Updated: April 1, 2026

This policy applies to the information Placements, Inc. (“Placements.io”, “we”, “us”, “our”)
collects and receives from individuals (“Users” or “you”) who access and interact with the
Placements Service (defined below) located at https://app.placements.io. Placements.io is
committed to transparency, and we want you to fully understand how we may collect, use, and
share information relating to Users, and the choices that are available to you.

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This privacy policy does not govern (i) the collection and use of information about visitors to
our website (www.placements.io) – that information can be found here or (ii) our Customer’s
collection, use and disclosure of information through their Third Party Integration Partners
(defined below), which is governed by their own privacy policies and practices.

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About Us
Placements.io has developed a proprietary enterprise software as a service platform designed
for media publishers and advertisers (“Placements Service”). The Placements Service is
designed to streamline and automate certain manual business processes that customers
undertake in buying or selling advertising inventory. Placements.io directly integrates with
third parties such as Salesforce.com and Google Ad Manager (“Third Party Integration
Partners”). With the Placements Service, customer publishers or advertisers (“Customer”) can
create proposals and insertion orders, check inventory availability in real-time and push ad
campaigns directly into the ad server. The Placements Service also provides reporting and
analytics on both pipeline and actual delivery allowing Customers to have a better view into the
health of their business. The Placements Service further reduces the manual processes
required for invoicing by tying both 1 st and 3 rd party delivery data into the system for revenue
and billing calculations.

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Information We Collect
Placements collects certain information from Users that may be considered “personal data” or
personal information” under applicable privacy or data protection laws (“Personal Data”). In
particular, we collect general business information from Users such as name, email address,
phone, company name and title. We also collect identifiers such as your IP addresses and
cookie identifiers. We also collect information about your activity within the Placements Service
(collectively, “User Information”).

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The Placements Service does not directly identify any Personal Information of Customer’s end-
users. Rather, such data is aggregated and pseudonymous when ingested by the Placements

Service from Third Party Integration Partners, which means that it does not directly identify
people.

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How We Collect User Information
Manual Input
User Information may be provided directly into the Placements Service by a User.

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Cookies and Other Technologies
We also use cookies and other standard web technologies to collect information automatically
from your device when you use the Placements Service.

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We engage with Google Analytics and HEAP Analytics who process certain activity information,
including without limitation the date and time of visits, the pages viewed, IP addresses, links
to/from any page, and time spent within the Placements Service. Cookies also allow our servers
to remember your account information for future visits and to provide personalized and
streamlined information across related pages of the Placements Service.

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How We Use User Information
Placements.io processes Personal Data on the following legal bases:

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- Contract: To provide the Placements Service under the Master Services Agreement
executed between Customer and Placements.io, and to contact you about the
Placements Service or any other information requested by you.
- Legitimate Interests: To operate and improve the functionality of the Placements
Service; understand sources of traffic and transactions; compile statistics and conduct
research and development; prepare performance reports; and protect against
fraudulent, unauthorized, or illegal activity, where these interests are not overridden by
your rights.
- Legal Obligation: To comply with applicable laws, court orders, or regulatory
requirements.
- Consent: Where required by applicable law, including for certain cookies.

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Where we rely on legitimate interests, we have assessed that our interests are not overridden
by your privacy rights. You may request information about our legitimate interest assessments
by contacting us at legal@placements.io.

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Data Processing on Behalf of Customers
Where Placements.io processes Personal Data on behalf of a Customer pursuant to a Data
Processing Addendum, such processing is governed by the terms of that agreement.

Sharing of User Information
We may share User Information that we collect as follows:

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- Placements.io Affiliates: We share User Information with other companies within
Placements.io’s group of companies to use for any of the purposes described in this
Services Privacy Policy.
- Business Transfers: We may share User Information in connection with an actual or
proposed sale or transfer of all or a part of our business or assets, corporate merger,
consolidation, or bankruptcy.
- Vital interest, legal rights and compliance with laws. We may share User Information
with law enforcement, regulatory authorities, courts with competent jurisdictions,
emergency services or other necessary third parties for legal, protection, security, and
safety purposes, including:
       o to comply with laws or regulatory requirements and to respond to lawful
requests and legal process;
      o to protect the rights and property of Placements.io, our agents, customers, and
others, including enforcing our agreements, policies, and terms of use and
protecting our network and physical assets; and/or
       o to protect the safety of our employees and agents, our customers, or any
person.

- Vendors, partners and other service providers: We may share User Information with
our vendors and partners who perform functions on our or our Customer's behalf and
require access to such information to provide us with services or do work for us.
Examples include: analyzing data, fraud prevention, hosting data, engaging technical
support for our technology platform, and performing analysis related to our technology
platform and related services.

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Individual Rights
You have the right to request the exercise of the following individual rights where relevant:

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- To access information Placements.io maintains about you.
- To correct information Placements.io maintains about you.
- To request that Placements.io erase information Placements.io maintains about you.
- To restrict processing of information Placements.io maintains about you.
- To object to processing, or exercise your right to data portability.

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In order to exercise these rights you can contact us at legal@placements.io. Note,
Placements.io may be unable to facilitate these rights in all cases.

Security Measures and Retention
Placements.io maintains reasonable security measures to protect against the loss, misuse or
alteration of any personal information we maintain. However, Placements.io is unable to
guarantee that the reasonable security measures we employ will not be penetrated or
compromised for reasons outside of our control, or that your information will remain secure
under any and all circumstances. For more information about the technical security practices
related to the Placements Services, please contact us at legal@placements.io.

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We will store any Personal Information or User Information provided for as long as is necessary
to respond to your inquires, provide you with the Placements Service, Placements Application,
Placements System and/or Placements Support and in order to maintain our relationship with
you.

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International Transfers
We operate the Placements Service from servers located in the United States. Laws governing
the collection and use of data in the United States may not be equivalent to those in the
country where you reside.

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Regarding the transfer of Personal Information to countries outside the EU or United Kingdom,
we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the
Commission of the European Union or UK Government for international transfer of personal
information to controllers or processors established in third countries as the case may be, when
appropriate.

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Additional Terms
This Policy is effective as of the date listed above and remains subject at all times to the terms
and conditions of the Master Services Agreement executed between Placements.io and
Customer. We provide links to third-party sites or reference third-party data practices in this
Policy. These sites and practices are maintained by third parties. Please be aware that
Placements.io is not responsible for and cannot control the privacy and/or security practices of
these other linked sites or third parties. We suggest that you visit those sites directly for more
information on their privacy, security, data collection and processing policies, as they may differ
from this policy or the Placements Service. We are not responsible for any acts or omissions
committed by our Third Party Integration Partners and third party service providers, and are
unable to guarantee that the security measures we employ will not be penetrated or
compromised or that your information will remain completely secure under and any and all
circumstances. Any capitalized terms used in this policy, but not defined, shall have the
meaning as set forth in your Master Services Agreement with Placements.

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How To Contact Us

We may change this policy from time to time and will notify you of any such changes. If you
wish to contact us about this policy you can reach us by email at legal@placements.io or at:

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Placements, Inc.
Attn: Legal Department
900 Broadway, Suite 1002
New York, New York 10003
United States

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