GRABTAP PRIVACY NOTICE

1. HOW WE COLLECT AND USE PERSONAL INFORMATION

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

We and our third-party providers may use (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services and to provide stream data (such as channel information and subscriber information). It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Policy.

3. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your personal information with:

• Other companies owned or controlled by GrabTap, or under common ownership and control as GrabTap. These companies will use your personal information in the same way as we can under this Privacy Notice.
• We may disclose personal information about you to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. This may include sending emails, processing payments, providing customer service, or providing web hosting and analytical services.
• Ad networks and online advertising partners with whom we may share personal information or may permit they collect personal information from you directly on our websites, to facilitate online advertising on third party platforms, such as search engines and social network advertising providers to serve targeted ads to you, or to groups of other users who share similar traits, such as likely commercial interests and demographics. For more information, including how to opt out of interest-based advertising, please see Third-Party Data Collection and Online Advertising below and our Cookie Policy.
• Our business partners, who will use the information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
• Other parties in connection with a corporate business transaction or potential transaction where GrabTap merges with another organization, files for bankruptcy, or sells some or all its assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• Third parties, such as legal advisors and law enforcement, as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or other agreements or to protect the security or integrity of the GrabTap services, including to prevent harm or financial loss, or in connection with preventing fraud or illegal activity; (c) to exercise or protect the rights and property of GrabTap, our Clients, visitors, or others; (d) to protect the health and safety of us or others; or (e) as otherwise required by applicable law.
• With third parties or publicly with your consent or direction.

4. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see our Cookie Policy to learn how you can opt out of interest-based advertising.

5. CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

• Email Communications Preferences. From time to time, we may also send you emails regarding updates to our Service, products or services, notices about our organization, or information about products/services that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the "unsubscribe link" provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly using the information provided in the Contact Us section, below. We will review your request and may require you to provide additional information to identify yourself. We may not be able to modify or delete your information in all circumstances.

6. DATA RETENTION

We will usually store the personal information we collect about you for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

For example, if your personal information is subject to the EU GDPR or UK GDPR, the criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

• Contract. Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
• Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
• Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
• Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
• Legal Claim. We may need to apply a "legal hold" that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain personal data supplied when joining our services, including complaints, claims and any other personal data supplied during the duration of an individual's contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise, or defence of legal claims.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.

7. CHILDREN'S PERSONAL INFORMATION

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we have collected has been provided by a child under the age of 13, we will promptly delete that personal information.

8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Service may include links to third-party websites, plug-ins, and applications that we do not own or operate, including, but not limited to, Twitch and YouTube. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party's rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.

9. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to change this Privacy Notice from time to time at our sole discretion. We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your GrabTap account and/or by placing a prominent notice on our website. It is your responsibility to review this Privacy Notice periodically. When we do change the Privacy Notice, we will also revise the "last modified" date.

10. CONTACT US

If you have any questions regarding this Privacy Notice, or any of our services, please send an email to [email protected].

11. REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions, or states. Please refer below for additional information that may be applicable to you:

• United States; California, Colorado, Oregon, Texas, and Virginia: Depending on your state of residency, you may be able to exercise additional rights granted by applicable law in relation to the personal information about you that we have collected (subject to certain limitations). If you are a resident of California, Colorado, Oregon, Texas, or Virginia, please review our Additional U.S. State Privacy Disclosures for additional information concerning these rights.
• European Economic Area, UK, or Switzerland: If you are located in European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), United Kingdom, or Switzerland, please see the Additional European Privacy Disclosures for additional European-specific privacy disclosures.

12. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES; CALIFORNIA AND OREGON

For residents of the States of California, Colorado, Oregon, Texas, and Virginia: These Additional U.S. State Privacy Disclosures ("U.S. Disclosures") supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of California, Colorado, Oregon, Texas, or Virginia. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our services, please read our Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these U.S. Disclosures.

For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

Sensitive Personal Information

We do not collect data elements that may be classified as "sensitive" under certain privacy laws.

Your Privacy Choices

Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The Right to Know. The right to confirm whether we are processing personal data about you, including:
  • The categories of personal data collected;
  • The categories of sources of the personal data;
  • The purposes for which the personal data were collected;
  • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
  • The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
  • The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
• The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
• The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• The Right to Opt Out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to "sell" personal information we have collected about you to third parties for monetary or other valuable consideration, or "share" your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
• The Right to Appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision. See "Appealing Privacy Rights Decisions" below for more information.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by:

• Emailing [email protected] with the subject line "Data Subject Rights Request,"
• Calling Toll Free at (323)-928-7848

We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising

Unless you have exercised your right to opt-out, we may disclose or "sell" your personal information to third parties for monetary or other valuable consideration, or "share" your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.

You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

To exercise the right to opt-out, you may submit a request by clicking the links below:

• Cookies-based Opt-Out (Do Not Sell or Share My Personal Information). To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please click here. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device. You may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process the GPC signal as a request to opt out. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance's (DAA) resources and/or the Network Advertising Initiative's (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android). You may also be able to opt-out of some, but not all, interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
• Opt-Out of "Selling" of Personal Information. In certain circumstances, we may share or make available your personal information (such as your name and e-mail address) with third parties who may use such information for their own commercial or business purposes. To opt out of such sharing, please email [email protected].

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent's authority to act on your behalf.

For requests to know, delete, or correct personal information, we require the following for verification purposes:

• (a) a power of attorney valid under the laws of California from you or your authorized agent; or
• (b) sufficient evidence to show that you have:
  • provided the authorized agent signed permission to act on your behalf; and
  • verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information "sales" or "sharing", we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted at [email protected].

• California Residents: If your appeal is denied, you may contact the California Attorney General to submit a complaint here.
• Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to submit a complaint here.
• Oregon Residents: If your appeal is denied, you may contact the Oregon Attorney General to submit a complaint here.
• Texas Residents: If your appeal is denied, you may contact the Texas Attorney General to submit a complaint here.
• Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.

California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

• Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers (e.g., name, email address, account name), personal information categories listed in the California Customer Records statute (e.g., name or credit card number), commercial information (e.g., channel information, subscribers information), internet/network information (e.g., browsing history, search history, and consumer online interactions), geolocation data (e.g., general location derived from IP address), and inferences generated from your use of our sites. We collect this information directly from you, from third party sources (including data providers and consumer reporting agencies), and automatically through online tracking technologies. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see How We Collect and Use Personal Information section of our Privacy Notice.
• Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Sharing of Your Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
  • Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
  • Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
  • Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics, and market research;
  • Social networks for advertising or personalization purposes, or to engage with you;
  • Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Services;
  • We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Notice.
• Sales of Personal Information and Sharing for Targeted Advertising. In the previous 12 months, we have sold the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:
  • Identifiers
  • Commercial Information
  • Internet / Network Information
  • Inferences

  In addition, please see Third-Party Data Collection and Online Advertising section of the Privacy Notice and our Cookie Policy to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us.

• Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.

  If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.

  If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child's behalf (i.e., you are the child's legal guardian or authorized representative).

• "Shine the Light". The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at [email protected].

13. ADDITIONAL EUROPEAN PRIVACY DISCLOSURES

Who is responsible for your personal information?

GrabTap is the data controller responsible for the collection and use of your personal information when you use the GrabTap website, contact us about our products and services, or click on an online advert promoting us or our Services. This means that we determine and are responsible for how your personal information is used.

What personal information do we collect and how do we use it?

We collect the following personal information when you use the GrabTap Services. For further information please see the How We Collect and Use Personal Information section of our Privacy Notice.

Some information, such as your third-party account credentials, may be necessary for your use of certain features and functionalities of the Services. If you choose not to provide certain personal information, we may not be able to provide those aspects of the Service to you, or to respond to your queries and other requests.

Marketing and Advertising

From time to time we may contact you with information about our Services, including sending you marketing messages and asking for your feedback on our Services. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or sending a request to [email protected].

Tracking Technologies Used in Our Emails

Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.

Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

We may link or combine the personal data we collect about you and the information we collect automatically.

We may anonymize and aggregate any of the personal information we collect (so that it is no longer linked to you and does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service. We may also share such anonymized and aggregated information with others.

Profiling

We may analyze personal information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use personal data about you to detect and reduce fraud.

How do we share personal information

We may share the personal information we collect with the recipients specified in the How We Share Your Personal Information section of our Privacy Notice. The purpose of sharing the personal information we collect with these recipients is also set out in the How We Share Your Personal Information section of our Privacy Notice. These recipients may use your personal information in the following ways:

International Data Transfers

We may transfer, store, or process personal information in a country other than the one in which it was collected.

Where we transfer your personal information to countries outside of the UK or EEA, we ensure that such transfers are subject to appropriate safeguards recognized under applicable data protection laws, including the following:

If you would like to find out more about the transfers we undertake and the safeguards we implement, please contact us as set out in the Contact Us section of the Privacy Notice.

Your Privacy Rights

You have the following rights in relation to your personal information (subject to certain limitations at law):

Please note that if the exercise of these rights limits our ability to process personal information, we may not be able to provide our products or services to you, or otherwise engage with you going forward.

Submitting Requests

To exercise any of your privacy rights, please contact us as set out in the Contact Us section of the Privacy Notice. We may need to verify your identity before processing your request, which may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above if we are unable to identify you.