Privacy Policy

Last Updated: March 2011

This privacy policy (the “Policy”) describes the privacy practices of Sharethrough Inc.
(“Sharethrough,” “we,” “our,” or “us”) with respect to our online video advertising services. We select,
target and deliver our advertisers’ ads through use of our proprietary technology and/or technology from third party technology service providers, if any (the “Sharethrough Platform”). In addition, in order to provide our users, current and prospective customers and job seekers, with information regarding our services, we maintain our corporate website, www.sharethrough.com (the “Site”). This Policy describes how we collect, use and disclose information in connection with our operation of the Sharethrough Platform and the Site.

Sharethrough reserves the right to modify this Policy at any time by posting the changes on the Site.

Your continued use of the Sharethrough Platform and/or the Site constitutes your acceptance of the current posted Policy.

What Information We Collect – Personally Identifiable Information

Sharethrough does not collect personally identifiable information through operation of the
Sharethrough Platform, but does collect personally identifiable information through the Site.

The personally identifiable information that is collected through the Site allows us to identify a potential user as a specific individual. Such personally identifiable information includes, but is not limited to your name, email address, mailing address and phone number. The Site collects personally identifiable information about users only if a user voluntarily provides that information to the Site. Personally identifiable information is collected on the Site in various instances including, without limitation: (i) through the “Contact Us” function, which requests a user to provide his, her or its name, address, email address and telephone number, as well as some additional basic information regarding the project that requires our services, (ii) a user posts a comment in the blog section of the Site, and submits his or her name and email address in connection with the posting or (iii) a user subscribes to the Site’s subscription function to obtain content updates by providing his or her email address.

What Information We Collect – Non-Personally Identifiable Information

The Sharethrough Platform collects non-personally identifiable information regarding how many times a video or other content is requested by users, what content is viewed, the dates and times of the requests, and how the video or other content is interacted with by the user. In addition, IP addresses are collected in order to determine the approximate geographic location of users so that we can serve advertisements that are more relevant to that location.

The Site collects non-personally identifiable information that your browser automatically sends
whenever you visit the Site, including information about your web request, click stream information, IP address, browser type, browser language, date and time of the request.

Cookies and Beacons

We, and some of our third-party service providers, collect non-personally identifiable information through the use of “cookies.” A cookie is a small text file containing a string of characters that is placed by an Internet server on your hard drive. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to store the non-personally identifiable described above, and to store inferences we make based on that non-personally identifiable information about what a User’s interests might be. Most web browsers are initially set up to accept cookies, but you can change your web browser settings to cause your browser to refuse cookies or to indicate when a cookie is being sent. You can remove and/or disable cookies by following directions provided in your Internet web browser’s “help” file or menu. Please be aware, however, that some aspects of the Sharethrough Platform may not function properly if cookies are disabled.

We also collect non-personally identifiable information through the use of “tracking pixels,” also known as “beacons.” A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the web page that contains the tracking pixel. We use tracking pixels to tell when an advertisement has been clicked on or otherwise interacted with, and use that information to judge which advertisements are more appealing to users. In some cases, we use third party service providers to help us collect and analyze this information.

Third-Party Information

We also receive non-personally identifiable information regarding user demographics and preferences from third-parties who collect and make available such non-personally identifiable information for advertisement-serving purposes. Because we cannot control the activities of third parties, we cannot accept responsibility for your use of their services or for any use of your personal information by such third parties and we cannot guarantee that they will adhere to the same privacy and security practices as ourselves.

How We Use Information

We use non-personally identifiable information for purposes of displaying advertisements to users that are more likely to be relevant to them than what we would be able to display without the use of such information. If requested by an advertiser, we may also use non-personally identifiable information to determine whether to serve an advertisement to a user and which advertisement to serve. We also use non-personally identifiable information to analyze usage of and improve our advertising services. In some cases, we use third-party service providers to assist us with such analysis. Please note that the non-personally identifiable information we know relates only to the IP address and the recent activity of the web browser software, to the extent that cookies are enabled in that software.

Sharethrough does not share the personally-identifiable information that you provide to Site with any third party, other than with its service providers that help Sharethrough provide the services that yourequest.

Sharethrough may transfer the information it collects on the Sharethrough Platform and the Site to any successor in interest to Sharethrough (such as a company that acquires Sharethrough), or internally to one or more affiliates (such as a corporate subsidiary or parent). Sharethrough may also disclose personally identifiable information about a user if it determines that an applicable law, regulation or legal process requires it, or if Sharethrough determines that it needs to share such information to protect or enforce Sharethrough’s rights or the rights of another user.

What We Disclose and Who We Disclose it To

The non-personally identifiable information we collect and receive is provided to third-party service providers that assist us in running our business operations. These include, but are not limited to, data storage providers and processing facilities. We also provide non-personally identifiable information to our network of publishers, advertisers and other third parties in order to report the performance of advertisements displayed through use of our services.

Choice

Sharethrough uses advertising cookies to improve the online experience of its users by trying to match the ads we serve to the possible preferences and interests of users and by limiting the number of times an ad is shown. By doing so, ads that Sharethrough serves may be more relevant and useful to you. However, you may opt-out of the use of Sharethrough cookies by clicking on the “Opt-Out” link at the bottom of this page. This will set an opt-out cookie on your browser that notifies our servers that no other Sharethrough cookies should be sent. Please note that “opting out” does not mean you will not see Sharethrough’s advertisements online, but that these advertisements will not be targeted based on your online user interest profile from us. Please note further that if you change your computer, web browser or delete your cookies, you will need to renew all of your opt-out choices.

Security

Sharethrough uses commercially reasonable security measures that are designed to protect the security, integrity and privacy of the personally identifiable information. Please note, however, that no data security measures can be guaranteed to be completely effective. Therefore, while we strive to protect your information, please be advised that Sharethrough assumes no responsibility or liability for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.

Sharethrough’s products, services and websites are directed to, and intended for use by, adults only. We do not knowingly collect personally identifiable information from children under the age of thirteen. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen, we will delete such information from our records.

Updates to this Policy

We may occasionally update this Policy. When we do, we will also revise the effective date at the beginning of the Policy. We encourage you to periodically review this Policy to stay informed about how we collect, use and disclose information.

Contacting Us

If you have any questions, comments or concerns about this Policy, please email us at
[privacy@sharethrough.com]. You may also contact us by calling (415) 644-0054 or sending a letter to:

Sharethrough, Inc.
Attention: Privacy Inquiries
244 Jackson Street, Floor 2
San Francisco, CA 94111

Opt-out of targeted advertising for desktop and for mobile