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GSN PRIVACY POLICY

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Effective Date: June 29th, 2020

Please read this Privacy Policy and the related GSN Terms of Service before using any GSN website, application or community feature.

GSN Games, Inc. and subsidiaries (collectively “GSN” or “we”, “our”, or “us”) are committed to protecting your privacy and take the protection of your personal data very seriously. This privacy policy (“Privacy Policy”) explains how we collect, use and share the personal data that you provide to us and what we collect when you use any of our websites (each, a “Website”) mobile applications (each, an “App”), and our chat service, forums, message boards, email service, messaging services, virtual communities, virtual assets, polls, surveys, and similar services (each, a “Community Feature”). The Website, Apps and Community Features are collectively referred to as the “Services.”

If you are located in the European Union (“EU”) or the UK, this Privacy Policy also informs you about the management of your personal data and your rights in accordance with Article 13 of the General Data Protection Regulation (“GDPR”).

Data Controller

GSN is the entity responsible for determining the means and purposes of processing personal data (i.e., the data controller) under this Privacy Policy and can be contacted as explained below in the How To Contact Us section. GSN has appointed a Data Protection Officer for issues related to personal data in the EU and UK, who can be contacted at dpo@gsngames.com.

Changes to the Privacy Policy

We ask that you read this Privacy Policy from time to time. We may modify it at any time in our sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on the Services. Where permitted by law, your use of the Services indicates that you accept the terms of this Privacy Policy.

GSN collects the following types of personal data to provide visitors, users and players with our Services and information relevant to your needs and interests:

Personal data you give us: You may give us personal data in a number of ways, including when you register to use our Services, receive offers, communicate with customer service, enter contests and accept prizes, and when you create an account.

·GSN Accounts: When you use certain Services, you may be required to register and create an account (“GSN Account”). You may be asked to choose a user name and password and to provide some or all of the following personal data, depending on which Service you use:

oYour real name

oDate of birth

oGender

oPostal address

oEmail address

oPhone number

Please note that your username and the city where you reside may be visible to other GSN users, depending on which Service you are using. In addition, when you make a purchase through our Services, either we or our payment processor will collect billing information, such as payment card information. We will retain data about your transaction history and any sweepstakes and other contests that you enter.

·Community Features: When you use our Community Features, your user name will be displayed, as will any content that you post. Some message boards may also display your IP address. All postings on Community Features will generally be available to, and freely accessible by, other users, and in some cases the general public. Because information posted will not be kept private, users should exercise discretion when using Community Features.

·Facebook: GSN may allow you to sign in and associate your Facebook account with the Services. When you do so, you allow GSN to access certain information from your Facebook profile that you have made available to be shared, including your Facebook ID, name, photo, and date of birth, and to use it (such as by posting your photo and name) in accordance with Facebook’s terms of use, this Privacy Policy, and GSN’s Terms of Service. Please refer to the privacy settings on Facebook for information about what data is shared with GSN and to manage sharing through your Facebook account.

You can use some aspects of the Services at any time without providing any personal data. While providing personal data is voluntary, you may not be able to take advantage of or participate in some of the Services, if you choose not to share it.

Personal data we get from outside sources: We also collect personal data about you (such as name, address, device IDs, location, Internet service provider, and usage and player information) from third parties, such as advertisers, platforms, customer rights management vendors, analytics companies, co-branded marketers, help desk vendors, and fraud detection companies. We use this data to improve the quality and relevance of the advertisements you see, improve the functionality of the Services, enable you to enter into competitions, or let you know of new developments in the Services. In the event that we receive such data and combine it with our customer records, the combined information will be treated in accordance with this Privacy Policy.

Personal data we collect automatically: We automatically collect information about the devices that you use to interact with the Services, as well as information about how you interact with the Services. The information that we automatically collect may include the following, depending on which Service you are using:

·Your IP Address;

·Device identifier;

·Web browser type and version;

·Operating system;

·Time zone;

·Web browsing;

·Location based upon IP Address;

·Precise geolocation of mobile device;

·GSN usage history;

·GSN game history and skill level;

·Page/app views; and

·Language.

How We Protect Children’s Privacy

GSN Services are general audience sites not directed to children under the age of 18. If we obtain actual knowledge that any information we collect has been provided by an individual under the age of 18, we will promptly delete that information.

If you are a parent or guardian who has discovered that your child has submitted his or her personal data to GSN, please send an email to help@gsngames.com to request deletion of that information. Please be sure to include in your message the same user name and password that your child submitted.

How We Use Personal Data We Collect About You

We use your personal data for the following purposes:

Communicate With You

·To provide you with customer support;

·To communicate with you about our products and services, including promotions and offers;

·To make suggestions and recommendations to you about goods or services that may interest you; and

·To let you know about new developments in the Services.

Manage and Improve Our Business Operations

·To provide you with access to the Services;

·To accept and process payments in connection with the Services;

·To improve your experience using the Services;

·To improve the functionality of the Services;

·To enable you to enter competitions;

·For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

·To allow you to participate in interactive features of our Services;

·To measure or understand the effectiveness of advertising we serve to you and others;

·To deliver relevant advertising to you; and

·To assist us in developing new products and improving our Services.

Ensure a Secure Online Environment and Comply with Legal Obligations

·Protect against and detect fraud, abuse or other unlawful activity;

·Enforce our Terms of Service, other corporate policies and industry standards; and

·Comply with all applicable laws and reporting obligations.

Unsubscribing From Communications: GSN uses your personal data to communicate with you directly via email, push notifications or direct mail, about purchases you have made and other related products and services we believe may be of interest to you, as well as related customer support. If you no longer want to be contacted, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us from the Menu in the App or on the Website in the FAQ section. To disable push notifications, access Settings on your device and select the App(s) you no longer wish to receive push notifications from.

To Support Business Services: We share your personal data with companies who perform services on our behalf to support our business operations, including the following:

·Product and/or experience customization;

·Distribution of marketing and promotional material;

·Website and App evaluation;

·Data collection, storage, management, analysis and, where applicable, deletion; and

·Other services to support our business operations, such as ad delivery and analysis.

To Provide Company Security: We disclose personal data when we determine that doing so is appropriate to:

·Verify compliance with and enforce our Terms of Service and other policies governing our Services;

·Protect our property, services and legal rights;

·Protect personal safety or the property of others;

·Respond to lawful requests from governmental authorities;

·Comply with applicable laws; and

·Support auditing, compliance and corporate governance functions.

To Offer Promotions: If you are a resident of the U.S. or Canada, you may participate in contests, sweepstakes or promotions in connection with our Services (“Promotions”). (EU and UK residents are not eligible to participate.) Such Promotions may be sponsored by or co-branded with a third-party company, who may obtain personal data that you submit in connection with the Promotions. We cannot control those third parties’ use of such data. If you do not want your personal data to be collected by or shared with such a third party, do not participate in these Promotions.

When entering a Promotion, we may ask for your consent to use your personal data or other information (such as name, voice or likeness) in advertising, promotional and marketing materials.

To Extend Offers from Other Companies: We may send you promotional mailings on behalf of other companies that provide game-related offers and other offers. If you sign up for the offers, we will share your GSN Account information with the offer provider.

If you are a resident of the EU or the UK, we will obtain your consent before using or sharing your information in this manner.

In the Event of Corporate Change: We disclose, sell or transfer information related to the Services, including personal data:

·To a subsequent owner, co-owner or operator of one or more of the Services; or

·In connection with a corporate merger, consolidation or restructuring; the sale of substantially all of our stock and/or assets; or other corporate change, including, without limitation, during the course of any due diligence process.

You will be notified by e-mail or prominent notice on our Website or in App in the event of a change of ownership or control of your personal data.

For Statistical Analysis: We disclose non-identifying, aggregated user statistics, such as the number of users who used the Services during a specific time period, to third parties for a variety of purposes, including describing our Services to prospective partners and other third parties.

Cookie Policy

Our Services place small data files on your computer or mobile device. These data files may be cookies, pixel tags, e-tags, or other local storage provided by your browser or Apps (collectively “Cookies”).

Some of these Cookies are technical (i.e., they allow us to provide the Services) and some are non-technical (i.e., they provide analytics about the use of our Services, allow us to remember your preferences, or facilitate advertising). We also use third-party advertisers (each, a “Third-Party Advertiser”) to market, sell and display advertisements on our Services. These Third-Party Advertisers may recognize Cookies we have placed (or place their own Cookie) on your device to collect information about your use of the Services for use in connection with their advertising activities.

How we use Cookies

We use both persistent and session Cookies. Persistent Cookies are used to improve your experience on our Services. This includes, for example, recording your acceptance of our Cookie Policy to remove the Cookie message that first appears when you use our Services. Session Cookies are temporary and are deleted from your device when your web browser closes. We use session Cookies to help us track internet usage.

We will not keep the personal data that we collect through Cookies for longer than is necessary to fulfill the purposes mentioned in this Privacy Policy.

Types of Cookies

How to delete Cookies

Most web browsers accept Cookies automatically. However, you can delete Cookies manually or set your browser to automatically delete Cookies on a pre-determined schedule. Most browsers will tell you how to stop accepting new Cookies, how to be notified when you receive a new Cookie and how to disable existing Cookies. You can find out how to do this for your particular browser by clicking “help” on your browser's menu or by visiting www.allaboutcookies.org.

Please note that if you decline to accept Cookies, you may not be able to take advantage of or participate in certain features of the Services.

Most browsers allow users to use a “private mode” by which Cookies are deleted after your website visit. Please read the help section of your browser to learn more about how to activate the “private mode.” You can still visit our website if your browser is in “private mode,” however, the user experience may not be optimal and some utilities may not work.

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Services from placing further Cookies on your device unless and until you adjust your browser setting as described above.

For more information on the development of user-profiles and the use of targeting/advertising Cookies, please see www.youronlinechoices.eu, if you are located in the EU, or www.aboutads.info/choices, if in the United States.

Adobe Flash Player

Our Services enable the use of the Adobe Flash Player, which generates “flash cookies” by default. Flash cookies remember user settings, preferences and usage similar to the browser Cookies referenced above, but flash cookies can store more information than browser Cookies and are managed through a different interface than the one provided by your web browser.

You can control the degree to which you accept flash cookies by accessing your Adobe Flash Player management tools directly through the settings manager for Adobe Flash, located at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you do not allow flash cookies to take any disc space on your computer, you may not be able to take advantage of or participate in certain features on the Service.

Web Beacons

Our web pages or e-mail messages may contain a small graphic image called a web beacon, which allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. We use web beacons to count visitors to our web pages or to monitor how our users navigate our Services, and we include web beacons in e-mail messages in order to count how many of the messages we sent were actually opened or acted upon.

IP Addresses

An IP Address is a number that is assigned to your mobile device, computer or network when you are linked to the Internet. When you use our Services, our servers log your IP Address. We use IP Addresses for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Services. We associate your IP address with other personal data you provide.

Third-Party Advertisers and Third-Party Analytics

Ad Serving Technology

Third-party advertising companies (each, a “Third-Party Ad Company”) also use Cookies, clear GIFs, web beacons or other technologies to collect information to ensure that appropriate advertising is delivered when you use the Services, calculate or control the number of unique and repeat views of a given ad, deliver ads that relate to your interests, and/or measure the effectiveness of ad campaigns.

The data that Third-Party Ad Company may collect for this purpose includes your IP address; device ID; information about your software, applications and hardware; machine or device make and model; advertisement(s) served; in-game location; length of time an advertisement was visible; other Internet and website usage information; web pages and mobile Internet sites which have been viewed by you (as well as date and time); domain type; size of the advertisement; advertisement response (if any); and angle of view. If you click on an ad that appears on the Services, data, such as your IP address, may be revealed to the advertiser (or the applicable Third-Party Ad Company).

The Third-Party Ad Company that deliver ads may combine the personal data collected with other information they have independently collected from other services or products. The collection and use by Third-Party Ad Company of personal data obtained through the Services and information they have independently collected from other services or products is governed by their own privacy policies.

To learn more about the data practices of our Third-Party Ad Companies and service providers (including opt-out mechanisms they may offer), see our Partners Page https://gsngamesnetwork.com/partners.html. You can also use your mobile device settings to manage interest-based advertising that appears on mobile applications; to do so, select “limit ad tracking” on Apple iOS operating systems and “opt-out of interest-based ads” on Android operating systems.

In addition, GSN uses pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our ad management partners (each, a “Management Partner”), who use them to recognize a unique Cookie placed by us or by another advertiser who works with the applicable Management Partner. The Management Partner may set and access its own Cookies on your web browser in order to serve ads it believes may be of interest to you based on the profile information you provided to us at registration (e.g., demographic information), your browsing behavior on the Services, as well as information collected about you by the applicable Management Partner elsewhere online. Management Partners may use information about you gathered from the Services to serve ads to you elsewhere on the Internet.

Analytics

Web analytics services that collect and analyze GSN users’ data, such as device ID and IP address, provide us with statistical information, such as where our users are located in the world, what content users view on our Services, and the size of our user base. We use this information to improve and personalize our Services.

How We Protect Your Personal Data

GSN has implemented an information security program that includes physical, technical and procedural safeguards designed to protect your personal data.

GSN will retain your personal data as needed to provide you with access to our Services and/or for as long as is necessary for the protection and pursuit of our legal rights and obligations under any laws that are applicable to our operations.

The Services may contain links to, or advertisements concerning, other websites. Other websites may also reference, advertise, or link to GSN. GSN is not responsible for the privacy practices or the content of such other websites. You should check the applicable privacy policy of any website you access through the Services.

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Location and Transfer of Personal Data

Personal data you provide to us and through our Services may be stored on servers, databases and with service providers in the United States and other countries whose data protection laws may differ from the jurisdiction in which you live. When we transfer personal information from the European Economic Area (“EEA”) or the UK, we put in place appropriate safeguards to ensure the safe and secure transfer and handling of such data.

Do Not Track Signals

Some browsers send signals or preferences to websites that you visit indicating that you do not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret Do Not Track (“DNT”) signals or a common definition of “tracking,” we do not currently respond to DNT signals on GSN websites.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal data by GSN to third parties for those third parties’ direct marketing purposes. To make a request to opt out of such disclosure, please use the Menu section of the App or the FAQ section of a Website.

The California Consumer Privacy Act (“CCPA”) also provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

Please see our Notice of California Consumer Data Collection and Sharing Practices Notice to Residents of California

Right to Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your player identification name and/or number; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) email.

Right to Request Deletion of Information

You have the right to request, in certain circumstances, that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your player identification name and/or number; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) email. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Information Regarding Participation in Data Sharing for Financial Incentives

We run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, certain games offer “Reward Videos” where players can earn virtual goods and / or game credits by watching targeted advertisements. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to Opt out of Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your personal information to third parties. To exercise this right, please visit the “Do Not Sell My Personal Information” webpage if you are using a Website or the Menu section of an App. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.

Right to Non-Discrimination

You have the right to receive non-discriminatory treatment based on your exercise of any of the privacy rights conferred by the CCPA.

How to Submit a Request

You may submit a request by filling out a Consumer Data Request form accessible from the Service you are using or by contacting us at the email address below applicable to the App or Website you are using or through the menu options in the App.

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For: (i) GSN Casino; and (ii) Lucky Homes

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If you are located in the EU or the UK, you have certain rights with respect to your personal data. If you would like to exercise those rights, please contact us at the email address below applicable to the App or Website you are using or through the menu options in the App.

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For: (i) GSN Casino; and (ii) Lucky Homes

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We will rely on the following legal bases for processing your personal data, depending on our purpose for such processing.

You have consented to the processing of your personal data: We will obtain your consent before using or sharing your data for advertising that is targeted based on your browsing history, online behavior or other personal data that we or third parties may have collected about you. If you consent to our use of your personal data for any purpose, you have the right to withdraw consent at any time by contacting us, as explained above, or through the App in which you provided consent.

We have a legitimate interest in processing your personal data: GSN has a legitimate interest in processing your personal data for certain business and security purposes and to comply with applicable laws, including, but not limited to, the following:

·Product and Service development, management, delivery and enhancement;

·Fraud detection and prevention;

·Network and system security;

·General corporate operations;

·User personalization;

·Compliance with applicable foreign laws;

·Communications regarding your purchases; and

·Non-targeted marketing and advertising.

You have the right to object to our processing of your personal data based on our legitimate interests. You can do so by contacting us through the App(s) you are using, as described above. The processing of some types of personal data is necessary to provide you the Services. Therefore, if you object to certain types of processing, we may not be able to provide you the Services.

Processing is necessary for compliance with a legal obligation: We will process personal data when necessary to comply with an obligation under EU or EU Member State law.

If we intend to use personal data that we have collected for a different purpose than was described to you, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.

Rights of Individuals Located in the EU or UK

If you are located in the EU and UK, you have the following rights, subject to applicable exceptions, under the GDPR and UK data protection laws:

Right of access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you are located in the EU or UK and you would like a copy of the personal data that GSN holds about you, please send a description of the personal data you would like a copy of and proof of your identity to the emails set forth above.

Right to correction: You have the right to correct any inaccuracies in the personal data we hold about you and, where applicable, complete any incomplete personal data that we hold.

Right to erasure: You have the right to request that GSN erase the personal data that we hold about you, if one of the conditions in Article 17 of the GDPR applies.

Right to restriction of processing: You have the right to restrict our processing of your personal data, if one of the conditions in Article 18 of the GDPR applies.

Right to data portability: You have the right to receive personal data concerning you in a structured, common and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.

Right to object: You have the right to object to processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights and freedoms of the data subject, or the processing serves the purpose of asserting, exercising or defending legal claims.

Right to withdraw consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

If you are located in the EU or UK and you would like to invoke any of these rights (other than “access,” which is explained above), you can make the appropriate change through your GSN Account, or you can contact us through the App(s) you are using, as described above.

Lodging a Complaint

Under Article 77 of the GDPR, if you are located in the EU or the UK, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes your rights under the GDPR. The right to lodge a complaint may be invoked in the EU Member State in which you reside, in which you work or where the alleged infringement occurred.

How You Can Contact Us

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GSN is dedicated to protecting your personal data and welcomes comments and questions on this Privacy Policy. You may e-mail us at the following address: help@gsngames.com.

© 2020 GSN Games, Inc. All rights reserved.

Notice of California Consumer Data Collection and Sharing Practices

The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in the GSN Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.

·Personal Identifiers:

·We collect your name, email address, phone number, and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.

·You provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account.

oWe do not collect your Driver’s License or passport number.

oWe do not collect any medical information or health information about you.

oWe collect your social security number only if you are a player of WorldWinner and choose to withdraw money that you have won, in order to comply with tax law.

oWe collect your IP address automatically when you use our Services.

oWe collect your Device ID automatically when you use our Services.

·Protected Classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We do not collect your racial or ethnic origin, or sexual orientation.

·Commercial Information: When you engage in transactions with us, we create records of purchases made or considered, as well as purchasing histories or tendencies. We also create records of your play preferences and information about gameplay.

·Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.

·Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and information regarding your interaction with websites, applications, or advertisements automatically when you utilize our Services.

·Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates) unless you play for cash on WorldWinner. If we collect your precise location, when you use the Services for the first time, we ask for your permission to collect your precise location (e.g., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.

·Audio, electronic, visual, thermal, olfactory, or similar information: We do not collect your image, voice recording, or any thermal, olfactory, or similar information.

·Professional or employment-related information: We do not collect information about your current employer or your employment history.

·Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.

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·Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.

We share the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of service providers with whom we share information and the services they provide are described in this Privacy Policy.

On certain occasions, we also sell information to third parties. An external party may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit. We sell the following information:

·Personal Identifiers: We provide your IP address and Device ID to our advertising partners.

·Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to our advertising partners.

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We may also disclose information to other external parties who are not listed here when required by law or to protect our Company or other persons, as described in the GSN Privacy Policy.

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