VIAMEDIA PRIVACY POLICY AND DATA SECURITY PROTOCOLS

Updated July 31, 2018

Background:

Viamedia, Inc. (“Viamedia”) is committed to protecting the privacy and the security of its third party advertisers and other business partners (“Partners”) and all data, including data provided to Viamedia by those Partners (“Partner Data”). Viamedia maintains security policies and procedures designed to ensure no unauthorized person or business has access to Partner Data. These policies cover the Viamedia website, any other direct access portals available to our Partners, and each of our products and services (the “Services”), and sets forth how Viamedia uses and stores the Partner Data it collects and receives (the “Privacy Policy”). Viamedia uses a variety of multi-level security procedures to limit the information it onboards and to protect the privacy and security of all Partner Data, including administrative, technical, and physical safeguards designed to protect personally identifiable Information against unauthorized access, use, or disclosure of any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, IP address, postal or other physical address, credit or debit card number (“PII”).

Processing of Partner Data:

Viamedia onboards, processes and uses Partner Data only in accordance with its Privacy Policy, and processes and stores Partner Data on its servers in the United States of America to provide the Services in conjunction with and according to the instructions of its Partners under a user agreement, insertion order, or other documentation that allows Viamedia to provide the Services.

Data Storage, Access and Deletion:

Partner Data is stored in an encrypted format, or is otherwise password protected, and is maintained in a secure environment that limits access only to those Viamedia employees who have a need to access the Partner Data in conjunction with providing the Services. Viamedia also maintains redundant back-up copies of Partner Data in this same secure manner. Viamedia takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of, Partner Data, including internal reviews of its data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where the Partner Date is stored. Once Partner Data is no longer needed to provide Services, it is securely deleted using industry standard data overwrite protocols.

PII:

Unless Viamedia enters into a written agreement with a third party provider where such third party provider gives its specific consent, Viamedia does not accept, onboard, process or store any PII, including: (i) personally identifiable information related to a person under the age of eighteen; (ii) social security numbers, driver’s license numbers, or other government-issued identification numbers; or (iii) information associated with a person’s name, account username or email address or other unique identifying information, such as authentication information, credit/debit card or financial account numbers, personally identifiable payroll or financial information, including employee identification numbers, information such as sexual orientation, gender identity or religion, and health information or conditions.

Protection of Viamedia Systems and Facilities:

Viamedia conducts risk assessments on, and makes adjustments to, its information systems and facilities in order to maintain the security of all Partner Data, and to identify vulnerabilities and unauthorized access attempts into its systems.  All Viamedia systems have antivirus protection and are protected by a hardware firewall, which provides ongoing screening (and automatic prevention) of potential security threats. Alert logs from the firewalls are reviewed daily, and periodic vulnerability scans and penetration tests of the network are run to ensure ongoing system security. Viamedia maintains strict physical security for its facilities and limits access to its facilities to authorized Viamedia employees and invitees.

Third Party Service Providers and Protocols:

Viamedia may engage third party service providers to provide a subset of Services. Only Partner Data that is specifically needed to execute such Services is shared and transferred to such third party service providers pursuant to an agreement with that third party service provider and through secure transmission methods and protocols. Viamedia’s third party service providers are required to maintain data security and privacy protections at least as stringent as those maintained by Viamedia.

Data Match Protocols:

For Services that include data match by Viamedia’s third party service providers, data is matched in a privacy-compliant manner that creates an anonymous targeting pool. Viamedia’s third party service providers are required to securely delete Partner Data upon completion of these Services.

Information Sharing:

Viamedia does not rent, sell, or share Partner Data with other individuals or companies except as follows: (i) Viamedia responds to subpoenas, court orders, or legal process, or to establish or exercise its legal rights or defend against legal claims; (ii) Viamedia shares information in order to investigate, prevent, or take action concerning illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violation of Viamedia’s terms of service, or as otherwise required by law; (iii) if Viamedia, or substantially all of its assets, are acquired or merged with another company, Partner Data is one of the assets that is transferred to a third party; and (iv) Viamedia will share with various third parties, including our Partners, aggregated, anonymized non-PII along with aggregated demographic and analytics information from other users in a manner where it cannot reasonably be used to identify any particular individual user.

Contacting Viamedia:

Partners with specific concerns, questions or comments related to this Privacy Policy or Viamedia’s procedures and protocols regarding Partner Data, or who wish to correct inaccuracies in Partner Data, or to request that Viamedia delete Partner Data, may contact Viamedia at info@viamediatv.com, or Customer Service, Viamedia, Inc., 220 Lexington Green Circle, Suite 300, Lexington, Kentucky 40503.

Changes to Privacy Policy:

Viamedia may change this Privacy Policy or its procedures and protocols regarding Partner Data from time to time.