AUDIENCE TOWN PRODUCTS PRIVACY POLICY

AUDIENCE TOWN PRODUCTS PRIVACY POLICY

Last Updated: July 1, 2025

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This Products Privacy Policy (“Policy”) describes how Audience Town, Inc. (“Audience Town”, “we”, “our” or “us”) collects, shares, and uses your personal data in operating our analytics and data products which are designed to help our business customers,  partners, and the companies they work with advertise and market their goods and services to consumers in a relevant and efficient way (the “Products”), and your rights and choices regarding your personal data. Audience Town is the controller of the processing of your personal data described in this Policy.

This Policy only applies to our Products and does not apply to personal data we collect or process in connection with the operation of our corporate website or other business-to-business activities. To review our privacy policy for those activities, please visit the Audience Town Corporate and Website Privacy Policy . This Policy also does not apply when we act as a service provider or processor on our customers’ behalf, such as when we buy advertising media on behalf of our customers. When we are in this role, our customers decide how and why your personal data should be used.

CONTENTS

1. ABOUT PERSONAL DATA
2. OUR PRODUCTS
3. SOURCES OF PERSONAL DATA
4. TYPES OF PERSONAL DATA
5. HOW WE USE PERSONAL DATA
6. HOW OUR CUSTOMERS USE PERSONAL DATA
7. HOW WE DISCLOSE PERSONAL DATA
8. AGGREGATED AND DE-IDENTIFIED INFORMATION
9. GEOGRAPHIC SCOPE
10. NOT DESIGNED FOR MINORS
11. HOW LONG DO WE RETAIN PERSONAL DATA
12. DATA SECURITY
13. SUPPLEMENTAL STATE-SPECIFIC DISCLOSURES
14. YOUR OPT-OUT CHOICES
15. SUMMARY OF STATE PRIVACY RIGHTS
16. PROCESS FOR SUBMITTING STATE PRIVACY REQUESTS
17. REVISIONS TO THIS PRIVACY POLICY
18. CALIFORNIA SHINE THE LIGHT DISCLOSURE
19. CONTACT INFORMATION

1. ABOUT PERSONAL DATA

Personal data means any data that identifies or can be linked to an individual, including pseudonymous data that requires additional information to identify you. This includes email addresses altered into a unique code or tracking cookies that, while not directly identifying you, can be linked to you when combined with other information.

Personal data excludes de-identified or aggregated information that cannot reasonably identify you. While publicly available information (such as government records, information shared widely in the media, or information you’ve made public) is generally excluded, it can become personal data if combined with identifying information.

The meaning of sensitive personal data differs by jurisdiction, but often means data that reveals your race, religion, ethnicity, sexual orientation, gender identity, philosophical beliefs, or a medical condition or diagnosis; it sometimes includes any information about health or sexuality, or trade union membership. These categories sometimes overlap with characteristics of protected classifications under California or other U.S. state or federal law.

2. OUR PRODUCTS

We provide analytics services to businesses seeking to understand and reach potential home buyers and other consumers interested in residential real estate. Through our foundation analytics product, businesses can implement our proprietary tracking pixel on their websites to receive aggregated visitor statistics. Additionally, businesses may enhance their understanding of their customers by integrating their customer databases with our databases to obtain further insights about consumer attributes, digital behavior patterns, and aggregated home sales and listing data. We develop audience segments that we share with advertising platforms, which advertisers can purchase to deliver targeted advertising to potential home buyers and other consumers interested in residential real estate products and services.

We collect personal data through (1) our own or third-party digital tracking technologies, and (2) commercial data sources. When we’re able to make inferences regarding the data, for example that two or more browsers or devices likely belong to the same user or household, we may use this information to enhance the quality of our databases. Our internal systems store directly identifiable data (such as names and addresses) and pseudonymous data. To protect privacy, we convert directly identifiable information into coded identifiers before linking it with other pseudonymous data in our databases. We collect these identifiers across web browsers, mobile devices, and connected TV platforms.

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3. SOURCES OF PERSONAL DATA

Audience Town receives personal data from the categories of third-party data sources listed below:

• Consumer data compilers and resellers
• Advertising networks and publishers
• Customers and advertisers
• Public records
  

Our customers may implement our proprietary tracking technologies on their digital properties to collect personal data. These technologies collect information such as IP addresses, browser types, operating systems, device information, referring URLs, page visits, and user interactions (including clicks, scrolling, and viewing time). We require our customers to: (1) provide clear notices about data collection, (2) obtain necessary consents, and (3) maintain compliant privacy policies. Some customers may also share information from their CRM databases.

We receive personal data from commercial sources which may collect such data online or offline, including Tapad, Inc. We utilize Tapad’s graph as described in its privacy notice available at https://www.tapad.com/global-privacy-notice. The graph uses data collected from technologies that track your activity across third party websites, mobile sites and applications, including non-affiliated sites and services and tracking occurs across your various devices over time. While these technologies do not collect direct identifiers (such as your name, address, or telephone number), the data is used to create a profile that links your devices together by identifying patterns and connections in your online activities. We use that profile information to determine likely associated devices in creating our audience products to provide more tailored advertising about goods and services of interest to you across those various devices.

We also receive publicly available real estate and property information from government records and Multiple Listing Service (MLS) databases. When we combine publicly available information with other personal data in our databases, we treat the combined information as personal data subject to this privacy notice and applicable privacy laws.

4. TYPES OF PERSONAL DATA

We collect the following categories of personal data:

• Offline Identifiers, such as a real name, alias, postal address, email address, or other similar identifiers. Please note we do not collect social security numbers, financial account information, or similar information.
• Online Identifiers, such as Cookie IDs, Mobile Ad Identifiers (MAIDs), CTV IDs, Household IDs, Hashed Emails, IP addresses, user IDs, or other online identifiers.
• Internet or other electronic network activity information based on your browsing activity, such as behavioral or interest data such as web pages, content, or advertisements viewed or clicked on, and time stamps.
• Geolocation data, such as IP addresses or zip codes associated with identifiers. Please note that we do not collect precise geolocation which means location derived by technological means within 1750 feet.
• Commercial or transactions information, such as mortgage type and property tax information associated with your identifier, and mortgages purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Please note we do not collect any payment information such as credit card details.
• Survey or volunteered data, such as self-reported information provided by individuals to commercial sources regarding interests, opinions, activities, or characteristics, including household data such as the number of household members, number of earners in the household, or household income level.
• Professional or employment information, such as current or past field of employment.
• Demographic information, such as age, gender, occupation, household composition, marital status, or household income level.

Sensitive Categories of Personal Data: We may receive certain personal data that qualify as sensitive personal data, including race and ethnicity data, which we use to generate aggregated, anonymized statistical information (such as pie charts and graphs) as part of our analytics products.

Publicly Available Information. The publicly available information we receive from our commercial data sources includes property records, ownership details, lender information, mortgage and lien information, zoning and land use details, property description, property tax information, HOA fees, neighborhood characteristics, demographics and other statistics, and other real estate-related data.

Inferences. Our commercial sources also share inferred data, which means they have made certain inferences about your preferences, interests, characteristics, or attitudes prior to sharing personal data with us. Inferred data may also include inferences regarding your general (not precise) location based on IP address. We may also create inferences.  

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5. HOW WE USE PERSONAL DATA

Our Products enable our customers to analyze the effectiveness of their websites and marketing efforts. We also use personal data to create audience segments for the purpose of targeted advertising. We distribute our audiences to third party platforms that facilitate the delivery of digital advertising for their clients. Our Products are principally employed for digital marketing and advertising, but may also be used for other marketing channels, including direct mail.

A. Commercial Purposes: To provide our Products

• For Website Analytics and Consumer Insights. Our analytics products help our customers identify and understand their customers and prospective customers better. Our databases help our customers get a full view of their website visitors to help them gather insights on user interactions with their sites and predict future buying behaviors, build brand loyalty, predict trends in the marketplace, or for other media consumption or business intelligence purposes.
  

• For Interest Based Advertising. We make our audiences available to advertisers or agencies for purchase via third party platforms where they can activate on the data via real-time bidding to reach individuals who may be interested in the topic of the advertisement. Audiences are based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., if a particular consumer is relatively likely to purchase a home in a particular zip code, be looking for a home with 4 bedrooms, or enjoy apartment living). Our platform does not support the creation of audience segments that would reveal sensitive personal data of individuals or that would otherwise violate applicable laws, including without limitation the Fair Housing Act. We regularly review our syndicated taxonomy of audience segments for compliance with applicable laws.
  

• For Profiling. We process, create or supplement user profiles in our databases, including to create audiences. This includes the creation of “lookalikes” through a data modeling process where the audience segments are created by inferring that individuals in the audiences may have similar interests as individuals who have expressed an interest in the particular topic of the advertisement. We may infer a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, or aptitudes. However, note that we do not engage in profiling in furtherance of “decisions that produce legal or similarly significant effects.”
  

• For Matching or Linking Personal Data from Different Sources. We may identify and link browsers and devices likely to be associated with you so that ads and ad campaigns can be targeted, capped, analyzed, measured and sequenced across those devices. We may also create or use graphs or tables to connect identifiers and signals that correlate with individual consumers to help locate consumers across various channels or devices based on common personal, device-based, or network-based identifiers (e.g. cookie IDs, IP addresses, or hashed emails).

B. Business Purposes: To operate our Products

• To Develop and Improve our Products. We use your personal data for our own internal purposes, such as to operate, analyze, improve, test, update and verify our Products; and develop new products.
  

• For Other Internal Purposes. We also may use personal data for auditing for legal and other compliance purposes, aiding in ensuring security and integrity to the extent the use of personal data is reasonably necessary and proportionate for such purposes, debugging to identify and repair errors that impair existing intended functionality, short-term and transient use, and for the establishment, or the exercise or defense of legal claims.

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6. HOW OUR CUSTOMERS USE PERSONAL DATA

Our analytics customers are typically home builders or other companies in the real estate industry who are responsible for their own data processing activities, including when they use our analytics products through our self-service dashboard, or when they supply personal data to us for use with our Products. Our customers may also use our platform to create their own audiences, including to deliver targeted advertising to prior visitors to their digital properties.

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7. HOW WE DISCLOSE PERSONAL DATA

We may disclose your personal data to the following categories of recipients:

A. Commercial Recipients

• Marketing Platforms. We disclose audience segments with third-party platforms, including social media companies, data marketplaces, and advertising technology companies (such as demand and supply side platforms). These platforms may combine our audience data with other datasets or create and license derived audience data to their clients for targeted advertising. Our syndicated audience segments are typically purchased by advertisers and agencies who wish to reach relevant consumers across various industries and market segments. When sharing audience data with marketing platforms, we exclusively use pseudonymized information and do not disclose directly identifiable personal data with these third parties.  
  

• Customers. Our analytics customers accessing our dashboard within our proprietary platform primarily see aggregated statistics, metrics, and trends. Individual-level personal data is only visible to customers when it pertains to consumers already existing in their own databases.

B. Business Recipients

• Processors/Service Providers. We disclose your personal data to service providers that provide business, professional, or technical support services to us, help us operate the Corporate Services, or administer activities on our behalf. We require our service providers to restrict their use of personal data to only use your personal data in connection with providing services to Audience Town.  
• Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your personal data to certain third parties, such as the acquiring entity and its advisers.
• Legal Obligations, Security, and Safety. We will disclose your personal data as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.
• Competent Governmental, Regulatory, and Public Authorities. We may disclose personal data to governmental or law enforcement authorities to comply with valid legal or regulatory obligations or requests.
• Other Disclosed Purposes. We will disclose your personal data to other third parties at your direction or with your consent.

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8. AGGREGATED AND DE-IDENTIFIED INFORMATION

We may aggregate and/or de-identify your personal data so that such information can no longer be linked to you or your device. We may use and disclose aggregated or de-identified information that cannot reasonably be used to identify you in our discretion. We will not attempt to re-identify such information, except as permitted by law.

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9. GEOGRAPHIC SCOPE

Our Products are intended for use only within the United States, and we do not knowingly collect or process personal data of individuals located outside the United States. If you believe we have inadvertently collected your personal data which is subject to privacy laws outside of the United States, please contact us at privacy@audiencetown.com. If we learn we have inadvertently collected such data, we will promptly delete the data.

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10. NOT DESIGNED FOR MINORS

Our Products are not designed for or directed to minors, and we do not knowingly collect or process personal data of individuals under the age of 18 ("minors"). If you are a parent or guardian and believe we have collected data of a minor under the legal age in your jurisdiction, please contact us at privacy@audiencetown.com. If we learn we have inadvertently collected such data, we will promptly delete the data.

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11. HOW LONG DO WE RETAIN PERSONAL DATA

We will retain personal data for as long as necessary for the purposes outlined in this Policy, including for the purposes of satisfying legal, regulatory, tax, accounting, or reporting requirements. We retain data as required by applicable laws and data may be retained for business continuity, dispute resolutions, or enforcement of agreements.

In using the Tapad graph, we only use their latest graph build which incorporates recent opt-outs as described in the Tapad privacy notice. Personal data supplied by our commercial sources are deleted once both the contractual relationship and any applicable statutory storage periods have ended.

We retain data only for as long it is useful in our Products and re-evaluate our data retention policies on a regular basis to ensure that we only store data as needed to continue to deliver our Products.

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12. DATA SECURITY

We have implemented appropriate technical and organizational security measures designed to protect personal data in our databases against unauthorized access, use, or disclosure. However, despite these measures, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal data using industry-standard security measures, we cannot guarantee absolute security or that it will not or cannot be subject to breach or to hackers.  

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13. SUPPLEMENTAL STATE SPECIFIC DISCLOSURES

This Section contains supplemental privacy disclosures that may apply to you based on your state of residence and applicable State Privacy Laws. Audience Town shares audiences with third-party platforms for targeted advertising (also known as cross-context behavioral advertising). As a result, we may have shared or sold any of the personal data categories listed below, as those terms are defined by applicable State Privacy Laws.

The following chart details: (1) how and with whom we disclose, sell and/or share personal data; and (2) which categories of personal data we have sold or shared in the past 12 months. When we sell or share personal data, it typically occurs through the sharing of audience segments for advertising purposes.

14. YOUR OPT-OUT CHOICES

Regardless of where you are located or what jurisdiction’s laws apply, we offer all individuals a right to opt-out for the processing of your personal data in our databases if you do not want your personal data used for any of the purposes described in this Policy.

A. Audience Town Opt-Out

Under various U.S. state privacy laws, we are required to provide state residents with specific opt-out options. We use a single opt-out system that applies to all data processing activities in our databases (subject to limited exceptions described in this privacy policy). Below, we explain each opt-out right and its purpose. Please note that these rights may vary depending on your state of residence and the specific privacy laws applicable to you.

Please visit our Privacy Choices page to opt-out.

• Do Not Sell or Share My Personal Data: This opt-out allows you to stop us from selling your personal data or using it for targeted advertising (also known as “sharing” or “cross-context behavioral advertising” in California). Under applicable State Privacy Laws, a "sale" of personal data may occur even without an exchange of money.
  

• Opt-Out of Targeted Advertising: You can request that we stop using your data for creating audience segments used in targeted advertising.
  

• Limit Use of Sensitive Personal Data: If you are a California resident, you can request that we stop processing or sharing your sensitive personal data.
  

• Right to Opt-Out of Profiling: We do not use your personal data for automated decision-making that could produce legal or similarly significant effects on you.
  

• Right to Withdraw Consent. In situations where we rely on consent to process your personal data, you may withdraw your consent at any time by visiting our opt-out page or submitting a deletion request. Please be aware that withdrawing your consent does not affect the lawfulness of the processing of your personal data based on consent before its withdrawal.
  

B. Third Party Opt-Outs

You can also opt out of interest-based targeted advertising in general through the Global Privacy Control (GPC), an opt-out feature that you can enable on a number of internet browsers or download as a browser extension. You can also visit advertising industry opt-out pages operated by the Digital Advertising Alliance. We do not control these third-party opt-out tools, and opting-out using these tools may not eliminate all interest-based advertising.

15. STATE PRIVACY RIGHTS

Certain U.S. states have enacted comprehensive privacy laws that give specific rights to residents of those states. As of the Effective Date of this Policy, these states include those listed below (the “State Privacy Laws”). This list may be updated as additional state privacy laws come into effect.

• California
• Colorado
• Connecticut
• Delaware  
• Indiana [effective January 1, 2026]
• Iowa
• Kentucky [effective January 1, 2026]
• Maryland [effective October 1, 2025]
• Minnesota [effective July 31, 2025]
• Montana
• Nebraska
• New Hampshire
• New Jersey
• Oregon
• Rhode Island [effective January 1, 2026]
• Tennessee
• Texas
• Utah
• Virginia
  

Depending on where you reside and whether a State Privacy Law applies, you may have certain rights regarding your personal data as summarized below, subject to certain restrictions and variations under applicable local laws. Section 16 describes how you can exercise those rights and our process for handling your requests.

• Right to Opt-out of Certain Types of Personal Data Uses and Disclosures. Depending on your state of residence, you may have specific opt-out rights, including rights to opt-out of the sale or sharing of your personal data, or the use and disclosure of your personal data for targeted advertising as further described in Section 14.
• Right to Delete. You may have the right to request that we delete personal data that we have collected from you, subject to certain exceptions. When you submit a deletion request, we will delete the personal data we have collected from you, subject to any exceptions permitted by applicable law. We will retain certain personal data in our systems as necessary to comply with our legal obligations, including ensuring your deletion request is honored through maintaining a suppression list and corresponding recordkeeping obligations.
• Right to Know or Request Access to Your Personal Data. You may have the right to request that we disclose the categories of personal data we collected about you, the categories of sources from which we collected the personal data, the categories of personal data that we sold or disclosed, our business or commercial purpose for collecting and selling your personal data, the categories of third parties with whom we shared your personal data, and the specific pieces of personal data we collected about you. Residents of certain states may also have the right to request a list of the specific third parties with whom we share your personal data.
• Right to Data Portability. You may have the right to access your personal data in a portable format to the extent technically feasible. Please note that if you submit a portability request, we will delete your personal data in accordance with our deletion request process described in this Policy.  
• Right to Correct. You may have the right to correct inaccurate personal data that we may maintain about you, subject to appropriate verification. Please note that if you submit a correction request, we will delete your personal data in accordance with our deletion request process described in this Policy.  
• Right to Appeal. You may have the right to appeal if we decline to act on your request. If we deny your appeal, depending on your state of residence, you may have the right to escalate the matter to your State Attorney General or other relevant state regulator.

16. PROCESS FOR SUBMITTING STATE PRIVACY REQUESTS

To submit a privacy request, please visit our Privacy Choices page.

Authorized agents. Where permitted by state law, you may authorize an agent to make privacy rights requests on your behalf. We reserve the right to verify both the agent’s authorization and identity, including by contacting you directly before processing any request, including requesting information directly from you confirming that the agent is authorized to make such a request.

Verification. When you submit a request (other than an opt-out), we will verify your identity and state of residency as permitted under applicable law, and follow certain required procedures. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your state of residence or your identity (or an agent’s authority to make the request) and confirm the personal data we maintain relates to you.

Fees. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Depending on applicable law, you may be limited in how many requests you make within a twelve (12) month period.

Our response. We will respond to your request within the timeframe required by your state's applicable privacy law, which in most cases is 45 days from receiving it. If needed and permitted by applicable law, we may extend this period, but we will notify you of any extension within the initial response period. If we are unable to complete your request in full, we will provide you an explanation about the reasons why we could not fully comply.

Right to Appeal. Residents of certain states have the right to appeal our decision regarding your requests. If we deny your request and you wish to appeal, please email privacy@audiencetown.com and include:

1. A detailed description of your original request

2. Our response to your request

3. The reason for your appeal

We will respond in writing within the time frame required by applicable law, detailing any actions taken or reasons for denial. If you are not satisfied with our response to your appeal, you may contact your state’s Attorney General or relevant privacy authority.

• Find your State Attorney General: https://www.naag.org/find-my-ag/
• California residents can also contact the California Privacy Protection Agency: https://privacy.ca.gov/california-privacy-rights/your-right-to-privacy/  

17. REVISIONS TO THIS PRIVACY POLICY

Audience Town may update this Policy at any time by posting changes on this website. We encourage visitors to check this page regularly and refer to the "Last Updated" date at the top of this Policy.

18. CALIFORNIA SHINE THE LIGHT DISCLOSURE

Under California Civil Code Section 1798.83, California residents have the right to request information regarding the disclosure of their personal data to third parties for direct marketing purposes. If you are a California resident and would like to request such information, please email us at privacy@audiencetown.com. Please include "California Shine the Light Request" in the subject line of your email. We will respond to your request within 30 days as required by law. You must include your full name, email address, and postal address in your request so that we can verify your California residence and respond. Please note that we are only required to respond to one request per individual each year.

19. HOW TO CONTACT US

You can contact us at privacy@audiencetown.com or by mail at the following address:

Audience Town, Inc.

595 South Riverwoods Parkway
Suite 400
Logan UT 84321
United States

Prior versions:

Privacy Policy – June 1, 2024

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