TRIPLE VERIFY PRIVACY POLICY

Last Updated: April 28, 2025

1. INTRODUCTION

Technology Payment Services, Inc. and its affiliates (collectively, "Triple Verify," "we," "our," or "us") respect your privacy and are committed to protecting it through compliance with this Privacy Policy ("Policy").

This Policy describes how Triple Verify collects, uses, discloses, and safeguards information when you interact with our fraud detection and prevention services, website at https://tripleverify.com and affiliated webpages ("Website"), applications, and other products and services (collectively, the "Services").

Triple Verify provides advanced e-commerce fraud detection and prevention solutions designed to help businesses identify and mitigate fraudulent transactions and activities. The nature of our Services necessarily involves the processing of certain personal information to detect patterns, assess risk, and prevent fraudulent activity.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT.

2. APPLICABILITY

This Policy applies to information we collect:

- Through our Website and Services.

- When you interact with our advertising and applications on third-party websites and services.

- Through email, text, and other electronic communications between you and Triple Verify.

- Through any mobile and desktop applications you download from our Website or authorized distribution channels.

This Policy does not apply to information:

- Collected by third parties, including through any application or content that may link to or be accessible from or on our Website or Services.

- Collected by us where a separate privacy notice is provided.

3. INFORMATION WE COLLECT

Triple Verify collects several types of information to provide and improve our Services. The information we collect depends on the context of your interactions with us and the choices you make, including your privacy settings and the products and features you use.

3.1 Categories of Information We Collect

3.1.1 Information You Provide to Us

We collect information that you provide directly to us, including:

- Account Information: When you register for an account, we collect your name, email address, password, company name, job title, phone number, and other information necessary to establish and maintain your account.

- Payment Information: When you make a purchase, subscribe to our Services, or sign up for our Affiliate Program we collect payment information, billing addresses, and other details necessary to process your payment and confirm the information you provided. Note that payment card information is processed by our payment processors and not stored directly on our systems except as required for transaction reference.

- Communications: When you communicate with us, we collect the content of those communications, including any information you choose to provide.

- Marketing Preferences: We collect information about your preferences for receiving marketing communications from us.

3.1.2 Information We Collect Automatically

When you interact with our Website or Services, we automatically collect certain information, including:

- Device Information: We collect information about the devices you use to access our Services, including device type, operating system, browser type, IP address, mobile network information, and device identifiers.

- Usage Information: We collect information about how you interact with our Services, including pages visited, features used, time spent on the Website, clickstream data, referring/exit pages, and date/time stamps.

- Location Information: We may collect precise or approximate location information from your device when you enable location services or through your device's IP address.

3.1.3 Information from Third Parties

In the course of providing our fraud detection and prevention Services and running our Affiliate Program we collect and process information from various third-party sources, including:

- Client-Provided Information: Information provided by our clients about their customers' transactions and activities for fraud detection purposes, which may include personal information such as names, email addresses, IP addresses, device identifiers, and transaction details.

- Fraud Intelligence Networks: Information from fraud intelligence networks, databases, and other security and identity verification services.

- Public Sources: Publicly available information from government agencies, public records, and other public sources.

- Business Partners: Information from our business partners, such as marketing partners, identity verification services, and data enhancement providers.

3.2 Sensitive Personal Information

We do not intentionally collect sensitive personal information such as government-issued identification numbers, financial account numbers, biometric data, precise geolocation data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, or data concerning health or sexual orientation, unless:

- You provide such information to us;

- Such information is required for compliance with legal obligations;

- Such information is necessary to provide our fraud detection and prevention Services; or

- Such information is necessary to confirm your information, consent, and/or signature relating to the use of the Services or your participation in the Affiliate Program.

When we do collect sensitive personal information, we implement additional safeguards to protect such information in accordance with applicable laws.

4. HOW WE USE YOUR INFORMATION

We use the information we collect for various purposes, including:

4.1 Provision of Services

- To provide, maintain, and improve our Services, including to detect, prevent, and investigate potentially fraudulent transactions and other security incidents.

- To set up and manage your account, including to authenticate your identity and authorize access to our Services.

- To process transactions and send notices about your transactions or account.

- To respond to your inquiries, comments, feedback, or questions.

4.2 Research and Development

- To create anonymous, aggregated, or de-identified data that we may use for research, analytics, and improving our Services.

- To test, develop, and analyze new features and functionality.

- To conduct data analysis to better understand user behavior and preferences.

- To improve the safety, security, and performance of our Services.

4.3 Marketing and Communication

- To send administrative information to you, such as changes to our terms, conditions, and policies.

- To communicate with you about products, services, offers, promotions, and events, and provide other information we think may be of interest to you, subject to your communication preferences and applicable laws.

- To manage referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events.

4.4 Legal and Security Purposes

- To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

- To detect, prevent, or otherwise address fraud, security, or technical issues.

- To comply with applicable laws, regulations, legal processes, or governmental requests.

- To enforce our Terms of Use and other agreements, including for billing and collection purposes.

- To prevent or investigate possible wrongdoing in connection with the Services.

5. LEGAL BASES FOR PROCESSING (FOR EEA, UK, AND SIMILAR JURISDICTIONS)

If you are located in the European Economic Area (EEA), the United Kingdom, or jurisdictions with similar data protection laws, we collect and process your personal information only where we have a legal basis for doing so. The legal bases depend on the Services you use and how you use them. We process your personal information on the following legal bases:

- Performance of a Contract: When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.

- Legitimate Interests: When processing is necessary for our legitimate interests or those of a third party, and your interests and fundamental rights do not override those interests. Our legitimate interests include: providing secure and effective Services, improving our Services, marketing our Services, protecting against fraud and unauthorized transactions, and complying with industry best practices.

- Compliance with Legal Obligations: When processing is necessary to comply with our legal obligations.

- Consent: When you have given us specific consent to process your personal information for a specific purpose. Where we rely on your consent, you have the right to withdraw it at any time.

6. INFORMATION SHARING AND DISCLOSURE

We may share your information in the following circumstances:

6.1 With Clients and Partners

- Clients: We share information with our clients as necessary to provide our fraud detection and prevention Services, subject to contractual restrictions and applicable law.

- Service Providers: We share information with third-party service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting, customer service, and marketing assistance.

- Business Partners: We share information with business partners to provide specific products or services that may be of interest to you or to jointly offer products or services.

6.2 For Legal Reasons

- Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

- Protection of Rights: We may disclose information to protect and defend the rights, property, or safety of Triple Verify, our clients, or others, including to enforce our agreements and policies.

- Corporate Transactions: We may share or transfer information in connection with a merger, acquisition, reorganization, sale of assets, bankruptcy, or similar corporate event, subject to appropriate confidentiality arrangements.

6.3 With Your Consent

We may share information with third parties when you consent to such sharing.

6.4 Aggregate or De-identified Information

We may share aggregate or de-identified information that cannot reasonably be used to identify you with third parties for any purpose, including for research, analysis, and improvement of our Services.

7. INTERNATIONAL DATA TRANSFERS

We may transfer, store, and process your information in countries other than your own. Our servers are located in various jurisdictions, including the United States. Please be aware that the data protection laws of these countries may differ from those of your country of residence.

If you are located in the EEA, UK, or other jurisdictions with data protection laws that restrict international data transfers, we implement appropriate safeguards to ensure that your personal information receives an adequate level of protection wherever it is processed. These safeguards may include:

- European Commission-approved standard contractual clauses.

- Binding corporate rules for transfers within our corporate group.

- Derogations for specific situations, such as consent or contractual necessity.

- Other legally approved mechanisms that ensure an adequate level of protection.

You can request more information about these safeguards by contacting us using the information in the "Contact Us" section.

8. DATA RETENTION

We retain your information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

- The duration of our ongoing relationship with you and the provision of our Services.

- Whether we have a legal obligation to retain the information.

- Whether retention is advisable in light of our legal position (e.g., for statutes of limitations, litigation, or regulatory investigations).

After the retention period expires, your personal information will be deleted or anonymized, unless we are legally required to retain it longer.

9. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have certain rights regarding your personal information. These may include:

9.1 Access, Correction, and Deletion

- Access: You may have the right to access personal information we hold about you.

- Correction: You may have the right to correct inaccurate or incomplete personal information we hold about you.

- Deletion: You may have the right to request deletion of your personal information in certain circumstances.

9.2 Restriction and Objection

- Restriction: You may have the right to request that we restrict processing of your personal information in certain circumstances.

- Objection: You may have the right to object to processing of your personal information in certain circumstances, including processing for direct marketing or based on legitimate interests.

9.3 Data Portability

You may have the right to receive a copy of your personal information in a structured, machine-readable format and to transmit that information to another controller.

9.4 Withdrawal of Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time.

9.5 Non-discrimination

We will not discriminate against you for exercising any of your data protection rights.

9.6 How to Exercise Your Rights

To exercise your rights, please contact us using the information provided in the "Contact Us" section. We may need to verify your identity before responding to your request. We will respond to your request within the timeframe required by applicable law.

Please note that some of these rights may be limited or subject to exceptions under applicable law.

10. JURISDICTION-SPECIFIC PROVISIONS

10.1 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

- The right to know what personal information we collect, use, disclose, and sell.

- The right to delete certain personal information.

- The right to correct inaccurate personal information.

- The right to opt-out of the sale or sharing of personal information.

- The right to limit the use and disclosure of sensitive personal information.

- The right to non-discrimination for exercising your privacy rights.

To exercise these rights, please contact us using the information provided in the "Contact Us" section.

Triple Verify does not "sell" or "share" personal information as those terms are defined under California law. However, we do use cookies and similar technologies as described in our Cookie Policy.

10.2 European Economic Area (EEA) and United Kingdom Residents

If you are located in the EEA or the UK, you have the rights described in the "Your Rights and Choices" section. In addition, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

10.3 Other Jurisdictions

We are committed to complying with the applicable data protection laws in all jurisdictions where we operate. If you are located in a jurisdiction with specific privacy rights not covered in this Policy, please contact us, and we will respond in accordance with applicable law.

11. DATA SECURITY

We have implemented appropriate technical and organizational measures designed to protect the security of your information. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Our security measures include:

- Encryption of sensitive information in transit and at rest.

- Access controls and authentication requirements for our systems.

- Regular security assessments and penetration testing.

- Monitoring for suspicious activities and unauthorized access attempts.

- Employee training on security and privacy best practices.

Despite these measures, we cannot ensure or warrant the security of any information you transmit to us or store on our Services. You provide your information at your own risk.

12. CHILDREN'S PRIVACY

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information as quickly as possible. If you believe we have inadvertently collected information from a child under 18, please contact us immediately.

13. COOKIES AND TRACKING TECHNOLOGIES

We and our third-party service providers use cookies, web beacons, and other tracking technologies to collect information about your use of our Website and Services. This information helps us to provide you with a better experience when you use our Services and allows us to improve our Website and Services.

13.1 Types of Cookies We Use

- Essential Cookies: These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.

- Analytical/Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website.

- Functionality Cookies: These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.

- Targeting Cookies: These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

13.2 Your Choices Regarding Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website.

For more detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy.

14. THIRD-PARTY LINKS AND SERVICES

Our Website and Services may contain links to third-party websites, products, or services. These third-party sites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. We encourage you to read the privacy policies of each site you visit.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time to reflect changes to our information practices. If we make any material changes, we will notify you by email (if we have your email address) or by posting a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

The date the Policy was last revised is identified at the top of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

16. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Triple Verify
1712 Pioneer Ave STE 135
Cheyenne, Wyoming 82001

[email protected]

Effective Date: April 28, 2025