We, Moloco, Inc., provide this Supplemental California Privacy Notice (“California Notice”) to residents of the State of California (“consumers” or “you”). This California Notice supplements our Website Privacy Notice and Candidate Privacy Notice, and provides additional information about how we process your personal information and your legal rights.This California Notice uses terms as defined in the California Consumer Privacy Act, as amended from time to time, and its implementing regulations (“CCPA”).

This California Notice does not reflect our collection, use, or disclosure of your personal information, or data subject rights, where an exception or exemption under the CCPA applies, or where you are one of our current or former employees or workers. If there are any inconsistencies between our Website Privacy Notice or Candidate Privacy Notice and this California Notice, this California Notice prevails. You can download a PDF version of this California Notice.

For each of the questions in the sub-headings below, we have answered with respect to California residents: (a) who use of https://www.moloco.com/ and related sites, including business client portals, and interact with our emails (collectively, “Sites”), and who otherwise directly communicate, interact, or share personal information with us, |including customers, prospective customers, and corporate representatives of our vendors and other partners; and (b) who apply for a job via our Sites or who otherwise apply or are considered for jobs with Moloco, including through referrals, job boards, networking sites, recruiting agencies, or a prior connection with Moloco. Our CCPA Privacy Policy is in Section 2 of this California Notice.

1.1 What categories of personal information do we collect?

(a) Sites users

Non-Sensitive Personal Information:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including information about devices from which you access our Sites.
• Professional or employment-related information.
• Commercial information, including records of property, products or services purchased, obtained, or considered, or other histories or tendencies relating to the purchase, usage, or interactions with products and services.
• Internet or other electronic network activity information, including, but not limited to, interactions with Moloco Sites, services, or advertisements.
• Geolocation data.
• Audio, electronic, visual, or similar information.
• Inferences drawn from any personal information to understand your preferences and interests.

Sensitive Personal Information

• A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

(b) Job applicants

Non-Sensitive Personal Information:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, state identification card number, passport number, or other information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including information about devices from which you access our Sites.
• Characteristics of protected classifications under California or federal law, if you choose to provide this information or where we are required or permitted to collect it by law.
• Internet or other electronic network activity information, including, but not limited to interactions with Moloco Sites, services, or advertisements.
• Geolocation data.
• Audio, electronic, visual, or similar information.
• Professional or employment-related information.
• Education information (such as degrees, transcripts, and schools attended), as that term is defined under CCPA.
• Inferences drawn from any personal information to to understand your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive Personal Information

• A consumer’s social security, driver’s license, state identification card, or passport number.
• A consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to an applicant account.
• Personal information collected and analyzed concerning a consumer’s health, such as health information you choose to provide for accommodations in the interview process.

1.2 For what purposes do we collect and use personal information?

(a) Sites users

We may use your personal information for a variety of business purposes, including:

To provide and improve our Sites and other information requested, such as:

• Fulfilling our contract with you;
• Responding to questions, comments, and other requests, including customer or technical support;
• Allowing you to register for events;
• Authenticating individual identities, providing access to certain areas, functionalities, and features of our Sites;
• Measuring interest and engagement, ensuring quality, control and safety of our Sites, and improving our Sites;
• Providing you, subject to your preferences and consent settings, with content, advertisements and direct marketing, including through the use of cookies, pixel tags (also known as web beacons), local storage, and other technologies (“Tracking Technologies”) to automatically collect some of the information described above, make inferences about your interests and preferences, and tailor our online advertisements to you;
• Collecting and fulfilling your marketing preferences and consent; and

Administrative, business, operational, security, and legal purposes, such as:

• Pursuing our business objectives, such as research and development (including marketing research), network and information security, and fraud prevention;
• Developing new products and services;
• Carrying out audits;
• Communicating with you about your account, activities on our Sites and Privacy Notice changes;
• Preventing potentially prohibited or illegal activities;
• Enforcing our agreements;
• Complying with our legal obligations; and
• Evaluating or effectuating a potential merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or similar business transaction (collectively, “Business Transactions”).

Sensitive Personal Information

We generally do not collect sensitive personal information from Sites users. However, if we do collect sensitive personal information, we would only use it for some or all of the following purposes:

• To perform the services or provide the goods reasonably expected by you in your role, including those services and goods that are reasonably necessary for us to administer our customer relationships and for our workers to perform their duties;
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information, including in or via our premises, computers, software, networks, communications devices, and other similar systems;
• To resist malicious, deceptive, fraudulent or illegal actions directed at us and to prosecute those responsible for those actions;
• To ensure the physical safety of natural persons;
• To verify or maintain the quality or safety of our services and products; and
• To improve, upgrade, or enhance our services and products.

(b) Job applicants

We use your personal information as reasonably necessary and proportionate to manage our recruitment-related activities, such as to confirm your identity and work authorization status and otherwise comply with law. Background checks are carried out for some job locations and roles. If you are offered a job, recruitment-related personal data will be used for pre-hire purposes. If you become an employee, it will be used for onboarding and employment purposes. In some cases, we use your personal data to determine the need to provide you with appropriate adjustments or accommodations during the recruitment process or employment, when conducting internal audits or workplace investigations, or to support or defend legal claims.

1.3 Do we sell or share personal information?

Yes, with respect to Sites users (including those who apply for a job with us via our Sites) and recipients of our emails, because we may disclose your identifiers, Internet or other electronic network activity information, geolocation data, electronic information, and inferences about your preferences and characteristics to our advertising partners. Please see our notice of right to opt out of selling and sharing here: Your Privacy Choices.

Please also see our CCPA Privacy Policy at Section 2 below for additional information on how to opt out of selling and sharing.

1.4 What criteria do we consider when retaining personal information?

We retain personal information, including sensitive personal information, for as long as needed to fulfill the purposes described here. For example, to provide and improve our Site, evaluate applicants for employment, respond to inquiries, comply with our legal and tax obligations, and establish or defend legal claims. When determining the retention period for each category, we consider the nature and sensitivity of the information, the purposes for which it was collected, applicable legal and regulatory requirements, and whether those purposes can be achieved through other means. See Section 2.2 for your right to request deletion.

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2.1 Our Personal Information Handling Practices

We have set out below categories of personal information about California residents that we have collected and, as applicable disclosed, for a business purpose in the preceding 12 months. If we process de-identified information, we will maintain the information in a deidentified form and not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether deidentification processes used satisfy legal requirements.
We collect the personal information described below from the following categories of sources:

• directly from you (e.g., when you submit a form, register for an event, or apply for a job);
• automatically from your device and browser when you visit our Site (for example, through Tracking Technologies);
• from third parties such as recruiters, job boards, networking sites, and referrals; and
• from service providers and analytics partners that support our Sites and business operations.

Sensitive personal information

We collect a limited amount of sensitive personal information, as described above in Section 1.1. We do not sell or share any sensitive personal information. We disclose sensitive personal information only to service providers and contractors (for example, recruiting, security, and document-processing providers), and to government authorities where required by law, to help us operate our business, maintain security, and satisfy our legal obligations. We use sensitive personal information only for the purposes permitted under Cal. Civ. Code § 1798.121(a) and 11 CCR § 7027(m).
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We processed the personal information for the purposes set forth in Section 1.2 above. We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age.

2.2 CCPA Rights

• As a California resident, you have the following rights under the CCPA:
• The right to know what personal information we have collected about you,, including the categories, sources, purposes, third-party recipients, selling or sharing, and specific pieces of personal information. You may exercise this right twice in any 12-month period.
• The right to delete personal information that we have collected from you, subject to certain exceptions.
• The right to correct inaccurate personal information that we maintain about you.
• The right to opt out of the sale or sharing of your personal information by us. We disclose California residents’ personal information to advertising business partners for the purposes of supporting our advertising efforts and, as such, we “sell” or “share” personal information as these terms are defined under the CCPA. If you exercise your right to opt-out of the “sale” and “sharing” of your personal information, we may still disclose your personal information to third parties for purposes other than cross-contextual behavioral advertising, as described in our privacy disclosures.
• The right to limit our use and disclosure of sensitive personal information to purposes specified in Cal. Civil Code 1798.121(a).
• The right to access automated decision-making technology (ADMT) with respect to you, to the extent required by applicable law.
• The right to not receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA.

2.3 How to Exercise CCPA Rights

Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please submit a request through our webform available at https://www.moloco.com/privacy-policy, call +1-888-251-8829 (toll free), or email us at [email protected].

Verification: In your request or in response to us seeking additional information, you must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected. We may ask you for information to verify your identity and, if you do not provide enough information, we will not be able to fulfill your request. We will only use the personal information you provide to us in such a request for the purposes of verifying your identity and fulfilling your request.

Opt Out of Selling and Sharing:

• To opt out of selling and sharing, please click the following link and follow the prompts shown: Your Privacy Choices.
• We respond to opt-out preference signals communicated via the Global Privacy Control and will process such signals with respect to the browser or device communicating the signals. To use Global Privacy Control opt-out preference signals, please follow the instructions here: https://globalprivacycontrol.org/. We do not separately respond to web browser Do Not Track signals.

Authorized Agents:

• You can designate an authorized agent to make a request under the CCPA on your behalf if:
• The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and
• For verifiable consumer requests, you directly confirm with us that you provided the authorized agent with permission to submit the request.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

3. Changes

From time to time, we may revise this California Notice. When we do so, we will publish the revised California Notice on our website and update the “last updated” date above, in addition to taking any other steps required by law.

4. Contact Us

If you have any questions or comments about these disclosures or our practices, please contact us at:

Attn: Privacy Group
Moloco, Inc.
135 Commonwealth Dr.
Menlo Park, CA 94025
[email protected].

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