PRIVACY POLICY
MCAP

August 2019

Introduction

This privacy policy is applicable to:

(a) MCap Media Limited, each company within its group of companies and each company within the MCap Holdings Limited group of companies (together, the MCap Group); and

(b) The user data processed by MTech Intelligence Limited (MTI) in respect of visitors to websites on which advertising is located which MTech has purchased on behalf of its clients.

This privacy policy will inform you as to how we look after your personal data when we collect it and tell you about your privacy rights and how the law protects you.

Part A of this privacy policy governs our processing of personal data which is subject to the jurisdiction of the General Data Protection Regulation 2016/679 (and all implementing legislation) (the GDPR) (such processing being EU Processing).

Part B of this privacy policy applies to our processing of data relating to users located outside of the EU, to the extent that such processing does not fall within the jurisdiction of the GDPR (Non-EU Processing).

Words and phrases defined in Part A of this privacy policy shall have the same meaning as given to them in Part A of this privacy policy when used in Part B of this privacy policy, unless defined otherwise therein, or the context requires otherwise.

· Important information and who we are

· Purpose of this privacy policy

This privacy policy aims to give you information on how MCap collects and processes your personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

MCap

This privacy policy is issued on behalf of the MCap Group so when we mention "MCap", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the MCap Group responsible for processing your data.

MCap’s primary business is that of a media finance company operating in the digital, outdoor and print media sectors. We work with agencies and media owners to drive advertising spend and assist media owners in managing and monetising their media resources.

MCap also operates a technology business in the digital advertising ecosystem through its subsidiary, MTI (the Adtech Business). MTI and its technology partners use data analytics to help its clients (advertisers, media agencies and brands) to advertise their advertisements on various websites that allow third party advertising (such parties being Publishers).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address: data@m.capital

Postal address: MCap Media Limited, 6th Floor Castle House, 75 Wells Street, London W1T 3QH

Telephone number: +44 (0)20 76121700

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. As the standards governing Internet privacy continue to evolve, MCap may find it appropriate or necessary to update this privacy policy from time to time. As a result, we reserve the right to change this privacy policy at any time and shall post such changes on MCap’s website. Our website will state the date the privacy policy was last updated. We encourage you to review the privacy policy whenever you use our website to make sure you understand how your information will be used. If we materially change how we use your personal information, we will notify via a prominent notice on the website prior to implementing the change.

This version was last updated on 26 June 2019. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

PART A – EU PROCESSING

1. The data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect and process personal data personal data about visitors to our website and those of each of the companies within the MCap Group, as well as business contact data relating to the representatives of our customers, suppliers and representatives, and visitors to our offices.

We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and pre-recruitment checks.

· Contact Data includes email and postal address and telephone numbers.

· Financial Data includes bank account details.

· Transaction Data includes details about payments made between you and MCap.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

· Profile Data includes your security information (username and password) that you may set with us in relation to your use of our website or other technology platforms operated by us.

· Usage Data includes information about how a visitor to our website uses it.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If a user fails to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. How is your personal data collected?

Section 2.1 of this privacy policy sets out how we collect personal data for use in respect of the primary business of the MCap Group and section 2.2 of this privacy policy sets out how we collect personal data for use in respect of the Adtech Business.

2.1 How we collect data for use in respect of the general business of the MCap Group.

We use different methods to collect data from and about you including the following methods:

· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create an account on our website, request marketing from us, or submit HR information to us (such as providing CVs etc). We will also record our employees entry into and exit from our offices and may use CCTV for this purpose and will from time to time collect contact details of business associates on business cards provided to us.

· Regulatory interactions. You may provide us with detailed Identity Data in the course of our completing KYC exercises required to be completed for us to comply with anti - money laundering legislation. We may also be required to collect personal data from you in the context of undertaking confirmation of your status as a Financial Conduct Authority Approved Person, or while carrying out fitness and properness checks.

· Automated technologies or interactions. As you interact with our website, and users may interact with Publishers’ websites, we will automatically collect Technical Data about the applicable user’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the sections of this policy regarding the Adtech Business and our cookie policy for further details.

· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

· Technical Data from the following parties:

(a) analytics provide

(b) advertising networks; and

· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

· Identity and Contact Data from data brokers or aggregators.

· Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

We may collect data about your health in the context of your employment or engagement by MCap, as well as any criminal convictions or offences that you disclose to us. If we collect this data, we will keep this data securely and in accordance with legal obligations and will not disclose this data to any third party without your consent, unless obliged to do so by law.

2.2 How we collect data for use in respect of the Adtech Business.

Publishers’ websites usually allow third parties, such as MTI or its technology partners, to set cookies or similar applications when on users’ devices or browsers when they visit these websites.

MTI and its technology partners use cookies and similar applications to develop marketing insights about user preferences, sometimes in combination with other data sets, in order to better match advertising content with user preferences. We or our technology partners will collect and analyse the data from these applications and may combine such data with aggregated data obtained from social media companies and market research firms, and user-level data from other advertising technology companies that support our services in various ways, such as fraud prevention through the detection of ‘bots’.

In operating the Adtech Business, MTI and its technology partners will process various categories of data at the user level, including the following:

(a) IP addresses, which are collected in order to assist us to understand the broad location of the user.

(b) Device ID (when users access websites on mobile devices).

(d) Timestamp on accessing the website and the website URL.

(e) Enrichment data collected about you from third parties, such as Nielsen & Eyeota.

(f) Tweets and Twitter handles, made publicly available via the Twitter platform.

(g) User interactions with the ad placed (whether the user actively clicks on the advertisements, previous user acquisition behaviour).

(h) Cookie technology data derived from cookies placed on users’ browsers or devices to assist in the advertisement delivery process.

Although we do not collect information that directly identifies individuals by name or physical address, we collect user’s IP information and other information about them, which may cause this information to become personal information for the purposes of the GDPR. For example, based on a user’s historic browsing behaviour, we may map an IP address to a city or geographical region and other information such as weather in that region, in order to predict users’ future buying decisions. Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

3. How we use the personal data that we collect: Purpose and Lawful basis for collection

Section 3.1 of this policy will set out how we use the data we collect in the operation of the primary business of the MCap Group and section 3.2 of this policy will set out how we use the data we collect in the operation of the Adtech Business.

3.1 Data collected for use in respect of the primary business of the MCap Group

We will only use personal data when the law allows us to. Most commonly, in operating the primary business of the MCap Group, we will use collected personal data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you. This means our processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. In these circumstances, legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

· Where we need to comply with a legal obligation. This means MCap’s processing of your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, except during our operation of the Adtech Business (please see below), we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we use your personal data

The table below provides you with details of how we will use your personal information and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your personal data.

3.2 Data collected for use in respect of the AdTech Business

We collect user-level personal data in relation to visitors to Publishers’ websites so that such visitors can see advertisements displayed on these websites which we think are relevant to them based upon their browsing behaviour and interests. This enhances the user’s experience while at the same time making our clients’ advertising campaigns more efficient and effective.

We use data analytics to predict user interests based on machine-learning techniques involving the use of algorithms. Our technology partners regularly review the algorithms that we use in order to ensure they are properly adjusted and error-free and use a “Pixel Implementation” policy which provides, among other things, that we will not target children or vulnerable adults or collect any special categories of personal data about users.

Primary Purposes

When a user visits a Publisher’s website with which MTI is associated, they will see a message asking them if they agree to allow the website publisher’s and third-party cookies to be set on their device and collect information from it when they first visit it. If the user agrees to the application of cookies, they will then be asked whether they consent to the processing of the information collected for each of the following purposes:

(a) Ad personalisation: The personal data we collect is used to personalise ads that users see over time on other sites. We will use the personal data we collect to infer the user’s interests and place ads that we believe may be of interest to the user.

(b) Ad selection, reporting and delivery: We collect information about what ads were shown, how often and when and where they were shown, whether the user clicked on them and made a purchase. This information is used to measure the effectiveness of the ads presented.

(c) Content delivery, selection and reporting: We collect and analyse information about each user’s interests and what content is shown to the user, how often, when and where, and whether the user clicked on what was shown. We do this in order to be able to adjust the content displayed to the user to be more relevant to the user.

(d) Measurement: We collect information on the manner in which visitors to the Publishers’ websites use content in combination with previously collected information. We use this data to understand and report on their use of content to our advertising clients or for our internal quality assurance purposes.

In the process of using data for the above purposes, MTI also employs the following technical features: (i) matching data to offline sources, (ii) linking devices and (iii) precise geographic location data.

When a user agrees to the placement of cookies and one or more of the identified processing activities, we will receive a message from the Publisher’s website where the visitor’s selection has been made, notifying us that we have permission to set a cookie, collect information on the user’s device and use it for the agreed purposes.

Consent
MTI will not process the personal data of users of Publishers’ websites unless it can be evidenced that in each case the relevant Publisher has first obtained the relevant user’s permission. This is usually achieved by means of a pop-up window that enables users to manage their preferences in regard to cookie application and related data processing.

Legitimate interests

Although it requires a user’s consent for it to be possible for us to carry out, we also conduct the following processing of personal data relating to users of Publishers’ websites on the basis of such processing being carried out on the basis of it being in our legitimate interests (see section 3.1 above) to carry such processing out, for the following reasons:

(e) Fraudulent website traffic: We also process personal data in order to detect the use of internet “bots” or similar functionality intended to distort the popularity of websites and digital ads by simulating human browsing activity. If a user agrees to the placement of a cookie and accepts the processing of their personal data for one or more of the purposes described above, our ability to detect this type of fraudulent behaviour is important to ensure that the data we rely on to cater to user preferences is not distorted by false inputs. We therefore use a third-party vendor to assess whether the IP addresses that we are processing are associated with fraudulent activity.

(f) Analysing social trends: We also process personal data in order to analyse trends in social media activity. This involves analysing common keywords that appear in public posts made available on the Twitter platform and producing aggregated insights from these to inform our advertisers about current social trends. We may use Twitter handles to identify trends relating to companies and popular personalities.

Should a user wish to object to our processing of their personal data for these purposes on the basis of it being in our legitimate interests to do so, they may do so by contacting our data privacy manager as indicated in the introduction to this privacy policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

Where necessary for the provision of our services, or as required by regulations we are subject to, we may share or disclose your information with third parties as follows:

· to businesses that are legally within the MCap Group, or that become part of that group of companies;

· to technical support providers, such as Appnexus & Google who assist with the placement of cookies, the collection of data from cookies and the IT structure of the MCap Group and its businesses;

· to providers that help us generate an ad image and content and collate information on viewing the ad on the web, such as Sizmek, Jivox and Appnexus;

· to ad verification partners, in particular Integral Ad Science (IAS), that help us to verify that users are genuine and not fraudulent ‘bots’ through analysis of browsing information they collect from users’ IP addresses;

· to our other IT providers, back office services providers, third party software providers to provide and maintain the provision of the services;

· to our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to advise us;

· to your professional advisers where you have provided your authority for us to share information with them;

· if required to do so, to the Financial Conduct Authority, or any relevant regulatory authority where they are entitled to require disclosure; and

· to UK and overseas tax authorities, for example HM Revenue & Customs.

We may also disclose your personal data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We will only share your personal data with third parties in the course of our utilising it for the purposes that we have collected it. If we wish to disclose your personal data to a third party for a purpose that does not correspond with the purpose for which you have collected the applicable data, we will notify you first and explain the legal basis for our disclosure of your data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We occasionally may need to share your personal data within the MCap Group. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

· where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

· where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield data security organisation which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In relation to the Adtech Business:

· Raw data that MTI collects about user online activities is kept for no longer than 180 days from the date collected and is stored in a secure environment. The user-level data is either anonymised or aggregated after 180 days, which means the information is expressed only in a summary form about user behaviour representing large groups of individuals.

· Anonymous data may be kept at MTI for 2 years and aggregated information relating to financial performance stored for up to 7 years for accounting and audit purposes. During the initial 180 day period, the information about user online behaviour is used to better target the ad campaigns and adjust the audience to ensure the ad is displayed to user groups that may be most interested in the product or service advertised.

· The data collected as part of the ad campaign may be used to develop insight reports for clients of the Adtech Business concerning advertising trends and campaign results. These reports are based on data that is provided in an aggregated form and does not allow for the identification of individuals.

In some circumstances you can ask us to delete your data: see paragraph 8 (Your legal rights) below for further information.

. Your legal rights

The law guarantees you rights in relation to your personal information. We have set out details of your rights below under individual headings.

· Access to information: You always have the right to ask whether or not we hold information about you. And if we do, what the information is, why we’re holding it and the ways it’s being used. You’re also entitled to a copy of the information.

· Rectification of information: We always want the information we hold to be up to date and accurate. If any of the information we hold is either incorrect or out of date then please tell us and we’ll fix it.

· Erasure of information: You have the right to ask us to erase or delete information where you consider there is no longer any justification for us holding it, either because:

- the information is no longer needed for the reason we collected it;

- we held and used the information based only on your consent, which you have now withdrawn;

- you have previously objected to a way in which we use information;

- we have been using the information unlawfully; or

- there is a legal obligation on us to erase the information.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

· Objecting to us using your information: You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

· Restricting some uses of information: In certain circumstances you have a right to limit the use of information by us. This may arise where:

- you have challenged the accuracy of the information we hold and we are verifying this;

- you have objected to a use of information and we are considering whether your objection is valid; or

- we have been using your information unlawfully but you want us to continue to hold the information rather than erase it.

· To request a transfer of personal data: You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (eg another company providing similar services). You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

· To object to decisions based on automatic decision making: If we made a decision about you based solely by automated means (ie with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to object to that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted.

· To withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

PART B - NON-EU PROCESSING

1. Key Terms

Below is a summary of key terms applicable to user privacy in relation to Non-Eu Processing:

Information NOT Collected – PII - We do not collect personally identifiable information (data collected with an intention to identify and contact a person such as name, address, telephone number or e-mail address) (hereinafter PII Information).

Information Collected – Non-PII Information - The non-personally identifiable information (Non-PII Information) we collect may include as an example, IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

How Used - We may use your Non-PII Information for the following general purposes: improved targeting and optimisation to deliver more relevant advertisements.

Sharing Your Information - We may share your Non-PII Information with third party service providers we have contracted with.

Security - We use reasonable and appropriate security measures to protect your Non-PII Information.

Retention - For Non-EU Processing, most of our Non-PII Information is aggregated after 30 days, with some of it being held for a maximum of 2 years.

Contact Us - If you have any questions relating to this privacy policy please email our data privacy manager at data@m.capital

2. Information we collect

Non-PII Information

(a) As part of our on-going efforts to deliver the most applicably targeted advertisements to our clients, MCap may through its technology partners collect and use log files, web beacons, cookies, device information, location information, and information available through other technologies, each as further defined below, to collect data from browsers and devices, advertiser sites, third party sites, and mobile applications. The Non-PII Information collected is used to inform our propensity models, which are then used primarily for ad targeting purposes, and as otherwise noted below in the section titled “How we use your information.” Such Non-PII Information enables us to determine which advertisements perform well, allows us to more effectively match advertisements and website content to your interests, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding the use of MCap’s services.

(b) “Cookies” are files (e.g. HTTP cookies) that are stored on your Internet enabled device, which may include, for example, your computer, tablet, smartphone or other PDA. We may use Cookies for purposes that include estimating the total reach of an advertising campaign, as well as frequency of display. Cookies allow advertisers to determine with greater accuracy the composition of the audience they reach. Cookies are also used to improve the user experience online. They may be used to control the delivery of a series of advertisements to a web browser, to limit the number of times a web browser receives any one advertisement, and to provide users with more relevant advertising.

(c) There are two classes of Cookies based on how long they remain on your system: (i) “Session Cookies” are used only during your visit to the applicable third party website and are erased once you close your browser, and (ii) “Persistent Cookies” can remain on your browser for up to 2 years from your last visit to the applicable third party sites (but more commonly 90 days) and enable us to remember you on subsequent visits to the applicable third party websites and provide more relevant content to you on such websites. A useful resource on understanding Cookies may be found at http://www.allaboutcookies.org.

(d) “Device Information” is information we automatically collect and store related to the device used when you visit third party websites and mobile applications, including the type of device you are using (e.g., an iPhone), certain device identifiers that are unique to the device you are using, and your internet service provider.

(e) “Location Information” is information acquired from your device’s global position system (GPS) signal, WiFi networks proximately accessible to your device, nearby cell towers, and other available location data. When you use location enabled services on a third party website or mobile application with location-enabled services, this type of information may be made available to us.

(f) “Other Technologies Information” relates to information that is now or may in the future become available through new technologies and the Non-PII Information you share or otherwise make available.

3. How we use your information

3.1 Information used and shared by MCap

(a) MCap will only use the Non-PII Information we collect about you for the limited purposes provided for in this Privacy Policy. These include using and sharing Non-PII Information:

(i) to deliver or assist our clients in delivering targeted ads to potential customers or other individuals;

(ii) to enable third party service providers to assist or facilitate in the services we provide to our clients;

(iii) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law;

(iv) to enforce our terms of use or to protect our rights;

(v) to protect the safety of members of the public and users of the service;

(vi) with other MCap entities, affiliates, and third-party marketing partners (including advertisers and publishers) for marketing purposes;

(vii) with vendors, administrative service providers, technology providers, and carefully selected partners for data validation, enhancement, information verification and suppression services; and/or

(viii) for any other purpose for which you provide consent. We also may share Non-PII Information with advertisers, publishers and other third parties for marketing purposes, but such Non-PII Information does not include PII Information.

(b) When targeting advertising campaigns on behalf of our clients, we may or may not choose to target users based on their Non-PII Information. This includes, but is not limited to, IP host address, the date and time of activity online, the pages viewed, browser type, referring URL, Internet Service Provider and operating system. We do not collect PII Information such as name, address, phone number, email address, credit card information, financial account information, or anything else that can personally identify individuals on behalf of our clients. Our use of Non-PII Information when targeting advertising campaigns is to ensure that MCap delivers the most appropriate and tailored ads to audiences online.

(c) Advertising campaigns delivered on behalf of our clients may include “interest-based” ads, which utilize Non-PII Information we have collected or received about your activities and interests across your linked devices or in connection with a single online action, such as visiting a particular website. This type of interest-based advertising is sometime referred to as “retargeting.”

(d) In connection with this type of interest-based advertising, we may use propensity models to predict users that may be interested in certain categories or “segments.” For instance, if you have recently visited a real estate website and a mortgage website, you may be placed in a “prospective homebuyer” segment, which may result in advertisers interested in this segment, such as a real estate broker, to show you, along with others in that segment, ads related to their offerings.

(e) In some cases, we may use Non-PII Information, non-sensitive, health-related topics, such as data related to visiting websites about acne or dry eyes, to create segments which our advertisers may use to retarget the users in that segment. We create propensity models and use said models for targeting or retargeting. These segments are created using algorithms to identify the set of consumer (non-health) variables most highly correlated with the profile of individuals with the specific health condition. No health data is ever used in the application of the models, making the approach in compliance with the Health Insurance Portability and Accountability Act of 1996 and privacy-safe.

3.2 Information collected by third party websites

(a) Please be aware that the websites and mobile applications of our advertiser clients, as well as the websites and mobile applications on which we place advertisements either on our own behalf or on behalf of our clients, or any third party websites or mobile applications linked to one of our websites or with which have agreed to place a cookie on their site on our behalf or on behalf of our advertiser, may collect Non-PII Information from you.

(b) Such information may include non-personally identifiable information through the use of Cookies and other technology (as described above), and with respect to third party sites and mobile applications, any personally identifiable information you may choose to give in registering and transacting with such website. This data, excluding PII Information, may be combined with data collected by MCap and used for ad targeting purposes.

4. Your Choices

4.1 Web Browser Opt Out

MCap serves cookies, and works with partners to serve cookies, in order to provide relevant advertising. View the chart below for opt-out options for advertising targeting undertaken by MCap and its group companies:

Served by - Opt-out Options

Appnexus - http://optout.networkadvertising.org/?c=1#!%2F

DBM - http://adssettings.google.com

Jivox - http://jivox.com/privacy/

Please note that opting out does not block ads, rather it stops tracking.

Alternatively, visit www.youradchoices.com

If you have multiple internet browsers or users on the same computer or device, you will need to perform the optout operation for each browser, device and/or user. If you or your privacy software deletes the opt-out Cookie from your computer, browser or device, you will need to repeat the process.

4.2 Mobile Application Opt Out

Mobile devices allow users to opt-out of the collection of usage information within their mobile apps.

To opt out of personalised interest-based advertising on your mobile device(s), please take the following steps:

On Android devices, go to Settings, and then select the option Google. On the resulting screen select Ads, and you will see the option to opt out of ads personalisation.

On Apple devices, go to Settings, and then select the option Privacy. On the resulting screen select Advertising, and you will see the option to turn on limited ad tracking.

4.3 Location Opt Out

By updating the location preferences on your device, or by updating the settings for individual apps, you can block the collection of location data.

5.4 Multiple Device & Browser Opt Out

We may use cross-device mapping services in order to link devices that belong to the same user or household. Users can opt-out of the collection of information for each device and browser by taking the steps mentioned above (i.e. opt-outs are not effective across multiple devices, even if said devices are linked for advertising purposes). However, opting out of the collection of information for one device or browser will not result in you being opted-out of the collection of information for other devices or browsers. As such, you may need to opt-out of multiple devices and browsers.

Please note that use of the opt-out Cookie will affect our ability to provide you content and advertisements that will more effectively match your interests and may prevent us from controlling the frequency with which you may view any particular advertisement. Please report any problems related to the opt-out process, or any complaints with regards to online behavioural advertising data and its use, to our data privacy manager at data@m.capital.

6. Retention and Data Security.

6.1 Retention

We retain Non-PII Information for use to more effectively match advertisements and website content to users’ interests. Most of this data is aggregated or deleted after 30 days; some data may be retained for up to 2 years in a less accessible infrastructure, not used for targeting purposes.

6.2 Confidentiality and Security

We maintain physical, electronic and procedural safeguards that comply with applicable law to guard your information. While we take precautions against possible breaches in our service and customer databases, no website or Internet transmission is completely secure. Accordingly, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of our service and our websites and mobile applications is at your own risk.

6.3 Representations

YOU THE USER UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose Non-PII Information you supply to us with regard to:

(a) the purposes for which such third party’s Non-PII Information has been collected;

(b) the intended recipients or categories of recipients of the third party’s Non-PII Information;

(d) how the third party can access and, if necessary, rectify the data held about them

7. MISCELLANEOUS

7.1 Children’s Privacy

(a) MCap is very sensitive to the issue of the privacy rights for children. We comply with the Children’s Online Privacy Protection Act (COPPA). For more information about COPPA and children’s privacy, please visit https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

(b) When we use the term “parent” below, we mean to include legal guardians. MCap’s websites, mobile applications and services generally are neither developed for, nor directed at, children. MCap does not knowingly collect, use or disclose personal information or PII from children under the age of 13 without prior parental consent or in accordance with applicable law.

PRIVACY POLICY MCAP

PRIVACY POLICY
MCAP