work to respond within one calendar month, and let you know if we need additional time.
• Right to Object: You have the right to object to processing the personal information we process, under certain conditions.
• Right to Restrict: You have the right to restrict the processing of your personal information, under certain conditions.
• Right to Data Portability: You have the right to receive the data we have collected from you. Under certain conditions, you may request that we transfer your personal information to another organization, or directly to you.
• Right to Lodge a Complaint: You have the right to file a complaint with the supervisory authority in your jurisdiction.

At any time, you may request or assert any of the rights above by emailing us at privacy@elementx.co. We may take steps to verify your identity before responding to your request, including asking you a series of questions about your previous interactions with us. Submitting a request does not require you to create an account with us.

Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent's authority to make the request) and confirm the personal information we maintain relates to you. You may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@elementx.co.

We will not discriminate against you if you decide to exercise your data subject rights.

We do not carry out any automated decision-making that produces legal effects or similarly significantly affects you.

If you believe there has been a violation of your privacy rights, please contact us or the supervisory authority. UK residents also have the right to lodge a complaint with the Information Commissioner's Office (https://ico.org.uk/), the supervisory authority for data protection issues in the UK. If you are based in the EEA you can find your relevant supervisory authority here. In Switzerland, the relevant supervisory authority is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/de/home.html). If you are based in Singapore, the PDPC is the relevant data protection authority. You can contact the PDPC by clicking here.

Agent Requests: Only you, or someone legally authorized to act on your behalf, may submit a request related to your personal information. You may also submit a request on behalf of your minor child, although as noted, we do not knowingly collect any information about individuals under 18 years of age. Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf. ElementX retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

13. Changes to this Website Policy

This Privacy Policy is subject to change from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.