Advertising Data Terms

Effective September 1, 2025 (Last updated July 9, 2026)

These Wee Amici Advertising Data Terms (these "Ad Data Terms") form a legally binding contract between Wee Amici, Inc. and its Affiliates ("Wee Amici"), and the entity agreeing to these Ad Data Terms (the "Advertiser") (each, a "party" and together, the "parties"), and govern the use of data in connection with the Ad Service, including data that may be shared between the parties, and with respect to the processing of Personal Information. The term "Advertiser", as used herein, will apply on a several basis to the entity whose Ads will be serviced by Wee Amici under these Ad Data Terms and any Agency acting on its behalf. These Ad Data Terms form part of the Supplemental Terms and Policies. Capitalized terms not defined in these Ad Data Terms shall have the meaning set forth in the Wee Amici Advertising Terms Definitions.

1. Definitions.

a. “Ad Details” means any information gathered from a specific Ad.

a. "Anonymous Data" or "anonymized" refers to data that irreversibly no longer allow a natural person to be identified directly or indirectly.

b. "Advertiser-Provided Ad Data" means data (including any Personal Information) that Advertiser provides to Wee Amici in connection with Advertiser's access to and use of the platform. Advertiser-Provided Ad Data may include, without limitation, Hashed Contact Data or Interaction Data.

c. "Collected Data" consists of Ad Details, Performance Data, and Wee Amici Data.

d. "Hashed Contact Data" means hashed names, email addresses, phone numbers, physical addresses, or other hashed identifiers that Advertiser provides to Wee Amici for use in connection with the platform.

e. "Wee Amici Ad Data" means Reporting Data and Tag Data.

f. "Performance Data" means data regarding a campaign gathered during delivery of Ads (e.g., number of impressions, interactions, and header information), but excludes Wee Amici Data.

g. "Reporting Data" means reports generated by Wee Amici measuring and analyzing Advertiser's Ad(s).

h. "Repurposing" means retargeting a user or appending data to a user's non-public profile for purposes other than performance of the Ad.

i. "Wee Amici Data" is any data that is: (i) preexisting Wee Amici data used by Wee Amici in connection with delivery of the Ad; (ii) gathered in the course of providing the Ad, including, without restriction, during delivery of Ads, that identifies or allows identification of Wee Amici, Wee Amici Properties, or Wee Amici's brand, content, context, or users, as such; or (iii) entered by users on any Ad Service Properties other than User-Volunteered Data.

j. "Tags" means Advertiser's (including its Agency’s or its service providers') HTML tag or other code or technology.

k. "Tag Data" means metrics and other analytics solely regarding the performance and effectiveness of Advertiser's Ad with Wee Amici's users.

m. "User-Volunteered Data" is Personal Information collected from individual users by Wee Amici during delivery of Ads pursuant to the Ad, solely in cases where it is expressly disclosed to such individual users that such Personal Information is collected by Wee Amici on behalf of Advertiser.

2. Collected Data.

a. Advertiser Usage. Advertiser may use Collected Data, solely on an aggregated and de-identified basis and solely to assess the performance and effectiveness of Advertiser’s Ads. Unless otherwise previously authorized by Wee Amici in writing, Collected Data shall not be used for any other purpose, including, without limitation, Repurposing. Notwithstanding the foregoing, Advertiser may use Performance Data for Repurposing, provided that such Performance Data is not joined or combined with any Ad Details or Wee Amici Data. In this Section 2(a), Advertiser excludes any applicable Agency.

b. Agency Usage. Agency shall not: (i) use Collected Data unless Advertiser is permitted to use such Collected Data; or (ii) use Collected Data in ways that Advertiser is not allowed to use such Collected Data. Notwithstanding the foregoing, Agency may: (1) use Collected Data on an aggregated and de-identified basis solely for internal media planning purposes (but not for Repurposing); or (2) disclose qualitative evaluations of aggregated Collected Data to its clients and potential clients, solely for media planning purposes.

3. Wee Amici Ad Data Use Restrictions.

a. Advertiser shall ensure that: (i) Wee Amici Ad Data is only shared with companies or individuals acting on Advertiser's behalf as Advertiser's service providers or data processors; and (ii) Advertiser's service providers or data processors appropriately protect Wee Amici Ad Data, limit their use of the Wee Amici Ad Data, and keep Wee Amici Ad Data confidential and secure.

b. Advertiser may use Wee Amici Ad Data on an aggregated or de-identified basis solely for the purposes of: (i) optimizing Advertiser's Ad campaigns run via the Ad Service; (ii) assessing the effectiveness and performance of Advertiser's Ad campaigns run via the Ad Service; and (iii) planning Advertiser's Ad campaigns to run via the Ad Service.

c. Advertiser may retain any Wee Amici Ad Data for only as long as Advertiser has a legitimate business need to retain it.

d. Advertiser shall not:

i. Share Wee Amici Ad Data with third parties, except that Advertiser may share Tag Data solely with the third-party owner of the applicable Tag, provided that such third-party owner is bound by terms of use of such Tag Data that are at least as restrictive as set forth in Section 8, below;

ii. Utilize any Wee Amici Ad Data to serve targeted advertisements on or off the Wee Amici Properties, nor enable or allow any third party to do so;

iii. Permit or enable any code, or other tracking technology to attach or redirect to third-party tags, code or other tracking technologies ("piggybacking") without prior written permission from Wee Amici;

iv. Resell, share, or otherwise distribute Wee Amici Ad Data, including in a manner that competes with the Ad Service provided by Wee Amici, including, by way of example and not limitation, by claiming to provide data that identifies Wee Amici's users, data of users that "look like" or share characteristics or behaviors of Wee Amici's users, or data about, originating from or otherwise related to Wee Amici, Wee Amici Properties, or Wee Amici's users;

v. Label, denote, or refer to in any manner any Wee Amici Ad Data (whether or not such data contains any personally identifiable information, personal data, or Personal Information) as being derived from Wee Amici, Wee Amici Properties, or Wee Amici's users;

vi. Utilize any Wee Amici Ad Data, including device IDs, advertising IDs, IP addresses, or other information relating to any Wee Amici user, nor transfer to, sell to or otherwise allow or enable any third party to make use of Wee Amici Ad Data or any information collected by any Tag;

vii. Attempt to re-identify any information provided by Wee Amici in de-identified or anonymized form in Reporting Data or attempt to associate any Reporting Data with any particular End User, household, or device;

viii. Use Wee Amici Ad Data to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer, or device; and

ix. Use Wee Amici Ad Data to improve or enhance Advertiser’s systems, products, services, methodologies, technologies, or business, except as permitted herein.

4. Metrics. Wee Amici may generate and provide Advertiser access to Wee Amici Ad Data by means reasonably determined by Wee Amici.

5. Advertiser-Provided Ad Data.

a. Advertiser represents and warrants that Advertiser has a lawful basis (in compliance with Applicable Data Protection Laws) and/or all necessary rights and permissions to disclose Advertiser-Provided Ad Data to Wee Amici for the purposes set forth in these Ad Data Terms, and for Wee Amici’s access to and storage of information on an End Users’ devices. Advertiser (including Agency, as applicable) must provide clear and comprehensive information to End Users in a sufficiently prominent notice regarding the access to and collection, sharing and use of Advertiser-Provided Ad Data that uses tracking technologies including: (i) that Advertiser’s website or mobile app, as applicable, uses tracking technologies operated by third parties, including Wee Amici, to collect information about how End Users use their website or mobile app; (ii) that the information is used to provide measurements and/or to target ads; (iii) how End Users can opt out of the collection and use of information for ad targeting; and (iv) where End Users can opt-out of the collection and use of information for ads targeted.

b. Advertiser will not share or otherwise provide Wee Amici with Advertiser-Provided Ad Data that: (i) Advertiser knows or reasonably should know is from or about children or minors under the age of eighteen (18) years; or (ii) includes health information, financial information, or other special categories of information defined as sensitive personal information under Applicable Data Protection Laws or otherwise specified as Prohibited Data.

c. Wee Amici’s Use of Advertiser-Provided Ad Data. Wee Amici may use Advertiser-Provided Ad Data to provide the Ad Service, and Advertiser hereby grants Wee Amici a non-exclusive, worldwide, royalty-free, sub-licensable license to use Advertiser-Provided Ad Data to provide the Ad Service, including (without limitation) use of Advertiser-Provided Ad Data for the following purposes:

To generate and provide Reporting Data to Advertiser;

ii. To comply with Wee Amici’s obligations under Applicable Data Protection Laws, including, without limitation, to respond to an individual’s information or data subject requests as required under Applicable Data Protection Laws;

iii. To detect data security incidents or to protect against fraudulent or illegal activity;

iv. To improve Wee Amici's safety, security, and anti-fraud measures;

v. For Wee Amici's research and product development;

vi. For Optimization, provided, however, that: (1) Wee Amici will not use Interaction Data for Optimization unless (and to the extent allowed under Applicable Data Protection Laws) Interaction Data is aggregated with data collected from other advertisers or other sources; and (2) Wee Amici will not allow third parties to customize Ads shown on Wee Amici solely on the basis of Advertiser's Interaction Data;

vii. To the extent permissible under Applicable Data Protection Laws, to create aggregated, de-identified, or anonymized information, which Wee Amici may use for any lawful purpose;

viii. With respect to Interaction Data:
1. To understand when Interaction Data about Advertiser's End Users is related to individual users of Wee Amici; and
2. To deliver Advertiser's Ads on Wee Amici to End Users who interact with Advertiser Properties.

ix. With respect to Hashed Contact Data, solely to match against Wee Amici's users in connection with providing the Ad Service; and

x. Otherwise with Advertiser’s permission.

xi. For the avoidance of doubt, Wee Amici will not share Interaction Data that Advertiser provides to Wee Amici with any third parties except: (a) to provide the Ad Service; (b) with Advertiser's permission; and (c) as required or permitted by Applicable Data Protection Laws.

6. Reporting Data.

Wee Amici will provide Reporting Data to Advertiser only on an aggregated and de-identified basis. Wee Amici will not share Reporting Data generated on Advertiser's behalf, or any portion thereof, with any third party unless: (a) Advertiser permits Wee Amici to do so; or (b) where Reporting Data generated on Advertiser's behalf has been combined with Reporting Data from multiple other third parties, and such combined information does not identify Advertiser.

7. User-Volunteered Data.

As between the parties, User-Volunteered Data is controlled by Advertiser, is subject to the Advertiser's privacy policy, and is deemed Confidential Information (as defined in the Ad Terms) of Advertiser.

8. Tags and Tag Data.

a. If Wee Amici makes the feature available (at its discretion), Advertiser may place Tags into its Ad Content, provided that Advertiser provides Wee Amici with: (i) the code or a means of identifying such code; (ii) the specific data that such code will collect or track; and (iii) how long such data will be retained before expiring or being deleted. Additionally, Advertiser must specifically identify whether such code includes any function for: (1) setting cookies; (2) creating or accessing local shared objects or HTML5 local storage; or (3) obtaining device IDs, advertising IDs, wireless IDs, user account information, geo-location, address book data, or other Personal Information.

b. Advertiser may allow the Tag to collect Tag Data, where such Tag Data is subject to the Wee Amici Ad Data use restrictions in Section 3 above.

c. To the extent that Advertiser collects Tag Data that includes Personal Information, Advertiser shall comply with all Applicable Data Protection Laws and these Ad Data Terms regarding the processing of such Personal Information and shall, where reasonably requested by Wee Amici, produce documentation to demonstrate such compliance.

d. Consumer Controls.

Advertiser shall ensure that the Tag is delivered by a member of the Network Advertising Initiative ("NAI"), Interactive Advertising Bureau ("IAB") or Digital Advertising Alliance ("DAA"); and that an opt-out cookie is provided to allow Wee Amici's users to opt-out of cookies collected by the Tag.

ii. Advertiser shall ensure that opt-outs requested by Wee Amici’s users are honored, whether the opt-out is requested through the NAI, IAB, DAA, EDAA, or some other mechanism.

iii. Wee Amici may, at its discretion, provide Wee Amici users with a mechanism to control whether Tags store or access information on such users’ device(s).

9. Personal Information.

To the extent that Wee Amici processes Advertiser-Provided Ad Data that constitutes Personal Information, or otherwise processes Personal Information on behalf of Advertiser in the course of providing the Ad Service, the parties hereby agree to the Data Processing Addendum for the Wee Amici Ad Service, attached as Exhibit A hereto.

10. Notice.

If Advertiser collects Tag Data from End Users, Advertiser must provide clear notice to each End User and obtain any legally-required consent from each End User for the collection, sharing, and use of that Tag Data by Advertiser and Wee Amici.

11. Use of Third-Party Ad Servers.

If Advertiser uses a third-party Ad server (including any tags, or other code or technology placed in Ads) (collectively, a "Third-Party Ad Server"), such Third-Party Ad Server must be approved by Wee Amici (at its sole discretion) and may be used solely to collect metrics and analytics regarding the performance and effectiveness of Advertiser's campaign with Wee Amici’s users, subject to compliance with these Ad Data Terms.

12. Privacy Policy.

Each party shall create and maintain a privacy policy on its website that complies with Applicable Data Protection Laws, and adhere to such privacy policy in all material respects.

EXHIBIT A

DATA PROCESSING ADDENDUM FOR THE WEE AMICI AD SERVICE

This Data Processing Addendum for the Wee Amici Ad Service (this "DPA") applies to (and to the extent of any conflict takes precedence over) the Ad Terms, Ad Data Terms, and/or other applicable agreement (collectively, the "Agreement") between Wee Amici, Inc. and its Affiliates ("Wee Amici") and the entity agreeing to this DPA, the advertiser (the "Advertiser") (each, a "party", together, the "parties") for the use of Wee Amici's Ad Service. The term "Advertiser", as used herein, will apply on a several basis to the entity whose Ads will be serviced by Wee Amici under the Agreement and any Agency acting on its behalf.

This DPA applies to the extent that Wee Amici Processes Personal Data on behalf of Advertiser, including such Personal Data subject to Applicable Data Protection Laws. Capitalized terms not expressly defined herein shall have the meaning ascribed to them in the Wee Amici Advertising Terms Definitions, Ad Terms, or Ad Data Terms, as applicable.

1. Definitions. For purposes of this DPA, the terms below have the meanings set forth below.

a. "Advertiser Personal Information" means Personal Information that is controlled by the Advertiser, and that is provided to and Processed by Wee Amici in the course of providing the Ad Service.

b. "Controller" means an entity which, alone or jointly with others, determines the purposes and means of the Processing of Personal Information.

c. "Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information. For avoidance of doubt, Personal Data Breaches do not include unsuccessful attempts or activities that do not compromise the security of Personal Information, including, without limitation, unsuccessful log-in attempts, pings, port scans, denial of service attacks, or other network attacks on firewalls or networked systems.

d. "Process" and "Processing" mean any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.

e. "Processor" means an entity which Processes Personal Information on behalf of a Controller.

f. "Sub-Processor" means an entity engaged a Processor, or any further subcontractor thereto, to Process Personal Information on behalf of and under the instructions of a Controller.

2. Scope. This DPA applies to Advertiser Personal Information, to the extent such Advertiser Personal Information is subject to Applicable Data Protection Laws.

3. Roles of the Parties. The parties acknowledge and agree that, as between the parties, Wee Amici is the Processor and Advertiser is the Controller.

4. Processing of Personal Information.
a. Advertiser's Processing of Personal Information. Advertiser shall, in connection with its use of the Ad Service, Process Personal Information in accordance with Applicable Data Protection Laws. For the avoidance of doubt, Advertiser’s instructions to Wee Amici for the Processing of Advertiser Personal Information shall comply with Applicable Data Protection Laws. Advertiser shall have sole responsibility for the accuracy, quality, and lawfulness of Advertiser Personal Information and the means by which Advertiser acquired Advertiser Personal Information.

b. Prohibited Data. Advertiser represents and warrants to Wee Amici that the Advertiser Personal Information does not and shall not include Prohibited Data.

c. Wee Amici's Processing of Personal Information. Wee Amici shall Process Advertiser Personal Information only to provide the Ad Service to Advertiser in accordance with the relevant agreement(s) between Wee Amici and Advertiser, and only on Advertiser’s documented instructions, except as required under Applicable Data Protection Laws, in which case Wee Amici shall inform Advertiser of the relevant legal requirement unless such information is prohibited by such Applicable Data Protection Laws. Wee Amici shall promptly inform Advertiser if Wee Amici reasonably finds that Advertiser’s documented instructions regarding Processing of Advertiser Personal Information would result in a violation of Applicable Data Protection Laws.

d. Obligations of Wee Amici. When Processing Advertiser Personal Information in connection with the Ad Service, Wee Amici:

Shall, taking account of the nature of Processing and insofar as is possible, reasonably assist Advertiser, by appropriate technical and organizational measures, in fulfilling Advertiser’s obligations to respond to individuals’ requests to exercise rights granted under Applicable Data Protection Laws.
Shall, taking account of the nature of Processing and information available to Wee Amici, reasonably assist Advertiser in complying with Advertiser’s obligations under Applicable Data Protection Laws, including, without limitation, with respect to Advertiser’s obligation to conduct data protection impact assessments or consultations as required under Applicable Data Protection Laws.
Shall make available to Advertiser, at Advertiser’s reasonable written request, information necessary to demonstrate Wee Amici’s compliance with its obligations under Applicable Data Protection Laws.

5. Security Measures.

a. Wee Amici Security Measures. Wee Amici will implement and maintain appropriate technical and organizational measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Information, as set forth in industry-standard practices to this DPA, and as required under Applicable Data Protection Laws; provided, however, that Wee Amici may update its security measures from time to time, so long as the updated measures do not materially decrease the overall protection of Personal Information.

b. Security Compliance by Wee Amici Personnel. Wee Amici will ensure that its personnel authorized to access Advertiser Personal Information are subject to appropriate confidentiality obligations.

c. Advertiser’s Security Responsibilities and Assessment.

Advertiser’s Security Responsibilities. Advertiser agrees that, without limitation of Wee Amici’s obligations under Section 6 of this DPA, Advertiser is solely responsible for Advertiser’s use and provision of Advertiser Personal Information in connection with the Ad Service, including, without limitation: (1) making appropriate use of the Ad Service to ensure a level of security appropriate to the risk in respect of the Advertiser Personal Information; (2) securing any account authentication credentials, systems, and devices Advertiser uses to access the Ad Service; and (3) making Advertiser’s own backup copies of Advertiser Personal Information.

ii. Advertiser’s Security Assessment. Advertiser agrees that the security measures set forth herein and Wee Amici’s commitments under this DPA are adequate to meet Advertiser’s needs, including with respect to any security obligations of Advertiser under Applicable Data Protection Laws, and provide a level of security appropriate to the risk in respect of the Advertiser Personal Information.

6. Sub-Processors.

a. General Authorization to Appoint Sub-Processors. Advertiser acknowledges and agrees, and generally authorizes, that: (i) Wee Amici Affiliates may be engaged as Sub-Processors; and (ii) Wee Amici and its Affiliates may respectively engage third-party Sub-Processors in connection with the provision of the Ad Service. Wee Amici will provide Advertiser with a list of Sub-Processors upon Wee Amici’s receipt of Advertiser’s written request and shall notify Advertiser by reasonable means in advance of changes to such Sub-Processors engaged by Wee Amici. Wee Amici has entered into, and shall enter into, a written agreement with each Sub-Processor that includes data protection obligations on the Sub-Processor at least as protective as those set forth herein, to the extent applicable to the nature of Processing activities carried out by such Sub-Processor, and sufficient to satisfy requirements under Applicable Data Protection Laws.

b. Objection Right for New Sub-Processors. Advertiser may reasonably object to Wee Amici’s engagement of a new Sub-Processor, promptly and in writing, in accordance with the notice provisions set forth in the relevant agreement(s) between Wee Amici and Advertiser for provision of the Ad Service. If Advertiser objects to a Sub-Processor as permitted in this Section 6(b), Wee Amici will use commercially reasonable efforts to make available to Advertiser appropriate changes to the Ad Service to avoid the Processing of Personal Information by such Sub-Processor. If Wee Amici is unable to make available such changes within a reasonable period of time, not to exceed sixty (60) days, then Advertiser may, by written notice to Wee Amici, terminate the relevant Ad Service to the extent that the Ad Service cannot be provided by Wee Amici without the use of the objected-to new Sub-Processor.

c. Sub-Processor Agreements; Liability. Wee Amici shall not be liable for the acts and omissions of its Sub-Processors, if such a Sub-processor fails to fulfill its data protection obligations.

7. Personal Data Breach.

a. Wee Amici shall notify Advertiser, without undue delay, of any Personal Data Breach of which Wee Amici becomes aware that impacts Advertiser Personal Information. Wee Amici shall take commercially reasonable steps, as it deems appropriate, to remediate the cause of such Personal Data Breach and mitigate potential adverse effects thereof.

b. As information becomes available and without undue delay, Wee Amici will provide Advertiser with information about the nature of such Personal Data Breach, the categories and approximate numbers of Personal Information records impacted, steps taken to remediate the cause of such Personal Data Breach and to mitigate potential adverse effects, steps Wee Amici recommends Advertiser take to address such Personal Data Breach, and other information required to be provided to Advertiser under Applicable Data Protection Laws.

c. Wee Amici shall provide reasonable assistance and cooperation to Advertiser in complying with Advertiser’s obligations under Applicable Data Protection Laws with respect to such Personal Data Breach.

d. Wee Amici’s notification of or response to a Personal Data Breach will not be construed as Wee Amici’s acknowledgement of any fault or liability with respect to the Personal Data Breach.

8. Duration of this DPA. This DPA shall continue in effect for as long as Wee Amici or its Sub-Processors Process Advertiser Personal Information subject to Applicable Data Protection Laws, except for those provisions that, by their nature or as expressly set forth herein, continue in effect for a longer duration, in each case notwithstanding the expiration or termination of the relevant agreement(s) between the parties for the Ad Service.

9. Deletion or Return of Advertiser Personal Information. After the end of Processing Advertiser Personal Information in connection with the Ad Service, Wee Amici shall delete or return to Advertiser all Advertiser Personal Information held or controlled by Wee Amici, upon Advertiser’s request, unless continued storage of the Advertiser Personal Information is required by Applicable Data Protection Laws. Wee Amici will comply with such deletion or return requests as soon as reasonably practicable and not later than ninety (90) days after receipt of such a request.