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Yaw Privacy Policy

This Privacy Policy and Notice at Collection (“Privacy Policy”) explains how Yaw entities

(“Yaw”, “us”, “our”, and “we”), collect and use Personal Information (defined below) and sets

out the basis on which Personal Information we collect from or about you will be processed by

us. This document aims to provide concise, transparent, intelligible and easily accessible

information about how we process personal data – please read it.

This Privacy Policy applies to all users of Yaw experiences provided via joinyaw.com and other

related Yaw websites (“Yaw Owned Sites”), and Yaw technology that is integrated on third-

party partner websites, app or mobile-device applications (“Partner Sites”) (collectively, “Yaw

Sites”). This Privacy Policy also applies to individuals who engage with Yaw in their

professional capacity on behalf of their company or employer in business dealings with Yaw.

Therefore, "you" and "your" means, depending on the context, either end-consumers who

interact with Offers (as defined below), or representatives of Partners (as defined below),

Advertisers (as defined below), or other business partners of Yaw. This Privacy Policy does not

apply where Yaw processes your Personal Information (as defined below) on behalf of any

Partners to enable those Partners to serve their own Offers and not those of any other

Advertiser. Please consult the privacy policies or notices of those Partners to understand how

they use your Personal Information. If you are a Yaw employee or contractor, or if you apply for

a job with Yaw, your Personal Information collected in the employment or job applicant contexts

will be subject to separate privacy policies that we provide to you where and when appropriate.

This Privacy Policy replaces and supersedes the last version of this Privacy Policy for all users.

What does Yaw do?

Yaw provides services to ecommerce companies (“Partners”) that allow you to receive offers,

promotions, product recommendations, coupons, discounts, app download invitations, and

calendar subscription invitations to purchase goods and products, and to interact with other

marketing services (including during or after a transaction) (collectively, “Offers”) from third-

party advertisers or merchants (“Advertisers. You may choose to sign up to receive

communications in respect of such Offers, including by email, phone or SMS, from Advertisers

or Partners, and from Yaw.

What are the consequences of opting into Yaw’s Offers?

There is no obligation for you to sign up to Offers, at all. If you sign up to any Offers, we may

share your Personal Information, where applicable, with the party identified in the Offer, so that

any Offers they have offered may be fulfilled by them, and so they may provide further

information associated with such Offers, as further detailed below under “Use and Disclosure of

your Personal Information.” Importantly, there are no negative consequences if you do not sign

up to an Offer, nor are you prevented from accessing the services in future from that company –

simply no further action will be taken in respect of that Offer.

Our commitment to privacy.

Yaw takes your privacy very seriously and is committed to protecting it, as well as securing the

data entrusted to us by Partners, Advertisers and you. We understand that you will only use our

service if you can trust us to protect your Personal Information and use it appropriately. For

more information on the steps we take to secure your data, see “Information security

safeguards” below.

What is Personal Information?

“Personal Information” or “Personal Data” is information about you which (i) can be used to

identify, contact or locate you; (ii) can be combined with other information that is linked to you;

or (iii) is defined as “Personal Data” or “Personal Information” by applicable laws or regulations

relating to the collection, use, storage or disclosure of information about you. Personal

Information includes contact information (e.g. email address, telephone number), online

information (e.g. IP addresses, device identifiers), and other data which can be used individually

or in combination with other data to identify an individual (such as gender, marital status, age, or

postcode).

Types of Personal Information that we collect, when, why and from whom (our basis for

processing).

We collect and process a number of categories of Personal Information, on the basis of the

legitimate interests of Yaw and its Partners and Advertisers:

 Personal Information you give us when you engage with us or sign up to Offers across

Yaw Sites (such as your name and email address);

 Personal Information you provide to us through our various customer contact channels

(such as your name, email address, phone number, and/or any other personal details

you choose to provide when you contact us);

 Personal Information about you provided to us by Advertisers and Partners (as part of

our services to them), such as your identifying details (such as email address, gender,

age/DOB, postcode, title, phone number), transaction details or conversion data (such

as what you purchased, when and via what method);

 Usage data about your interactions with the Yaw Sites and/or Offers or any

communications sent on behalf of Yaw, Advertisers or Partners, including:

o information relating to your Offer interaction, such as Offer click-through rates

and viewing data;

o information relating to the outcomes following your interaction with an Offer, such

as whether you made a purchase, signed up with the Advertiser, or claimed a

given Offer;

o device information and website analytics information retrieved from your

device/web browser, such as your device profile, IP address, browser

type/version, language preferences, access times, referring website address, or

your general geographic area based on your IP address;

 Information we automatically obtain using cookies, eTags/cache browsers, pixels, web

beacons/GIFs, local storage, or other identifiers or other tracking technologies on Yaw

Sites and in e-mails we send you, that tell us the pages you view, the links you click,

whether an email has been opened, transaction information and other actions relating to

our services and technology;

 If you engage with Yaw on behalf of your business or employer in furtherance of

commercial dealings with us, we will collect Personal Information in the course of

managing the relationship, such as your business contact information and our contact

history, your login credentials to access your Yaw account, and a history of your

company's transactions with Yaw. In addition to collecting this information on the basis of

our legitimate interests, we also collect and process some of this information in order to

enter into, execute, and carry out our contractual obligations with you.

 Personal Information about you that we may obtain from third-party sources and

platforms (including data validation services, authentication service providers (including

for calendaring services), public databases, data enrichment providers, social

networking sites, online marketing and segmentation providers and ad-targeting

companies) to supplement the information we collect from Partners and Advertisers and

directly from you. For example, when you sign up to an Offer using your email address,

we verify with a validation service that the email address is real, in order to ensure valid

registration information and prevent fraudulent signups. In other cases, we may use age

verification providers in order to ensure that Offers are appropriate for a particular

individual above or below the age of majority, or the age of digital consent.

In some circumstances where we process your Personal Information on the basis of our

legitimate interests and those of our Partners and Advertisers, separate consent may be

required by law for us to operate our technology (for example, in the case of cookies or other

tracking technology that we use to access end user devices or technology that identifies your

general location or geographic position). Your consent may be obtained by us or on our behalf

by our Partners and Advertisers.

The legitimate business interests referred to above, which have been balanced against the

rights and freedoms of data subjects and their reasonable expectations, include:

 (i) the provision and use of website preference management software and analytics

services ensuring customers have the best possible website experience by ensuring that

content is relevant, engaging and personalized for each user viewing content on Yaw

Sites (e.g. “if you just bought this product, you might like…”) or accords with the

Partner’s specified user journey or journey parameters;

 (ii) the provision and use of website brand management tools to promote brand safety

for website users and owners;

 (iii) ensuring website safety by ensuring Offers presented to users are age-appropriate

and shown only to their intended audience (e.g. not to children);

 (iv) the provision and use of website analytics and conversion tracking tools to assess

the transaction attributes to optimize future marketing campaigns and future marketing

strategy;

 (v) the provision of customer and email management software services allowing

customers to effectively subscribe or unsubscribe to Offers that may be of interest or

value to them;

 (vi) allowing website owners to recoup the actual cost of providing website services to

users;

 (vii) validating users to verify the accuracy of customer data and to reduce fraudulent

signups;

 (viii) creating and retaining evidential records to validate the provision of consent to

direct marketing;

 (ix) using limited data sets for suppression purposes to prevent further unwanted

processing for users who have either (a) objected to direct marketing or (b) have

exercised their right to erasure (in respect of Personal Information provided by them), if

applicable; and

 (x) managing our customer relationships with Partners and Advertisers, and overseeing

our vendors, service providers, and data processors to ensure compliance with

contractual and legal obligations.

Note that, depending on local data protection laws where you are located, you may have a right

to object to processing on the above basis – see below under “Your rights in relation to your

Personal Information.”

Note in order to offer .you a more consistent and personalized experience in your interactions

with Yaw, information collected through one Yaw service may also be combined with

information obtained through other Yaw services.

Use and disclosure of your Personal Information.

Yaw’s technology allows us to display Offers from Partners and Advertisers, and allows you to

make purchases or sign up to receive communications with respect to such Offers. The

following subsections detail how your Personal Information is used by Yaw (i.e. for what

purpose), as well as the basis on which we disclose information to our Partners and Advertisers

and other third-party processors.

(i) Use of Personal Information by Yaw

We use your Personal Information for purposes including:

 providing, maintaining, protecting, and improving our technology, products and services,

 monitoring the effectiveness of our services;

 selecting, displaying and providing to you Offers that are targeted and customized and

personalized to your interests, attributes, preferences and experiences;

 predicting what Offers are relevant and engaging to people like you, based on your

known characteristics;

 disclosing the information to Yaw’s Partners and, if applicable, Advertisers – as set out in

the sub-section (ii) below;

 making our services easier to use by eliminating the need for you to repeatedly enter

your information;

 Offer targeting and suppression purposes, including display retargeting;

 sending you confirmation messages, further details messages and follow-up reminders

for Offers that you have signed up to, via the applicable or appropriate medium including

email, SMS, or communicating with you at the telephone number provided or confirmed

(which may include using an automatic telephone dialing system or pre-recorded

message), on our own behalf and on behalf of Partners and Advertisers;

 where you have signed up on the Yaw Owned Sites, or verbally confirmed with our staff,

sending you marketing and promotional materials you have elected to receive;

 maintaining appropriate legal or business records;

 enabling us to conduct customer research and develop new services;

 validating the information you provide to us;

 verifying your identity in relation to privacy requests you make;

 to protect our rights, property or safety, our users and employees, or any third-party (incl.

Advertisers or Partners);

 complying with applicable laws and regulations; and

 if you engage with us in a business-to-business capacity on behalf of your business or

employer, in addition to the above, we also use your Personal Information to administer

and manage our relationship with you and your employer (such as record keeping,

payments, communicating with you, tracking outcomes, and verifying your eligibility and

suitability).

We may state a more specific additional purpose when we collect your Personal Information.

(ii) Disclosure of your Personal Information to Advertisers or Partners

 We disclose your Personal Information (including information you give us and Offer-

related information to the Partner) to Partners when you engage with Offers while on the

Partner’s site, including by swiping or clicking on Offers;

 We disclose your Personal Information (including email address and segmentation data

(e.g. gender, age/DOB, postcode, title, phone number and third-party provided data),

even where this information is not directly displayed on screen), to named Advertisers if

you indicate that you wish to accept their Offers (including by swiping or clicking) or if

you purchase a product offered by the Advertiser. For example:

Where a Partner or Advertiser has made an Offer, and you indicate that you wish to accept it

(including by swiping and clicking) or purchase the relevant product, we disclose your Personal

Information to the Partner or Advertiser (as applicable) so that any Offers they have offered may

be fulfilled by them, and so they may provide you with further information associated with such

Offers to you via the applicable or appropriate medium (including email, SMS, or communicating

with you at the telephone number provided or confirmed (which may include using an automatic

telephone dialing system or pre-recorded message)). That information is provided to such party

for the purpose of fulfilling the Offer, providing a transaction receipt, or other purpose explicitly

disclosed at the time of collection, and your information will be handled by that party in

accordance with its own privacy policy.

(iii) Further disclosure of your Personal Information

We may additionally disclose your Personal Information as follows:

 to third-party agents and processors, such as our technology vendors, CRM and data

management platforms, data transmission companies, email service providers, data

validation service providers, authentication service providers, data enrichment providers,

online marketing and segmentation providers; and ad-targeting companies, as

applicable, predominantly located in the USA, for third-party processing;

 to Advertisers or Partners if you have entered a contest or promotion sponsored by Yaw

via their site;

 to any member of the Yaw Group, meaning subsidiaries of parent company Peach

Works, Inc., and their respective professional advisors, directors, employees, contractors

and personnel;

 as required by any law, subpoena, court order, or other enforceable legal process

(including laws outside your country of residence);

 as necessary to detect, prevent, or otherwise address fraud, security or technical issues;

 as necessary for us to do in order to establish or exercise our legal rights or defend

against legal claims; or

 as part of or in anticipation of a business sale, merger, consolidation, investment,

change in control, transfer of substantial corporate assets, reorganization, liquidation, or

similar business transaction or corporate event;

 and for such other purposes that are consistent with the way we have informed you that

we will use your Personal Information in this Privacy Policy or at the time we collect your

Personal Information; and subject to appropriate confidentiality and security measures.

Disclosure of your Personal Information to recipients outside the United States

Yaw processes Personal Information in multiple countries, possibly located outside the country

where you live, with our primary servers located in the United States. Before we disclose your

Personal Information to an overseas recipient, we take steps as are necessary and reasonable

in the circumstances to help ensure that the overseas recipient does not breach privacy laws in

relation to your Personal Information.

Where we disclose your Personal Information to Advertisers and other third-party processors, it

is likely (although not assured) the Advertisers or third-party processor will be located in one of

the markets in which we operate or have a presence – namely the United States, Canada,

Australia, Singapore, Japan, the EU, the United Kingdom, New Zealand and any other countries

in which we operate.

Yaw discloses Personal Information of individuals located in the European Economic Area with:

(i) suppliers; (ii) other members of the Yaw Group; and (iii) Yaw’s Advertisers and Partners

located outside of the European Economic Area. Such transfers may be made: (a) to a third

country or territory that is assessed by the European Commission as ensuring an adequate

level of protection; (b) to recipients who have in place appropriate safeguards, such as standard

contractual clauses that are approved by the European Commission or binding corporate rules

that have been approved by a competent supervisory authority; or (c) where a transfer to a third

country is occasional and necessary in relation to a contract between us or in your interest or for

the establishment, exercise or defense of legal claims. In order to safeguard transfers of

personal data for EU residents outside of the EU, Yaw discloses information concerning EU

residents both (i) with suppliers and (ii) within the Yaw Group, on the basis of EU-approved

standard contractual clauses approved under Art 47 GDPR.

Information security safeguards.

The security of your Personal Information is a priority for us, especially when your personal

information is transferred outside the United States.

We take technical and organizational measures (including physical and electronic security)

designed to safeguard Personal Information from loss, misuse, unauthorized access,

modification or disclosure. The measures we use are designed to provide a level of security

appropriate to the risk of processing your Personal Information. However, no method of online

transmission or storage of information is 100% secure, and we cannot guarantee that your

Personal Information will always be safe no matter what measures we put in place. Specific

measures that we use include:

 restricting access to Personal Information where practicable;

 using industry-standard encryption to help protect data in transit and at rest;

 building and maintaining a secure (private) network with no direct access between the

internet and systems processing your data;

 using pseudonymization techniques such as hashing email addresses or device IDs that

we associate with you to reduce the risks when processing that data;

 conducting regular scans and penetration tests of our applications and networks to

identify (and address) any potential vulnerabilities;

 demanding equivalent security and confidentiality measures from any third parties we do

business with.

Data retention.

Yaw sets data retention periods in consultation with its Partners and Advertisers in determining

how long to retain the Personal Information about you supplied to us by them, subject to you

exercising your lawful data subject rights, and further subject to any requirement for us to hold

data for such period as may be required to establish, exercise or defend legal rights or ongoing

legitimate business interests (e.g. to prove that you signed up to a particular Offer or electronic

communication). These periods vary by market in accordance with local laws. Please refer to

the “Your rights in relation to your Personal Information” section below for more information

about how you can exercise your rights.

In respect of other categories of Personal Information and Personal Information collected on

Yaw Owned Sites, if Yaw has no ongoing legitimate business need to process your Personal

Information, we will take all reasonable steps to destroy the information and/or ensure that the

information is de-identified or anonymized or, if this is not possible (for example, because your

Personal Information has been stored in backup archives), then we will securely store your

Personal Information and isolate it from any further processing until deletion is possible.

We rely on the following criteria to help determine the appropriate retention periods: (i) the

necessity of the Personal Information to provide our services to Partners and Advertisers; (ii) the

types and sensitivity of Personal Information being processed; (iii) regulatory requirements that

we are subject to, including laws and regulations related to tax, employment, accounting, and

securities; and (iv) whether a legal claim might be brought against us, for which the Personal

Information would be relevant.

Yaw is not responsible for how long Partners and Advertisers may retain your Personal

Information. You should consult the privacy notices provided by Partners and Advertisers with

whom you interact in order to determine how long they may retain your Personal Information.

How we use Tracking Technologies.

Like many companies, when we display online Offers to you, we may use one or more

persistent “Tracking Technologies” (such as cookies, entity tags (eTags), pixels, web

beacons/ GIFs, local storage, or other identifiers on your device and browser settings) in order

to recognize you and your device each time we display Offers to you. We also apply statistical

probabilities to data sets, which attempt to recognize or make assumptions about users and

devices (e.g., that a user of multiple devices is the same user). Tracking Technologies may set

or alter settings or configurations on your device. We use both session and persistent Tracking

Technologies.

We use these technologies for a number of purposes to enhance your online experience, such

as for preference setting, Offer selection, analytics, conversion attribution and fraud reduction.

By rejecting Tracking Technologies, this does not mean that you will no longer see ads when

you visit Yaw Sites.

What this Privacy Policy does not cover.

Where Yaw provides information to a third-party (such as an Advertiser or Partner, for example,

in relation to an Offer), you acknowledge that your Personal Information will be handled by that

third party in accordance with its own privacy policy and not in accordance with the Yaw Privacy

Policy. You should consult our Advertisers’ and Partners’ own privacy policies for further details

on their use, disclosure, transmission or storage of your Personal Information.

This policy does not apply to the practices of organizations that Yaw does not own or control, or

to people that Yaw does not employ or oversee even if Offers, coupons or links to their websites

appear within our technology.

As a marketing technology provider, Yaw does not endorse any specific Partner or Advertisers,

nor does it take any responsibility for concluding or finalizing Offers on their behalf. Yaw gives

you the opportunity to elect to receive information about Offers that you determine are of

interest to you – without taking any of your specific personal circumstances into account.

Your privacy rights.

Where provided for by applicable law where you are located, you may have a number of rights

regarding the processing of your Personal Information, including some or all of the following

rights:

 the right to request access to, or copies of, your Personal Information that we process or

control, or have collected or shared about you, together with information regarding the

nature, processing and disclosure of that Personal Information (such as (i) the

categories of Personal Information that we have collected about you (including sensitive

Personal Information); (ii) the categories of sources from which we have collected

Personal Information about you; (iii) the business or commercial purpose for collecting

your Personal Information; (iv) the categories of Personal Information that we have sold

or disclosed about you and the categories of outside parties to whom the Personal

Information was sold or disclosed; and (v) information about the logic involved in any

automated decision-making processes used by us (if applicable), as well as a

description of the likely outcome of the process with respect to you);

 the right to request rectification of any inaccuracies in your Personal Information that we

process or control;

 the right to request, on legitimate grounds:

o deletion of your Personal Information that we process or control; or

o restriction of processing of your Personal Information that we process or control;

o the right to object, on legitimate grounds, to the processing of your Personal

Information by us or on our behalf;

 the right to request available information on the source of the Personal Information

where it is not from you;

 where we engage in profiling or automated decision-making as defined under applicable

laws, you may request to opt-out of such profiling or automated decision-making;

 the right to request that we limit our use and sharing of your sensitive Personal

Information only to those purposes described under applicable privacy laws (e.g.

providing our goods and services that you have requested, maintaining the quality of our

services, or protecting our platforms against illegal activity);

 where we rely on your consent to use your Personal Information (e.g. for the sending of

direct marketing by electronic mail), the right to withdraw that consent – see below under

“How do I withdraw consent/ unsubscribe?”

 where we process your Personal Information on the basis of our legitimate interests, the

right to object to the processing of your Personal Information.

 the right to file a complaint with a Data Protection Authority regarding the processing of

your Personal Information by us or on our behalf.

Non-discrimination and applicability of these rights

Other users may have similar rights granted to them under local laws. In such case we will act in

accordance with those laws. You will not to be discriminated against for exercising your privacy

rights. We may deny certain requests, or fulfill a request only in part, based on our legal rights

and obligations. As noted earlier, if you are an employee or contractor, or if you are a job

applicant, your rights with respect to your Personal Information collected in those contexts will

be described in a separate privacy notice that we provide to you where and when appropriate.

How to exercise your privacy rights (including through an authorized agent).

To exercise one or more of these rights, or to ask a question about these rights or any other

provision of this Privacy Policy, or about our processing of your Personal Information, please

send an email to admin@joinyaw.com . You may designate an authorized agent to make a

request on your behalf, using the same methods described here. When submitting the request,

however, please ensure the authorized agent identifies himself/herself/itself as your authorized

agent.

If you are not satisfied with the outcome of your request and would like to request further review,

you may send an email to admin@joinyaw.com with “Personal Information Requests Appeal” in

the subject line.

Verification and security.

We will take reasonable steps to verify your identity prior to responding to your requests. The

verification steps will vary depending on the sensitivity of the Personal Information and the

nature of your request. Note as a security measure, to ensure that we properly identify you,

such requests will be confirmed by way of reply email to the specific email address from which

the request was made. Note we will refuse requests made in respect of email addresses which

a user cannot access. User requests will be answered as soon as possible but not later than

one month after they are made or such other time that may be required under applicable privacy

laws.

How do I withdraw consent / unsubscribe from marketing communications?

Withdrawing consent from Yaw for direct marketing communications / unsubscribing.

Where you have given your consent for specific purposes, such as sending direct marketing by

electronic mail, Yaw provides a facility for you to withdraw such consent for Yaw to process the

Personal Information for that purpose. Note there are no adverse consequences for withdrawing

your consent.

To unsubscribe from:

 any specific electronic correspondence from Yaw, use the “unsubscribe” link contained

in emails we send you or reply “STOP” to any SMS message you receive;

 all future email correspondence from Yaw, please send an email

to admin@joinyaw.com with the subject “Withdraw Consent” and we will unsubscribe

you from all communications we send you.

Note: if you withdraw consent, we will keep a copy of your email address on file to record that

you have withdrawn your consent, and we will retain any information not provided on the basis

of consent, and any information to the extent necessary to establish, exercise or defend legal

rights. Even if you opt-out, we will still send you non-marketing emails, such as emails about

recent transactions or updates to our legal terms.

Withdrawing consent from Yaw’s Advertisers and Partners for direct marketing communications

/ unsubscribing.

In order to withdraw consent from our Advertiser and Partners, to exercise your data subject

rights or to otherwise access, update or delete any of your Personal Information retained by

them, you should contact them directly.

Where Yaw Advertisers and Partners have integrated with the Yaw unsubscribe mirroring

service, where you request to unsubscribe from any further email correspondence from Yaw,

you will be presented with the option to also unsubscribe from the applicable Yaw Partner or

Advertiser’s communications at the same time. This may only be done by following the

unsubscribe link contained in the emails we send you, and will be confirmed at the time of

making the unsubscribe.

Otherwise, if you wish to unsubscribe from any further electronic correspondence from a Yaw

Partner or Advertiser, you should submit a request to those organizations directly using the

unsubscribe facility provided by them, or otherwise as described in their communications to you,

or as set out in their privacy policy.

Is unsubscribing the same as opting out?

No. Unsubscribing/ withdrawing consent means we won’t send future electronic

communications to you unless you sign up again to subsequent Offers.

Additional privacy disclosures for California residents.

For purposes of California privacy law, if you are a resident of California, please note the

following additional disclosures about how your Personal Information is collected, processed,

used, disclosed or retained by Yaw.

Depending on the nature of your interactions with Yaw, we may collect and use the following

categories of personal information for the business and commercial purposes described in this

1798.80(e) (e.g. your name, email address, phone number, and date of birth); characteristics of

protected classifications under California or federal law (e.g. gender and age); commercial

information (e.g. your interactions with Offers, what you purchase from Advertisers or Partners,

which Yaw services you express an interest in or purchase on behalf of your business or

employer, and which areas of the Yaw Sites you visit); internet or other electronic network

activity information (e.g. your browsing activity on Yaw Sites, or your interactions with our online

content and emails that we send you); geolocation data (i.e., your general location based on

your IP address or ZIP code); professional information (e.g. your job title and business contact

information); and sensitive information (your login credentials to access your Yaw account); and

inferences.

Depending on the nature of your interactions with Yaw, we may use the above-described

categories of Personal Information for some or all of the business and commercial purposes

described in the Use and disclosure of your Personal Information section above.

We may collect the above-described categories of Personal Information from the following

categories of sources, as more fully described in the Types of Personal Information that we

collect, when, why and from whom section above: directly from you; automatically from your

devices; from our service providers; from Advertisers and Partners; from social networking sites;

from third-party data providers (e.g. data validation services; authentication service providers,

and data enrichment providers); from online marketing and segmentation providers and ad-

targeting companies; and from our corporate affiliates in the Yaw Group.

Depending on the nature of your interactions with Yaw, we may disclose each of the foregoing

categories of Personal Information to our corporate affiliates in the Yaw Group; our service

providers (e.g. our technology vendors, CRM and data management platforms, data

transmission companies, email service providers, data validation service providers,

authentication service providers, data enrichment providers, and professional advisors for tax,

legal, or similar purposes); online marketing and segmentation providers; ad-targeting

companies; Advertisers and Partners; with entities for legal compliance purposes; as necessary

to protect our company from fraudulent or illegal activity or to establish or exercise our legal

rights; and with potential acquirers of parts of our business. See the Use and disclosure of your

Personal Information section above for more details.

We may “sell” or “share” (as those terms are defined under California privacy law) the following

categories of Personal Information: identifiers; personal information categories listed in Cal. Civ.

Code § 1798.80(e); commercial information; Internet or other electronic network activity;

geolocation data; and inferences. We sell and share this Personal Information with advertisers,

advertising networks, and social networks. We do not knowingly sell or share the Personal

Information of consumers under 16 years of age.

We do not use or disclose sensitive Personal Information for purposes other than those

specified under applicable California privacy regulations.

Children’s privacy.

Yaw does not allow advertisements to be targeted at individuals under the age of 16.

Yaw does not knowingly collect Personal Information from or about children under the age of

13. If we learn that we have collected Personal Information of a child under the age of 13, we

will delete that data from our systems.

Yaw encourages parents and guardians to monitor their children’s activities online.

Complaints.

Yaw treats complaints relating to privacy very seriously. If you submit a concern or complaint,

we will endeavor to deal with it comprehensively and reach an outcome with which all parties

are satisfied. If you have any questions concerning any element of this Privacy Policy, or privacy

complaints, please contact the privacy team at admin@joinyaw.com.

Changes to this Privacy Policy.

Yaw may update this Privacy Policy at any time. If we do so, we will post any Privacy Policy

changes on our website, which you can review at any time. You will also be presented with this

services after any change will signify and confirm your assent to changes to our Privacy Policy.

Who to contact about this policy.

Yaw’s Data Protection Officer can be contacted via admin@joinyaw.com.

The data controller of your Personal Information collected as part of our services to you will be

the Yaw entity with whom you (or your company / employer) contracts with. Other members of

the Yaw Group with whom you interact or with whom data is shared in accordance with this

Version: September 2025