Last Updated: September 3, 2025.

Vantage Analytics Inc. (“Vantage”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) to set out how we collect, use, and disclose information about identifiable individuals (“Personal Information”) through our website located at www.gotvantage.com (“Website”) and web platform (“Platform”) and in the course of providing business to business advertising technology services, such as analytical and reporting services, described in further detail on our Website (collectively, “Services”). This Privacy Policy applies to Personal Information we collect or receive in the course of providing Services for our customers, which include retailers and brands (“Customers”) which pertains to the end users, clients, or prospects of Customers (each an “End User”), as well as Personal Information we collect about visitors of the Website, users of the Platform (together with Customers and End Users, “User”, “you”, “your”). 

1. OVERVIEW.

A Note to End Users. If you are an End User, please note that when we process Personal Information we receive from Customers or collect on behalf of Customers, we do so solely in connection with provision of Services to the relevant Customer and pursuant to the Customer’s instructions as their service provider. For example, we receive and/or collect Personal Information about End Users who visit a website of our Customer to browse the Customer’s products.   

We process such Personal Information in connection with the Services to help Customers recognize and understand their End Users, improve their marketing and advertising campaigns, and to help Customers create more targeted and relevant ads. If you are an End User and want to know more about how we may process your Personal Information on behalf of Customers, please consult the relevant Customer’s privacy policy.

1.1 International Users. In connection with the Services, Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. Specific terms of this Privacy Policy (below) apply to Personal Information about Users in California, the UK, and EEC.

1.2 Lawful Processing. We process Personal Information only to the extent necessary for the purposes described in this Privacy Policy. We set out below the type of Personal Information we collect and how we use such Personal Information. Except as set forth in this Privacy Policy, Personal Information will not be used for any other purpose without appropriate consent. We do not actively collect Personal Information for the purpose of selling or marketing that Personal Information to third parties. 

1.3 Scope. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including Customers, End Users, or any third-party service providers engaged by our Customers (each, a “Partner”), and any services offered by other third parties which are accessible via the Services.

1.4 Changes to this Privacy Policy. We may change this Privacy Policy from time to time at our sole discretion and we will update the “Last Updated” date as set out above. Vantage may require you to provide consent to the updated Privacy Policy before further use of the Services is permitted.

2. COLLECTION OF PERSONAL INFORMATION.

2.1 Information provided to us. We collect Personal Information disclosed to us as follows:

• • Onboarding and providing the Services to Customers. We collect business contact information of our Customers, such as name, address, email, payment information, and any other information required (for which we will obtain Customer’s consent at the time of collection) to onboard Customers onto the Platform, deliver the Services, communicate with Customers about their business relationship with Vantage and to facilitate payment of fees for the Services.

• • Information submitted to Vantage via the Website. Certain functionality of the Website or Platform may enable you to contact us, in which case we collect any Personal Information you may choose to provide to us via the Website. We ask that you do not disclose sensitive Personal Information (including, without limitation, medical information) when you submit information to us.  

• • Information received or collected while providing the Services. At the discretion of the applicable Customer, the following information (received from Customers or Partners or collected by Vantage via Cookies or an Integration) to provide the Services to the Customer, some of which may constitute Personal Information: 

• • • Browsing Activity. This includes information about End User browsing activity on a Customer’s website, such as which page was visited and when, and what items were placed into an online shopping cart. Further, If an End User makes a purchase on a Customer’s website, we may collect information about the End User’s purchase, including name, email, address, and IP address, and expressly excluding the End User’s financial or payment information. 

• • • Device and Browser Information. This includes technical information about the device or browser used by an End User to access the Customer’s website, such as a device’s IP address, cookie string data, and in the case of mobile devices, the device type and unique identifier, such as the Apple IDFA or Android Advertising ID (“Device Information”). In addition to the Customer’s privacy policy, we recommend End Users check the policies of their device manufacturer or software provider to learn what Device Information may be shared with Vantage. 

• • • Ad Information. This is information about the ads served to an End User, such as how many times an ad has been served to an individual, what web page(s) the ad appeared on, and whether someone clicked on or otherwise interacted with the ad. This may include pseudonymous advertiser identifiers, such as a “customer ID” or an identifier associated with a hashed version of an email address. We work with Partners and Customers to synchronize such information to enhance data points about a particular unique browser or device. 

• • Integrations. We may integrate with Customer’s online platforms or rely on third-party platforms and services to provide the Services to Customers (“Integrations”). For example, Users of the Website may contact us via our social media handles and Customers may share Personal Information with us in connection with the Services via an Integration. Any Personal Information submitted to us via Integrations that we can access will be subject to this Privacy Policy, but please note that such Personal Information will also be subject to the terms of the applicable Integration. 

• • Applying to work with us. If you would like to work with us and submit hiring materials to us (either directly or through an Integration or recruiter), we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. If you submit hiring materials to us, we ask you to only include information relevant to the position you’re applying for, such as your employment history and credentials. Please note that any Personal Information you submit through an Integration or recruiter will be subject to the privacy practices of those entities. If you are a current Vantage employee, please contact the Vantage Privacy Officer per Section 10 below for more information on how your employee information may be collected and processed.

2.2 Information we collect during provision of Services. 

• • Cookies. In connection with the Services, we collect certain information through technologies such as cookies, pixel tags, and other automatic data collection technologies (“Cookies”), some of which may constitute Personal Information. We use Cookies for authentication and to compile aggregate statistics about usage of the Services, such as how long Users spend using the Services, and what parts or pages of the Website or Platform are viewed most often. This information is used to improve the content and operation of the Services, and to promote the Services to prospective Users through marketing and advertising. You may opt out of Cookies or prevent third-party websites from accessing our Cookies by adjusting your privacy settings on your browser. However, if you are a Customer, opting out of Cookies may disable some features of the Services and may prevent us from providing you with the information and services you have requested. Opting-out will not prevent you from seeing ads, but those ads are likely to be less relevant because they won’t be tailored to your interests. 

• • Device and Location Information. In connection with the Services, we may collect Device Information, some of which (such as unique device identifiers) may constitute Personal Information. The Personal Information we collect from Device Information can depend on the individual settings of your device and software that you use to access the Services. We recommend checking the policies of your device manufacturer or software provider to learn what Device Information may be shared with Vantage. You may disable the sharing of Device Information, but doing so may disable some features of the Services and may prevent us from providing you with the information and services you have requested. 

In connection with the Services, we may use Cookies to gather information (such as Device Information) about End User interactions with Customer and Partners. Such information about End Users is used to provide the Services to our Customers. For details about the type of information collected via Cookies, please see “Information received or collected while providing the Services” under section 2.1 above. 

3. USE OF PERSONAL INFORMATION.

Vantage uses Personal Information as follows:

• • To authenticate and onboard Customers, and provide web Users with access to the Website and Customers with access to the Services;  

• • To provide, maintain, improve, and enhance the Services; 

• • To develop new Vantage products, features, and services; 

• • To communicate with you, provide you with updates and other information relating to the Services, provide information that you request, respond to comments and questions, and otherwise provide customer support; 

• • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to Customers, where Customers have subscribed to receive them; 

• • To find and prevent fraud, and respond to trust and safety issues that may arise;  

• • For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and 

• • For other purposes for which we provide notice at the time the Personal Information is collected.

4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES.

We may share your Personal Information with our employees, contractors and with third parties (described below) while providing the Services and performing our contractual obligations. We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose. We share your Personal Information with the following third parties:

4.1 Customers. If you are an End User, we may share information (some of which may include Personal Information) with a Customer about how you have interacted with the Customer’s website or ads. This is done in connection with provision of Services to Customers and helps the relevant Customer provide better targeted ads to their End Users. 

4.2 Partners. If you are an End User, we may share information (some of which may include Personal Information) with a Customer about how you have interacted with a Partner’s ads. This is done in connection with provision of Services to Customers and helps the relevant Customer optimize their advertising campaigns. 

4.3 Other service providers. We employ service providers in connection with provision of the Services, and we may need to share Personal Information with such service providers to enable them to perform those tasks. Other than Partners, such service providers include third-party companies for general business functions, including the provision of database management, payment processing, and customer relationship management tools.  

4.4 Business transfers. If our business (or substantially all our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.  Your Personal Information may also be transferred in connection with due diligence for any such transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to the restrictions and protections set forth in this Privacy Policy. 

4.5 As required by law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

4.6 With your consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

5. DELETION AND RETENTION.

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another User).

6. ACCESS AND ACCURACY.

You may access the Personal Information we hold about you to verify accuracy of your Personal Information, to have a general account of our uses of your Personal Information, and to correct your Personal Information as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another User). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate, and to respond to you in a timely manner.  

7. SECURITY.

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as reasonably necessary to carry out the stated purposes we have communicated to you. Notwithstanding the foregoing, our servers and those of third parties who may receive your Personal Information may be located in Canada, the United States, and the EEU. Accordingly, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

8. RESIDENTS OF THE EUROPEAN ECONOMIC COMMUNITY (“EEc”) AND THE UK.

If you are a resident of the EEC or the UK, you have certain additional data protection rights. Vantage takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018). 

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact our Privacy Officer per Section 10. Note that if you are an End User, we act as a data processor on behalf of our Customers and you will be required to contact the data controller directly to exercise your rights. 

In certain circumstances, where we act as data controller, you have the following data protection rights:

• • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it. 

• • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. 

• • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

• • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

• • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.  

• • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  

• • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.  

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority.   

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

9. CALIFORNIA PRIVACY RIGHTS.

This Section 9 provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”). 

For more details about the Personal Information collected over the last 12 months, please see Section 2 above. We collect this Personal Information for commercial purposes described above. Vantage does not sell (as that term is defined in the CCPA) the Personal Information we collect.   

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.   

California consumers may make a request pursuant to their rights under the CCPA by contacting us per Section 10 below. We will verify your request using the information (including Personal Information) we have about you. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. 

10. CONTACT US.

If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Privacy Officer per the information below:

• • Via email: Email us at privacy@gotvantage.com using the subject line “Re Privacy Policy”. 

• • Via mail: Mail us correspondence to the following address:

2100 Bloor Street West, Unit 6110 Toronto, ON Canada M6S 5A5
Re: Legal/Privacy c/o Vantage Analytics Inc.