Privacy Policy

Introduction

Surfside Solutions Inc., a Delaware corporation (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your Personal Information. We are a technology company that provides advertising and marketing services to businesses that engage us (“Clients”). Using our proprietary advertising technology (the “Technology”), we help Clients develop marketing strategies and deliver online advertising that may be relevant to individuals (collectively, the “Services”).

This Privacy Policy describes how we collect, use, disclose, and retain Personal Information when you:

• visit or interact with www.surfside.io (our “Website”);
• visit, use, or interact with websites, applications, advertisements, or other digital properties where we provide the Services; or
• otherwise interact with us or the Services.

This Privacy Policy does not apply to the privacy practices of Clients or other third parties, including their collection or use of information through their own websites, applications, products, or services. Please review their privacy policies for information about their practices.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. It does not include information that applicable law excludes from the definition of personal information, such as certain publicly available, de-identified, or aggregated information. Where we maintain information in de-identified form, we will maintain and use it in de-identified form and will not attempt to re-identify it, except as permitted by applicable law.

Please read this Privacy Policy carefully. It explains our privacy practices and the choices available to you. Depending on applicable law and our processing activities, you may have rights regarding your Personal Information, including the right to opt out of certain processing, such as the sale or sharing of Personal Information or the use of Personal Information for targeted advertising. See Your Privacy Rights and Choices below.

We may update this Privacy Policy from time to time. If we do, we will post the updated Privacy Policy on the Website and update the “Last Updated” date. Where required by applicable law, we will provide additional notice of material changes.

Children’s Privacy

Our Website and Services are not directed to children under 16 years of age, and we do not knowingly collect Personal Information from children under 16. If you are under 16, do not use the Website or Services or provide us with any Personal Information. If we learn that we have collected Personal Information from a child under 16, we will delete that information as required by applicable law. We do not knowingly sell or share the Personal Information of consumers under 16 years of age or use their Personal Information for targeted advertising without affirmative authorization where required by applicable law. If we have actual knowledge that a consumer is under 16, we will comply with applicable requirements relating to the consumer’s Personal Information. If you believe we may have collected Personal Information from or about a child under 16, please contact us at privacy@surfside.io.

Information We Collect and Sources

We collect Personal Information directly from you, automatically through the Website and our Technology, and from retailers, brands, Clients, service providers, and other third parties in connection with the Services. The Personal Information we collect depends on how you interact with us, our retail and brand partners, the digital properties on which our Services are available, and advertisements or other content delivered through our Services. The categories of Personal Information we may collect include:

• Identifiers – such as name, email address, telephone number, postal address, customer or loyalty-program identifier, account identifier, cookie identifier, mobile advertising identifier, device identifier, IP address, hashed identifier, online identifier, and other persistent identifiers.
• Internet, Electronic, and Network Activity Information – such as browser type, device type, operating system, internet connection, pages viewed, search activity, links clicked, referring and exit pages, date and time of activity, and interactions with websites, applications, advertisements, emails, or other online content.
• Commercial Information – such as products or services purchased, viewed, searched for, added to a cart, considered, returned, or otherwise interacted with; transaction date and time; purchase amount; retailer or store identifier; product category; order, transaction, or loyalty-program information; and other information about shopping or purchasing activity.
• Location Information – such as approximate location derived from an IP address or other device or network information and, where applicable, store or geographic-area information associated with a transaction, shopping activity, or device interaction.
• Demographic Information – such as age, race, gender, and other demographic attributes, where collected or received in connection with the Services.
• Professional Information – such as business contact information, employer, title, and professional role, when you contact us or interact with us in a business capacity.
• Inferences Drawn from Other Personal Information – such as audience segments and inferences about likely interests, product preferences, shopping patterns, purchase propensities, and other characteristics derived from information described above.
• Information You Provide Directly to Us – such as information contained in inquiries, requests, or other communications submitted through the Website.

We collect Personal Information from the following sources:

• You, including when you contact us, submit information through the Website, or otherwise communicate with us.
• Retailers and our other Clients, including information from retailer websites, mobile applications, loyalty programs, point-of-sale systems, ecommerce systems, customer relationship management systems, and other Client systems, subject to applicable law and our agreements with those Clients.
• Your browser, device, and online activity, including when you visit or interact with the Website, retailer or brand digital properties, advertisements, or other online content where our Technology is deployed.
• Brands, advertising partners, and other campaign participants, including information relating to advertising campaigns, campaign activity, and measurement or attribution.
• Service providers and other business partners, including advertising networks and exchanges, measurement and analytics providers, identity-resolution providers, data providers, social-media platforms, and technology partners.
• Our affiliates and related entities.

Our Use of Cookies and Similar Technology

We use cookies, pixels, web beacons, software development kits (“SDKs”), application programming interfaces (“APIs”), server logs, and similar technologies to collect information automatically and to support the Services.

• Cookies are small text files placed on your browser or device that help recognize your browser or device, remember preferences, and measure activity.
• Pixels and web beacons are small pieces of code or electronic files that can help us and our partners understand when a page, advertisement, or email has been viewed or interacted with.
• SDKs and similar technologies may be incorporated into mobile applications to collect information about app and device activity.
• APIs, server-to-server integrations, and server logs may be used to receive information from retailers, brands, and other partners, including information used for campaign activation, measurement, attribution, and reporting.

Your Choices. Depending on applicable law and the nature of the processing, you may have the right to opt out of the sale or sharing of Personal Information or the processing of Personal Information for targeted advertising. You may exercise available choices through https://surfside.io/optout. We also honor opt-out preference signals, such as Global Privacy Control, where required by applicable law. See Your Privacy Rights and Choices.

How We Use Personal Information

We may use Personal Information to provide, operate, support, measure, improve, and protect the Website and Services. The ways we use Personal Information depend on the nature of our relationship with you, the Services involved, and the information at issue.

To provide and operate our retail-media and advertising services. We may use Personal Information to:

• Develop, manage, deliver, and optimize advertising campaigns for retailers, brands, and other Clients.
• Create, maintain, activate, and manage audiences, including by using identifiers, shopping activity, transaction information, online activity, and inferences to determine the advertisements or content that may be relevant to an individual.
• Deliver advertisements and other marketing content on retailer-operated digital properties, third-party websites and applications, and, where applicable, in-store or other offline channels.
• Identify, link, or associate devices, browsers, accounts, and other identifiers for advertising delivery, frequency management, audience suppression, attribution, measurement, and reporting, where permitted by applicable law.
• Measure, attribute, analyze, and report on campaign performance, including by assessing whether advertising impressions, engagements, or other campaign activity are associated with purchases, transactions, or other conversion events.
• Conduct analytics, research, modeling, and reporting relating to advertising, shopping activity, transactions, audiences, campaign performance, and the effectiveness of the Services.

To maintain and improve the Website and Services. We may use Personal Information to administer and support the Website and Services; troubleshoot and debug; monitor performance; conduct testing, research, analysis, and quality assurance; develop and improve our Technology, products, and services; and understand how the Website and Services are used.

To communicate and respond to requests. We may use Personal Information to respond to inquiries, communicate with you about the Website or Services, provide requested information, manage our relationship with Clients and business contacts, and send administrative or service-related communications.

To protect our business and comply with law. We may use Personal Information to:

• Protect the security, integrity, availability, and functionality of the Website, Services, Technology, systems, networks, databases, and other assets.
• Detect, investigate, prevent, and respond to fraud, security incidents, malicious or deceptive activity, violations of our agreements or policies, and other illegal activity.
• Establish, exercise, or defend legal claims; comply with legal obligations; respond to lawful requests from law enforcement, regulators, courts, or other governmental authorities; and enforce our agreements.

For other disclosed or permitted purposes. We may use Personal Information for another purpose that is disclosed to you at the time of collection, with your consent where required by applicable law, or as otherwise permitted by applicable law.

How We Disclose Personal Information

We may disclose Personal Information to the following categories of recipients for the purposes described in this Privacy Policy:

• Retailers, brands, and other Clients. We may disclose identifiers and online identifiers; shopping and transaction information; online activity information; advertising and campaign information; audience segments and inferences; and, where applicable, location information to retailers, brands, and other Clients. We make these disclosures to provide, manage, deliver, measure, attribute, optimize, analyze, report on, and otherwise support advertising campaigns and the Services.
• Advertising, measurement, and technology partners. We may disclose identifiers and online identifiers; device, browser, and network information; online activity information; advertising and campaign information; audience segments and inferences; and, where applicable, shopping, transaction, or location information to advertising platforms, advertising networks and exchanges, demand-side platforms, publishers, ad servers, social-media platforms, identity-resolution providers, clean-room providers, measurement and analytics providers, and other advertising or technology partners. We make these disclosures to support audience activation, advertising delivery, frequency management, suppression, measurement, attribution, analytics, campaign optimization, reporting, fraud prevention, and related Services.
• Service providers and contractors. We may disclose the categories of Personal Information described in this Privacy Policy to vendors and other service providers that process information on our behalf or provide services to us, such as cloud hosting, data storage, infrastructure, security, analytics, communications, customer support, professional services, auditing, and billing support. These disclosures are made to operate, support, secure, improve, and administer the Website, Technology, and Services.
• Affiliates and related entities. We may disclose the categories of Personal Information described in this Privacy Policy to our affiliates and related entities for the purposes described in this Privacy Policy, including to operate, support, improve, secure, and administer the Website and Services.
• Professional advisers and corporate-transaction parties. We may disclose relevant Personal Information to auditors, attorneys, accountants, insurers, and other professional advisers, as well as actual or prospective purchasers, investors, lenders, financing sources, and their advisers, in connection with a merger, acquisition, financing, restructuring, reorganization, sale of assets, bankruptcy, or other corporate transaction.
• Government authorities and other parties for legal, security, and safety purposes. We may disclose relevant Personal Information to comply with applicable law, regulation, subpoena, court order, legal process, or governmental request; to enforce our agreements; or to protect the rights, property, safety, security, or integrity of the Company, our Clients, individuals, or others. We may also disclose Personal Information to detect, investigate, prevent, or respond to fraud, security incidents, malicious or deceptive activity, violations of our agreements or policies, or other unlawful conduct.
• Other parties at your direction, with your consent, or as otherwise disclosed at the time of collection. We may disclose Personal Information when you direct us to do so, when you consent to the disclosure, or as otherwise disclosed to you when the information is collected.

We may use, disclose, and otherwise process aggregated information and de-identified information for any lawful purpose.

In some circumstances, we process and disclose Personal Information on behalf of a retailer, brand, or other Client in accordance with that Client’s instructions and our agreement with the Client. The Client’s privacy notice may provide additional information about its information practices.

Your Privacy Rights and Choices

Depending on where you live and the nature of our processing of your Personal Information, you may have certain rights regarding your Personal Information. Subject to applicable law, these rights may include the right to:

• Know and access. Confirm whether we process your Personal Information and request access to, or information about, the Personal Information we collect, use, disclose, sell, or share, including the categories of Personal Information, sources, purposes of processing, and categories of recipients, as applicable.
• Correct. Request correction of inaccurate Personal Information we maintain about you.
• Delete. Request deletion of Personal Information, subject to applicable legal exceptions.
• Portability. Obtain a portable copy of certain Personal Information, where applicable.
• Opt out of sale and sharing for targeted advertising. Opt out of the sale or sharing or processing of Personal Information for targeted advertising, as applicable.
• Limit certain uses and disclosures of Sensitive Personal Information. Request that we limit certain uses or disclosures of Sensitive Personal Information, where applicable.

We will not discriminate against you for exercising rights available to you under applicable privacy law.

How to Submit a Request

You, or an authorized agent acting on your behalf, may submit a privacy-rights request by:

• Visiting https://surfside.io/optout
• Emailing us at privacy@surfside.io; or
• Calling us at (917) 512-1743.

To protect Personal Information and prevent fraudulent requests, we may need to verify your identity before processing certain requests. Our verification procedures may vary based on the type of request, the sensitivity of the Personal Information involved, and the nature of our relationship with you.

An authorized agent may submit a request on your behalf, subject to verification of the agent’s authority and, where permitted by applicable law, verification of your identity. You may also submit a request on behalf of your minor child, where permitted by applicable law.

If we deny your request, you may appeal our decision by emailing privacy@surfside.io with “Privacy Rights Appeal” in the subject line. We will respond to an appeal in accordance with applicable law. If we deny your appeal, you may have the right to contact the attorney general or other regulator in your state of residence.

We will respond to verified requests within the time period required by applicable law. Where applicable law allows an extension, we may extend the response period and will provide any required notice of the extension.

Advertising Choices

We may use or disclose Personal Information in connection with audience development and activation, advertising delivery, campaign measurement, attribution, analytics, and related Services. Depending on applicable law and the relevant data flow, these activities may constitute the sale or sharing of Personal Information or processing for targeted advertising.

You may opt out of the sale or sharing of Personal Information and the processing of Personal Information for targeted advertising by visiting https://surfside.io/optout.

An opt-out does not mean that you will stop seeing advertisements. You may continue to receive advertising that is not based on Personal Information subject to your opt-out, including contextual advertising. You may also continue to receive advertising from third parties that do not receive or are not required to honor your opt-out request.

Unless we can associate your request with other identifiers or an account, your opt-out may apply only to the browser, device, or identifier used to submit the request.

Opt-Out Preference Signals

Where required by applicable law, we recognize and honor opt-out preference signals, such as Global Privacy Control (“GPC”), as a request to opt out of the sale or sharing of Personal Information and the processing of Personal Information for targeted advertising, as applicable.

An opt-out preference signal generally applies to the browser or device from which it is sent. If we can associate the signal with an account or other identifiers, we will apply the signal to the extent required by applicable law.

Cookies and Device Controls

You may be able to control certain tracking technologies through your browser or device settings. For example, many browsers allow you to block or delete cookies, and mobile-device settings may allow you to reset or limit the use of mobile advertising identifiers.

You may also manage certain tracking technologies and advertising preferences through https://surfside.io/optout. Restricting cookies or similar technologies may affect the functionality of certain websites or applications and may not prevent all online advertising.

You may be able to opt out of certain interest-based advertising from participating companies through industry programs, including the Network Advertising Initiative and the Digital Advertising Alliance. These industry tools apply only to participating companies and generally apply only to the browser or device on which you make your selection.

Data Security

We maintain administrative, technical, and physical safeguards designed to protect Personal Information against accidental, unlawful, or unauthorized destruction, loss, or use. Our safeguards are designed in light of the nature and sensitivity of the Personal Information we process and the risks associated with our processing activities. No method of transmitting information over the internet or storing information is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident involving Personal Information, we will investigate and provide notifications as required by applicable law.

Third-Party Websites and Services

The Website and Services may link to, integrate with, or otherwise interact with websites, applications, platforms, and services operated by third parties, including retailers, brands, advertising platforms, publishers, and other business partners. This Privacy Policy does not apply to the privacy practices of third parties that we do not control.

We encourage you to review the privacy policy of each third party before providing Personal Information or using its website, application, platform, or service. A retailer’s or brand’s privacy policy may provide additional information about its collection, use, and disclosure of Personal Information in connection with its own website, application, store, loyalty program, or other services.

Data Retention

We retain Personal Information for no longer than reasonably necessary and proportionate to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

We determine retention periods based on the nature and sensitivity of the Personal Information; the purposes for which the information was collected or processed; the need to provide, support, secure, measure, attribute, analyze, report on, and improve the Services; our contractual obligations to retailers, brands, service providers, and other business partners; applicable legal, regulatory, tax, accounting, and recordkeeping requirements; and the need to establish, exercise, or defend legal claims.

When Personal Information is no longer needed for the purposes described above, we will delete, de-identify, aggregate, or otherwise dispose of it in accordance with applicable law and our retention practices.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated Privacy Policy on the Website and revise the “Last Updated” date at the top of the Privacy Policy.

If we make material changes, we will provide additional notice as required by applicable law. We encourage you to review this Privacy Policy periodically to remain informed about our privacy practices.

Contact Information

If you have questions or comments about this Privacy Policy and our privacy practices, contact us at: privacy@surfside.io.

‍