This TWIGtv B2B Privacy Notice (“Notice”) describes how TWIGtv, Inc. and its affiliates (“TWIGtv,” “we,” or “us”) collect, use, and disclose personal information about you in your role as an employee, independent contractor, owner, director, or shareholder (“you”) of an organization that is doing business or may be conducting business with us (“business partners”).

TWIGtv collects and processes personal information about you in the course of our business, including:

• When you use TWIGtv’s products and services for business partners, including TWIGtv websites, TWIGtv OneView, TWIGtv Ad Manager, TWIGtv’s software development kits, reference designs, the TWIGtv developer portal, dashboard, and other developer tools (collectively, “TWIGtv B2B Services”);
• When you make contact with us, such as when you request information from us or interact with our emails, surveys, e-newsletters, and marketing materials;
• When you interact with us, whether through in-person or virtual events; and
• As a result of your relationship with our staff or one of our business partners.

This Notice applies only to our processing of personal information gathered about you in the course of conducting business with other businesses. Information collected outside of this context is governed by our other privacy policies. For example, information collected during your interaction with us as a consumer of our products and services is governed by the TWIGtv Privacy Policy.

Part I. Information Collection

TWIGtv may collect and process the following personal information about you, as described below:

A. Information You (or someone on your behalf) Provide

1. Registration Information
   When you (or someone on your behalf) sign up for an account for TWIGtv B2B Services, when you visit one of TWIGtv’s offices or attend our virtual events, we may ask for information such as your name, address, email address, telephone number, job title, your employer, and the name of your business or website. You will also be asked to provide a password for your TWIGtv business account.
2. Payment Information
   If you buy advertising services from us, we will collect payment information, including your credit or debit card number, employer identification number, and tax ID. If you are a publisher who monetizes your channel on TWIGtv’s streaming platform, we will also collect financial account information (e.g., for your bank or PayPal account), tax ID, and currency details in order to enroll in the TWIGtv Partner Payouts Program and process payouts.
3. Communications
   When you contact us directly in the ordinary course of doing business, for example, to inquire about TWIGtv B2B Services, we may receive additional information you provide, such as your name, email address, and phone number, and the contents of the message and attachments that you may send to us. You may also provide us with information if you subscribe to marketing communications from us or to obtain content such as product information, white papers, and reports.
4. Information You Provide About Others
   We also collect the personal information of other people, for example, if you invite or refer our products or services to other people by providing their names 

or email addresses. We rely on you to obtain any required permissions in advance to allow us to collect their personal information.

1. Comments, Reviews, and Feedback
   You can provide comments, reviews, and feedback regarding the TWIGtv B2B Services (e.g., on TWIGtv’s developer forums, blogs, and message boards), and accounts on third-party social networking sites. Information posted in these venues may be visible to the public. Please be mindful of your own privacy needs and those of others as you choose what to disclose and make public. We cannot control the privacy or security of information you choose to make public.

B. Information Collected Through TWIGtv B2B Service

1. Device Information
   We may receive information about the browser and devices you use to access the Internet, such as device types and models, MAC address, IP address, operating system type and version, browser type, and language.
2. Usage, Location, and Analytics Information
   We and our vendors and service providers, such as analytics and marketing partners, collect information about your online activities over time and across different online services. For example, we use cookies, pixel tags, web beacons, SDK, device identifiers, or similar technologies to recognize you when you use TWIGtv B2B Services, and to collect information such as the number of visits, which features, pages, or content are popular, and to measure your browsing activities. When you visit one of our offices, we also collect information about your location through the electronic access card or key FOB that we issue to you. These technologies allow us to optimize the operation of our services, improve and personalize the services, and to provide, personalize, and measure advertisements.

1. Audio and Video Recordings
   When you visit a TWIGtv office or attend a virtual event, we may collect videos and images of you, including through security cameras and webcams, and audio or video recordings from the meetings you attend.

For full details on how we manage your information or to contact us, please email us at twig@calltwig.com.

Part II. Information Usage

Your personal information is used for the following purposes:

1. Support, Maintenance, and Provision of Services
   We use your personal information to provide and maintain our services and to process and fulfill your requests.
2. Improvement of Products and Services
   We use your information to understand and analyze how you use our services, to improve, optimize, and enhance our services, and to develop new products, services, features, and functionalities.
3. Personalization
   We use your information to personalize your experience on our services.
4. Managing Business Relationships
   We use your information to manage and maintain our relationship with you and our business partners, including account management, the selection and vetting of partners, gathering information regarding partners, and performing due diligence reviews.
5. Marketing, Advertising, and Promotions
   We use your information for marketing purposes, including sending you emails and text messages about products, events, promotions, and offers from TWIGtv or its partners, and to measure and understand the effectiveness of our marketing.
6. Analytics and Performance
   We use your information to measure performance and analyze key metrics relevant to our business.
7. Service Communication and Customer Care
   We use your information to communicate with you, including sending you service information such as confirmations, invoices, notices, updates, security alerts, surveys, and support and administrative messages; and to respond to your comments and questions and provide customer service.
8. Business Operations, Security, and Fraud Prevention
   We use your information for operational reasons, including to secure our IT and network systems, premises, and other assets, and to protect, investigate, and deter against fraudulent, unauthorized, infringing, or illegal activity.
9. Legal Compliance
   We use your information to enforce or comply with contract obligations, laws, and regulations, to protect our business, partners, or users, and to exercise or defend the legal rights of TWIGtv.

Part III. Information Disclosures

1. Service Providers and Vendors
   We work with other businesses (including contractors and service providers) to provide services for us and to help with our operations, which may require that they access and use your information. For example, we may use companies to communicate with you (via telephone, email, or letter) about our products and services, to send information to you, to process and collect payments, to provide customer support, and to perform analytics.
2. Advertisers, Ad Networks, and Other Advertising Partners
   We work with ad networks and other advertising partners to show you ads that may interest you, including ads for TWIGtv products and services. We disclose information to these ad networks, advertising partners, and our advertisers, and they may set and access their own cookies, pixel tags, and similar technologies on the TWIGtv B2B Services.
3. Advertising Measurement Providers and Services
   We work with advertising measurement providers and their service providers to help us understand information about the content and ads viewed on TWIGtv B2B Services, and the effectiveness of ad campaigns, including the audience that saw their ads and how they responded.
4. Corporate Affiliates
   We may disclose your personal information to our current or future affiliates (parent company, subsidiaries, joint ventures, or other companies under common control), in which case we will require our affiliates to honor this Notice.
5. Consent
   We may also disclose personal information with your consent. For example, when you attend an event that we host with a joint marketing partner or sponsor, you may consent to us providing your information to that partner or sponsor for their own use, subject to their privacy policies.
6. Merger, Sale, or Other Asset Transfers
   We may also disclose your personal information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, or transaction involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
7. As Required by Law and Similar Disclosures
   We may disclose your personal information (1) to comply with laws or respond to lawful requests and legal processes, (2) to protect the rights and property of TWIGtv, our employees, agents, customers, and others, including to enforce our agreements, policies, and terms of use, (3) in an emergency to protect the personal safety of TWIGtv, its employees or customers, or any person, or (4) to investigate, prevent, or take action regarding illegal or suspected illegal activities.
8. Aggregated or De-Identified Information
   We may disclose aggregated or de-identified information (i.e., information that does not personally identify you directly) or statistical information about you for a variety of purposes, including for their own uses to improve products and services for us and others, and to make ads more relevant to your interests.

Part IV. Information Access and Choices

1. General Requests
   If you have a TWIGtv B2B Services account, you may view and update some of your information by logging into your account. If you wish to request access, correction, or deletion of personal information that we have collected about you, please submit your request to twig@calltwig.com. We may decline requests that are unreasonable, prohibited by law, or not required to be honored by applicable law.
2. Email Marketing Choices
   Our marketing emails provide instructions on how to opt out of further marketing communications. If you opt out, we may still send non-marketing emails, such as those related to your TWIGtv B2B Services account or business dealings with us.
3. Personalized Advertising Choices
   You can request TWIGtv to stop personalizing your ads on TWIGtv B2B Services by accessing our Opt-out tool. This tool will apply only to the specific device or browser and will not affect personalized advertising across other browsers or devices.

Part V. Modifications

We may amend this Notice at any time by posting the updated version on TWIGtv B2B Services or by providing notice as required by applicable law.

Part VI. Additional Notice for California Residents

This section supplements the information contained in the Notice and applies only to the Personal Information of California residents who have a business relationship with us.

For California residents’ privacy rights and how to exercise them, refer to the full notice by contacting us at twig@calltwig.com.

Part VII. Additional Notice for Residents of the European Economic Area (EEA), Switzerland, and the United Kingdom (UK)

1. Legal Basis for Processing Personal Information

If you are located in the European Economic Area, Switzerland, or the United Kingdom, our legal basis for collecting and using your personal information will depend on the personal information and the specific context in which we collect it. We typically collect personal information from you (1) where we need the personal information to enter into or perform a contract with you, your employer, or a business partner on whose behalf you are acting, (2) where we have your consent to do so, (3) where the personal information is needed to comply with a legal obligation, or (4) where the processing is in our legitimate interests (or those of others) and is not overridden by your rights. These legitimate interests may include the operation, maintenance, and improvement of TWIGtv B2B Services, our products and services, communications necessary to provide TWIGtv B2B Services to you, fraud prevention, network and information security, marketing activities, and detecting or preventing illegal activities.

If you have questions about the legal basis for how we collect and use your personal information, please contact us at twig@calltwig.com.

2. Privacy Rights

Subject to the law in your country or state, you may have the following data protection rights:

• The right to access, correct, update, or request deletion of your personal information.
• The right to object to the processing of your personal information, ask us to restrict processing, or request portability of your personal information.
• The right to opt-out of marketing communications from us at any time.
• The right to withdraw your consent at any time if we have collected and processed your personal information with your consent.
• The right to complain to a data protection authority about our collection and use of your personal information.

To exercise these rights, please contact us at twig@calltwig.com. Please note that certain personal information may be exempt from such requests in accordance with applicable data protection laws or other laws and regulations.

You will not usually have to pay a fee to access your personal information or exercise any of your other rights. However, TWIGtv reserves the right to charge a reasonable fee if your request is unfounded or excessive. TWIGtv may also refuse to comply with the request in such circumstances.

TWIGtv may need to request specific information from you to help us confirm your identity and your right to access the information (or to exercise any of your other rights).

3. Cookie Choices

To opt-out of non-essential cookies on our websites, you can access our Opt-out tool. This opt-out mechanism applies only to the specific device or browser you are using to opt-out and will not affect activities on other browsers or different devices.

4. Transfers

TWIGtv is a global company with affiliates, business processes, management structures, and technical systems that cross borders. Information collected by TWIGtv may be transferred and processed in any other country where TWIGtv or its service providers maintain facilities, including jurisdictions that may not have data privacy laws equivalent to those in your home country. Information may be subject to the laws of the country in which it is held, including possible disclosure to governments, courts, or law enforcement under the laws of that country.

5. Data Privacy Framework

TWIGtv complies with applicable data privacy frameworks for processing personal information transferred from the EU, UK, and Switzerland to the United States and other jurisdictions. For more information about our certification under these frameworks, please contact us at twig@calltwig.com.

6. Retention

TWIGtv retains your personal information for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, and reporting requirements. To determine retention periods for personal information, TWIGtv considers the following:

• The amount, nature, and sensitivity of the personal information.
• The potential risk of harm from unauthorized use or disclosure of your personal information.
• The purposes for which TWIGtv processes your personal information and whether those purposes can be achieved by other means.
• Applicable legal requirements.

7. Data Controller

The primary controller of your information when using the TWIGtv B2B Services is TWIGtv International B.V. However, this may change depending on the product or service. If you have any questions about this, please contact us at twig@calltwig.com.

Part VIII. Additional Notice for California Residents

This section supplements the information contained in this Notice and applies only to California residents. It is intended to comply with the California Consumer Privacy Act (CCPA) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this section.

1. Your California Privacy Rights

If you are a California resident, you have certain rights with respect to your personal information, including:

• The right to know what personal information we have collected about you in connection with your business relationship with us, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties with whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• The right to correct inaccurate personal information that we maintain about you.
• The right to request deletion of personal information that we have collected about you, subject to certain exceptions.
• The right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising.
• The right to limit our use or disclosure of your sensitive personal information, where permitted by law.
• The right not to be discriminated against for exercising any of your California privacy rights.

You can submit a deletion, correction, or right-to-know request by contacting us at twig@calltwig.com. Such requests are subject to our ability to reasonably verify your identity. Upon making a request, we may ask you to provide additional information to verify your identity.

Please note, by submitting a request, your request will not affect the information we collected from you as a consumer of our products and services. You should review the TWIGtv Privacy Policy for more information about submitting requests related to data collected from you as a consumer.

2. Categories of Personal Information We Collect and Disclose

In the course of our business relationship with you, we collect and disclose the following categories of personal information as described in this Notice:

• Identifiers: such as name, address, email address, phone number, and device identifiers.
• Commercial Information: such as records of products or services purchased, obtained, or considered, and other purchasing or consuming histories.
• Internet or Other Electronic Network Activity: such as browsing history, search history, and information regarding your interactions with our website, application, or advertisements.
• Geolocation Data: such as general location based on your IP address.
• Audio and Visual Information: such as security camera footage and recordings of meetings, webinars, and presentations.
• Professional or Employment Information: such as your job title, role, and other employment details.
• Financial Information: such as account login information, credit card details, and payment history.

We disclose these categories of personal information to the following categories of third parties:

• Service providers and vendors.
• Advertisers, ad networks, and advertising measurement providers.
• Our affiliates.
• Law enforcement or other entities involved in legal or security matters.

In the past 12 months, TWIGtv has collected and disclosed the personal information outlined in the categories above for business purposes. Some of these data disclosures, under the CCPA, may be considered a “sale” of personal information or “sharing” of personal information for cross-context behavioral advertising.

3. Sensitive Personal Information

TWIGtv does not use or disclose sensitive personal information for purposes other than those permitted by the CCPA. We do not knowingly sell or share the personal information of consumers under 16 years of age for cross-context behavioral advertising.

4. Opt-Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to opt-out of the sale or sharing of your personal information. To exercise this right, you may contact us at twig@calltwig.com or use the opt-out tool available on our website. Please note that this opt-out mechanism applies only to the specific device or browser you are using and does not affect activities on other devices or browsers.

5. Authorized Agents

You may authorize another person (your “authorized agent”) to submit a request on your behalf. Your authorized agent should submit proof that you gave them permission to submit the request. We may still require you to directly verify your identity and confirm that you have authorized the agent to act on your behalf.

Part IX. Modifications to This Notice

TWIGtv reserves the right to modify or update this Privacy Notice from time to time. Any changes will become effective upon posting the updated version on TWIGtv B2B Services or as otherwise required by applicable law. We encourage you to review this Privacy Notice periodically to stay informed about our privacy practices.

U.S. FEDERAL AGENCIES

1. Amendment to Roku Distribution Agreement. Any U.S. government agency (“Agency”) using the Platform to distribute Applications or Content is subject to the terms of the Agreement with the following amendments. Capitalized terms used but not defined in this Federal Terms Amendment will have the applicable meanings stated in the Agreement.

2. Government Agency. “Government Agency” within the Agreement will mean the Agency itself and will not apply to, nor bind (a) the individual(s) who utilize the Platform on the Agency’s behalf, or (b) any individual users who happen to be employed by, or otherwise associated with, the Agency. TWIGtv will look solely to the Agency to enforce any violation or breach of the Agreement as modified by this Federal Terms Amendment, subject to federal Law.

3. Indemnification, Liability, Statute of Limitations. Any provisions in the Agreement related to indemnification and filing deadlines are hereby waived, and will not apply except to the extent expressly authorized by Law. Liability for any breach of or any claim arising from the Agreement as modified by this Federal Terms Amendment, will be determined under the Federal Tort Claims Act, or other applicable federal authority. Federal Statute of Limitations provisions will apply to any breach or claim.

4. Governing Law. Any arbitration, mediation, or similar dispute resolution provision in the Agreement is hereby waived. The Agreement and this Federal Terms Amendment will be governed by and interpreted and enforced in accordance with the laws of the United States of America without reference to conflict of laws. To the extent permitted by federal law, the laws of the State of California (excluding California’s choice of law rules) will apply in the absence of applicable federal Law. 

5. Limitation of liability. The parties agree that nothing in the Limitation of Liability clause or elsewhere in the Agreement in any way grants TWIGtv a waiver from, release of, or limitation of liability pertaining to, any past, current, or future violation of federal Law. 

6. No cost agreement. Nothing in the Agreement as modified by this Federal Terms Amendment obligates the Agency to expend appropriations or incur financial obligations. The parties acknowledge and agree that none of the obligations arising from the Agreement as modified by this Federal Terms Amendment are contingent upon the payment of fees by one party to the other. The parties further agree that any fee-based agreement for use of the Platform by the Agency would differ from this no cost agreement in that a fee-based agreement would be subject to federal procurement Laws. Any fee-based agreement therefore would require separate actions by both parties. The Agency and other interested U.S. Government users will comply with all applicable federal procurement Laws and guidance if they decide to enter into any separate fee-based agreement in the future.

Part X. Contact Us

If you have any questions or concerns about this Privacy Notice, or if you wish to exercise any of your rights under this Notice, please contact us at:

Email: twig@calltwig.com
Address: TWIGtv, Inc. – Privacy Office, Palm Coast, FL 30019