PRIVACY POLICY

Adxcel Inc. dba ArtsAI ("ArtsAI" or "we" "us" "our") provides targeted advertising and marketing services for our business customers, including advertisers, advertising agencies and publishers.

Through our services, business customers can create, manage and measure served advertisements, measure website and other digital property visits, and monitor the effectiveness of advertising campaigns.

To provide our services, we collect and use information about consumers who are targeted with ads. By “information” we mean information relating to an identified or identifiable consumer or that is considered "personal information" or "personal data" under applicable law.

This Privacy Policy describes:

• The types of information ArtsAI collects from consumers.
• How that information is collected and used.
• To whom that information is disclosed.
• Consumer choices regarding the collection and use of such information.
• How that information is secured.

See additional relevant disclosures if you are a consumer who lives in the following regions:

• California
• Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia
• Nevada
• EEA, Switzerland, or the UK

For our contact details, see the Contact Us section below.

We collect the following categories of information about consumers:

• Device identifiers, such as Ad IDs and IP addresses.
  Ad IDs are user-resettable identifiers (such as the Apple IDFA or Android Advertising ID) found in mobile device operating systems. IP addresses are numbers that identify a device connected to an internet network. IP addresses may be truncated or encrypted or both based on local legislation or other requirements. IP addresses collected outside of the United States will be truncated by removing the last octet before processing.
  Device identifiers also include pseudonymous advertiser identifiers, which are unique identifiers generated by us or a third party that are linked to a device but not intended to identify a consumer.
• Device information, such as operating software and browser details (e.g., type, version, and configuration), internet service provider details, and regional and language settings.
• Internet activity, such as device browsing history and interactions, date and times of visits, domains and pages visited, referring and exiting pages, and ad data. Ad data is data about the online ads that have been served or attempted to be served to a device. For example, how many times an ad has been served and whether the ad was clicked on or otherwise interacted with.
• Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.
• Characteristics or demographics, such as country.
• Inferences generated from any of the above. For example, consumer interests.

We collect information in the following contexts:

• When you interact with a website, mobile app, advertising, podcast, or other online service that contains the ArtsAI pixel
  ArtsAI operates a proprietary ArtsAI pixel. A pixel is a small transparent image that is placed on websites, mobile apps, advertisements, podcasts, and other online services that allows communication between a web browser and a server. We collect information through ArtsAI pixels embedded within ArtsAI’s own services as well as within the websites, mobile apps, advertisements, podcasts, and other online services of ArtsAI’s business customers and third parties who have contracted with ArtsAI to use the pixel.
• When you interact with our website
  We collect information when you browse or otherwise interact with the ArtsAI website, including information you provide directly (such as in a webform) and information automatically collected through third party pixels and cookies embedded within the website. Cookies are small text files stored in a web browser that can remember preferences, recognize browsers, and communicate with pixels. Cookies can be controlled by browser settings.
• Information from our business customers
  In addition to information collected through the ArtsAI pixel, we obtain information provided by our business customers in connection with helping them create, manage and measure served advertisements, measure website and other digital property visits, and monitor the effectiveness of advertising campaigns. For example, we may collect information through third party pixels and cookies embedded within their services, such as Google’s ad server (DFP).
• Information from our affiliates
  We obtain information from our affiliates. For example, in connection with providing services to our business customers, we are able to access the Claritas Identity Graph and obtain information about you. For details about Claritas’ privacy practices, see the Claritas Privacy Policy.
• Information from third party data sources
  We also collect information from third party data sources. For example, information obtained via server-to-server connection, or via secure file transfer.

We collect and use information for the following purposes:

• Targeting
  Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads.
• Frequency capping
  Making sure you don't see the same ad too many times.
• Sequencing
  If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
• Cross-device matching
  Identifying different devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices, and so that campaign effectiveness can be measured and analyzed.
• Attribution
  Monitoring when, where, and at what price we served certain ads on behalf of an advertiser so that we can measure our influence on the marketing results of the advertiser’s campaigns and overall marketing strategy.
• Reporting
  Providing advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, clicks, and conversions. This data allows an advertiser to determine if an ad is not performing well (customers are not clicking on it), so that the advertiser will be able to see that data and update the ad.
• Improvements
  Developing and improving our services, including training our models and algorithms.

In some cases, ArtsAI acts as a processor or service provider on behalf of a business customer. When acting in such capacity, ArtsAI will process the information in strict accordance with the permissions and restrictions imposed by the business customer providing such information. Please see our business customer’s privacy policy for details.

We disclose information about you:

• To our business customers
  We disclose information to our business customers in connection with providing services to them. For example, we may disclose information about how you have interacted with an advertiser’s ads.
• To our service providers
  We contract with and disclose information to companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting), as well as billing, collections, tech, customer and operational support.
• To third party vendors
  Some of the companies we work with independently control the purposes and means of processing your information. For these third parties, we encourage you to familiarize yourself with and consult their policies and terms of use.
• To our affiliates
  We may disclose your information to our affiliates, including in connection with accessing the Claritas Identity Graph.
• In connection with legal proceedings
  When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of ArtsAI, our business customers or any other third party.
• In connection with security, enforcement, and the law
  We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, our services or anyone else.
• In connection with a sale of our business
  If ArtsAI considers selling, merging or otherwise reorganizing its business, we reserve the right to transfer and disclose information to any potential or actual purchaser or investor.

We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. Below are some specific policies:

• Information associated with the ArtsAI pixel
  Information associated with ArtsAI pixel, including Ad Ids and IP addresses, are deleted from our active database after 15 months following our provision of services to a business customer.
• Information associated with Real Time Bids
  Information logged for a particular submitted bid or a received real time bid request, including Ad Ids and IP addresses, are deleted from our active database after 6 months following our provision of services to a business customer.
• Information Associated with Google’s ad server (DFP)
  Information associated with Google’s ad server (DFP), including Ad Ids and IP addresses, are deleted from our active database after 15 months following our provision of services to a business customer.

Information collected from the European Economic Area, Switzerland, United Kingdom, and other countries outside of the United States may be transferred to and processed in the United States. We will protect all transferred information and ensure that international transfers comply with applicable data transfer laws.

Our products and services are not designed or intended for children (as defined in applicable data protection laws). We do not knowingly collect personal information from children on the websites we operate or through our services. Please advise us if you are aware of our having received personal information from a child, in which case we will take appropriate steps to delete it. For these purposes, "children" and "child" refer to ages defined by applicable law in the countries where we provide our services.

We apply technical, administrative and organizational security measures designed to protect the information we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

Ads with the embedded ArtsAI pixel usually link to other websites, which may have privacy assurance practices that differ from ours. ArtsAI does not control and cannot be held responsible for the content of these websites and data collection on these web sites by any third party. To make sure your privacy is protected, please consult the respective privacy policy of the web site you are visiting.

We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads (sometimes called "interest-based ads") you receive and how we use your information.

Claritas Identity Graph

As noted above, we access the Claritas Identity Graph in connection with providing services to our business customers. If you wish to have your information deleted from the Claritas Identity Graph, please make your request here.

ArtsAI Pixel Browser Opt Out

We offer a browser-based opt out for our ArtsAI pixel that reduces the number of targeted ads you receive. This opt out does not impact how we use or disclose information collected through the ArtsAI pixel.

To opt out of targeted ads shown in connection with the ArtsAI-pixel, сlick here.

By clicking above, we will drop an opt-out cookie on your browser, which allows us to recognize that browser in the future and respect your opt-out preferences for that browser. The cookie will apply to the specific browser you are using. If you wish to opt out for other browsers that you use, you must repeat the process using those browsers. All other cookies associated with your browser will remain intact and your opt out will be effective with respect to the browser used as long as you do not delete the cookie file from your hard drive. Please note that if you erase all cookies from your computer, you will also erase our opt-out cookie and will need to repeat the process of opting out. This opt out will not work for non-browser based services, such as mobile apps.

DAA Opt Out

ArtsAI is a participant in the Digital Advertising Alliance (DAA), and we adhere to the DAA Self-Regulatory Principles. The DAA offers an opt-out tool that, similar to the ArtsAI pixel Browser Opt Out, allows consumers to reduce the number of targeted ads they receive from DAA participants. This opt-out tool does not impact how participants use or disclose information collected through the ArtsAI pixel.

For details on how to opt out, see https://youradchoices.com/control. We are not responsible for the effectiveness of their tools.

Resetting your Ad ID

Most mobile devices allow you to reset your device’s Ad ID through your device settings, which is designed to limit how the prior Ad ID can be used. See your device settings for details.

Region-Specific Choice

See additional relevant disclosures regarding your rights if you are a consumer who lives in the regions below.

Where ArtsAI acts as a processor or service provider on behalf of a business customer, please contact the business customer directly to exercise any rights you may have.

This section applies solely to the personal information of consumers who reside in the State of California ("consumers" or "you") and supplements the information above. We have included this section to comply with the California Consumer Privacy Act of 2018, as amended (CCPA) and any terms defined in the CCPA have the same meaning when used in this section.

Notice at Collection

For residents of California, at or before the time of collection of your personal information, you have the right to receive notice of our data practices. Our data practices are as follows:

• Collection. The categories of personal information we have collected in the past 12 months and the categories sources from which the personal information is collected are set out in the “What Information We Collect” and “How We Collect Information” sections above.
• Purpose. The specific business and commercial purposes for collecting and using personal information are set out in the “How We Use the Information We Collect” section above.
• Disclosure. The categories of persons to whom personal information is disclosed, including service providers for business purposes, are set out in the “To Whom We Disclose Information” section above. We disclose the categories of personal information listed in the “What Information We Collect” section above to service providers for business purposes.
• Sales and Shares. Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under California law. A “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the categories of information listed in the “What Information We Collect” section above.
• Sensitive Data. To the extent any personal information we collect is considered sensitive personal information under California law, we collect, use, and disclose sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.
• Retention. The criteria used to determine the period of time we retain your personal information is set out in the “Data Retention” section above.

Your Rights

The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Sales and Shares

You have the right to opt out of us selling or sharing your personal information to third parties. To exercise this right, click here to manage your technology preferences or turn on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you opt out of tracking through the methods above, we do not know who you are within our systems, and your opt out will apply only to information collected through tracking technologies on the specific browser from which you opt out or, where required by law, to any pseudonymous profiles we maintain associated with your browser or device. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings.

Verifiable Requests

• Access. You have the right to know what personal information we have about you, including: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting, selling, or sharing that personal information; (iv) the categories of third parties with whom we disclose that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• Correction. You have the right to correct any of your personal information that we collected from you.
• Deletion. You have the right to delete any of your personal information that we collected from you and retained.

Your rights are subject to exceptions and our retention practices.

Exercising Access, Correction, and Deletion Rights

To exercise the access, correction, and deletion rights described above, please submit a verifiable consumer request to us by e-mail sent to privacyinfo@claritas.com or by calling us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering service code 813# to leave us a message or by filling-out following web-form

To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. Except where prohibited by law, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.

You may only make a verifiable consumer request for access, correction, or deletion twice within a 6-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Shine the Light

If you are a consumer who is also a customer, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the Contact Us section below and specify that you are making a "California Shine the Light Request."

Do Not Track

Your browser or extension may allow you to automatically transmit Do Not Track signals. Except as required by law, we do not respond to Do Not Track signals.

This section applies only to residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia. Our practices in these states regarding the collection, use, and retention of your personal data are set out in the main Privacy Policy. Some of our disclosures of personal data may be considered a “sale” under applicable law, which is often defined to include a disclosure for something of value. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

In addition to the choices noted in the main Privacy Policy above, you may request the additional rights listed below. Please note, these rights are not absolute, and are subject to exceptions and our retention practices. In some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity. You may make a rights request using an authorized agent. Except where prohibited by law, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.

Verifiable Requests

• Confirm/Access/Correct/Portability/Delete. You have the right to (i) confirm whether we process your personal data, and, in some regions, confirm the categories of personal data we have processed; (ii) access your personal data; (iii) correct inaccuracies in your personal data; (iv) delete your personal data; and (v) obtain a copy of personal data that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
• List. If you are an Oregon resident, you also have the right to obtain a list of the specific third parties to which we have disclosed personal data.

These rights are verifiable rights, meaning that we need to verify your identity before fulfilling them. To exercise any of these rights, please submit a request through our webform above, or you may call 1-866-467-8688) and enter Service Code 813#. We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information.

Sales and Targeted Advertising

Opt out of sales and targeted advertising. If we sell your personal information for monetary consideration or engage in targeted advertising according, you can opt out. To exercise this right, click here to manage your technology preferences or turn on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you opt out through either of the above methods we do not know who you are within our systems, and your opt out will apply only to information collected through tracking technologies on the specific browser from which you opt out or, where required by law, to any pseudonymous profiles we maintain associated with your browser or device.

Other Rights

• Right to Non-Discrimination. ArtsAI will not discriminate against consumers who exercise their rights.
• Consent. You have the right to revoke consent previously given to us for the processing of your personal data. To revoke consent, write us at the email or postal address set out in the Contact Us section below (specifying the consent you wish to withdraw). If you withdraw consent, you may not be able to receive certain services related to that consent.
• Appeal. Under the laws of certain jurisdictions, you have the right to appeal our decision not to act on your request to exercise certain of the rights described above. To appeal our decision if you are in an eligible jurisdiction, please email us at privacyinfo@claritas.com. If we deny your appeal, you may submit a complaint to your Attorney General as follows:
  • For Colorado residents: https://coag.gov/file-complaint/
  • For Connecticut residents: https://www.dir.ct.gov/ag/complaint/
  • For Montana residents: https://dojmt.gov/consumer/
  • For Oregon residents: https://justice.oregon.gov/consumercomplaints/
  • For Texas residents: https://oag.my.salesforce-sites.com/CPDOnlineForm
  • For Utah residents: https://attorneygeneral.utah.gov/contact/complaint-form/
  • For Virginia residents: https://www.oag.state.va.us/consumercomplaintform

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your opt-out of "sale" rights you can do so by clicking here to manage your technology preferences or turning on a recognized opt-out preference signal, such as Global Privacy Control in your browser or extension. If we decline to take action on your request, you may appeal such refusal by sending us an email to dpo@artsai.com within a reasonable time period after we send you our decision.

Legal Basis for Processing

If you interact with our services from the European Economic Area, Switzerland and United Kingdom, our legal basis for collecting and using personal data is legitimate interest with respect to the following activities:

• Ad selection: The interest pursued is the advertiser’s interest in promoting its business. There are also benefits to others, including publishers that can monetise their inventory and end users of the properties who are able to benefit from free or subsidised use of the publisher’s website.
• Ad measurement: The interest pursued is the advertiser’s interest in measuring the effectiveness of its advertising, which can help to improve future campaigns and reduce wasted expenditure.

Your Data Protection Rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided below under Contact Us section.
• You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided below under Contact Us section.
• If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Complaints

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

ArtsAI has appointed a Data Protection Officer. If you have any questions or believe your personal data has been used in a way that is not consistent with this policy or applicable legislation, or you have any other data protection related issues or queries, please contact our Data Protection Officer by e-mail sent to dpo@artsai.com.

Written inquiries may be addressed to:

Data Protection Officer
ArtsAI
8044 Montgomery Road, Suite 455
Cincinnati, Ohio 45236, USA

Data Privacy Framework

ArtsAI complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF") and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce. ArtsAI has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. ArtsAI has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework ("DPF") program, and to view our certification, please visit https://www.dataprivacyframework.gov/

With respect to personal data received or transferred pursuant to the DPF, ArtsAI is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the DPF, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF, should direct their query to dpo@artsai.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to dpo@artsai.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

ArtsAI’s accountability for personal data that it receives in the United States under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, ArtsAI remains responsible and liable under the DPF Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless ArtsAI proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, ArtsAI commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF and the Swiss-U.S. DPF. EU and Swiss individuals with inquiries or complaints should first contact dpo@artsai.com

ArtsAI has further committed to refer unresolved DPF-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

We may update this policy from time to time. We will post a prominent notice on our website notifying users when it is updated. We ensure that privacy practices described in this privacy policy are up to date and reflect current ad-serving and data collection mechanisms employed by ArtsAI.

This Privacy Policy will always include information on the effective date of the most recent version.

The controller under this Privacy Policy is:

Adxcel Inc. dba ArtsAI
8044 Montgomery Road, Suite 455
Cincinnati, Ohio 45236, USA
privacyinfo@claritas.com

European Representative: EUrep.ArtsAI@lewissilkin.com

If you have questions about our practices regarding your information or have trouble accessing this Privacy Policy, please contact us at the postal address or email addresses above. To exercise choice available to you, please use the designated methods listed in this Privacy Policy.

To learn more about data collection, online behavioral advertisements, web analytics, cookies or other aspects from the perspective of Internet security and privacy, please visit these public sites: www.youronlinechoices.com and www.iabeurope.eu.

ArtsAI participates and complies with the rules of an advertising industry framework called the IAB Europe Transparency & Consent Framework (“IAB TCF”), which consists of a set of technical specifications and policies to which members must adhere. AdXcel, Inc. dba ArtsAI IAB TCF Vendor ID: 1330.