ROCKYADS, LLC PRIVACY POLICY

Last Updated: February 4, 2025

RockyAds, LLC (“Rocky,” “we,” “us,” or “our”), knows that data privacy is important to you. We have created this privacy policy (the “Privacy Policy”) to describe how we collect and process information from and about you through our website located at www.wearerocky.com (the “Site”), our crowdsourcing advertising platform (the “Platform”), and any other website, online portal, or digital property that is authorized to link to this Privacy Policy (collectively, the “Digital Properties”).

By accessing or using the Digital Properties or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Service for Creatives which together make up the Agreement. If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such party to the terms of this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Digital Properties. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

I. THE INFORMATION WE COLLECT, HOW WE COLLECT IT, AND HOW WE USE IT

While providing the Digital Properties, we may collect or receive the following types of information about you, which may include personal information.

1. Profile Information

When you create an account with us, you will need to provide us with certain profile information, such as your first and last name, email address, your birthday, and your location (country, state and city). You may also voluntarily provide additional information, such as your gender, sexual orientation, relationship status, ethnicity, whether you have children or pets, income, religion, political affiliation, your mantra, or a profile picture.

We use Profile Information in an effort to be inclusive and authentic in the advertising process. Our belief is that different people use and identify with brands and products in different ways. The many different interactions and stories are interesting to brands and other consumers. On the Digital Properties, all of your Profile Information (except for your first and last name) will be associated with your user name. This information will be shared with the brands for which you create content.

2. Account Credentials

In order to create an account with us, we will ask you to provide a user name and password and potentially additional information that will assist us in authenticating your identity when you log-in in the future (collectively, the "Account Credentials"). Your user name will be visible to all other users of the Platform, and you will be identified by this name when you post User Generated Content.

3. Server Logs

Like most websites today, our web servers automatically collect and store log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device's IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Digital Properties or the pages you’ve clicked on while on our Digital Properties). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

4. Information Obtained From Your Online Activity, Including From Third-Party Analytics Services

When you access or use any of our Digital Properties, we, and third-party analytics services such as Google Analytics, may use browser cookies, pixels, web server logs, web beacons, and similar technologies (collectively, “Tracking Technologies”) to collect and evaluate information relating to your device and internet usage such as: the type of device, the advertising identifier, the operating system and version, carrier and network type; IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); browser type and language; referring and exit pages and URLs; date and time of access; the content viewed; the amount of time spent on particular pages; what features of the Digital Properties are used or visited; details of any purchases; click stream information; and geolocation data.

The data we or third parties collect automatically is typically statistical data that may not identify you personally; however, we or third parties may maintain, associate and/or combine it with personal information collected in other ways or received from third parties.

We use this information to recognize you, save your preferences, customize your experience, evaluate your access and use of the Digital Properties, compile reports on activity, collect demographic data, analyze performance metrics, and serve targeted advertisements. Rocky may also evaluate your computer, mobile phone, or other access device to prevent fraud, identify malicious software or activity that may affect the availability of the Digital Properties.

By accessing or using the Digital Properties, you consent to the processing of data about you by our analytics providers in the manner and for the purposes set out in this Privacy Policy. We may add to or change these third-party analytics Digital Properties from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Digital Properties.

•Google Analytics: https://www.google.com/analytics

Cookies (browser cookies), a commonly used Tracking Technology, consist of small packets of data that a website or device stores on a browser, hard drive or device so that your device will “remember” information about your visit. To do this, we or third parties may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. If you do not want cookies placed on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this. If you decide not to accept cookies or other Tracking Technologies, the Digital Properties may not function properly.

5. Information Obtained From Other Sources

a)Social Media

We may maintain a presence on social media such as YouTube, Instagram, Facebook, Twitter, Twitch, TikTok, Snapchat, and other social media and third-party sites. We may collect personal information when you visit or use social media, including when you access our Digital Properties from social media. We will do so in accordance with the terms of use and privacy policies of those sites, mobile apps, and applicable law. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors and users of our social media pages and use of the content. This Privacy Policy does not cover personal information collected by such third-party social media sites. For more information on their privacy and security practices, please review the privacy policies and terms of use on their respective websites.

b)Other Third Parties

We may purchase or receive information from third parties, including information related to you. We may combine your information with such acquired information and use it to improve your experience, personalize our Digital Properties and content, and/or for targeted advertising.

c)TikTok Integration

1. Data We Collect Through TikTok

When you connect your TikTok account to the Rocky platform (via TikTok’s Login Kit) or otherwise use TikTok-related features within the Rocky app, we may collect and process certain information that TikTok shares with us, including:

•Basic Profile Information: Your open ID (unique identifier), TikTok display name, profile avatar, and verification status.

•Profile & Account Details: Profile web link, bio description, and any other publicly available data you authorize TikTok to share.

•Content & Video Information: Data related to videos you publish or upload via the Rocky app to your TikTok account, including video IDs, posting status, and any associated metadata.

•User Statistics: Likes count, follower count, following count, total video count, and other usage statistics that TikTok makes available through its API.

•List of Public Videos: A list of your publicly available TikTok videos if you choose to grant us this access.

2. How We Use TikTok Data

We collect this information to:

•Authenticate Your Account: Simplify the process of linking your TikTok account to the Rocky platform, enabling a seamless login experience.

•Publish Content: Allow you to publish or upload videos from the Rocky app directly to TikTok, or schedule content drafts for further editing within TikTok.

•Performance & Analytics: Provide you (and, where applicable, Brands on the Rocky platform) with social and content metrics, such as engagement statistics, to evaluate campaign performance.

•Account Management: Display your TikTok profile details within the Rocky app so you can view and manage your shared or scheduled TikTok content.

•Support & Troubleshooting: Notify you of posting errors or issues via our internal notifications, and help you resolve them.

3. How We Share or Disclose TikTok Data

•We primarily use TikTok data internally (e.g., to power your Rocky dashboard, analytics, or creator tools).

•In some cases, aggregated or anonymized analytics may be shared with Brands on the Rocky platform for campaign performance reviews. These shared stats do not identify individual TikTok users unless you have explicitly consented or it is necessary for the specific campaign.

•We do not sell your TikTok information to third parties.

4. Data Retention & Storage

•We store certain TikTok data (e.g., user statistics, published content details) in our secure databases to provide historical insights and performance tracking.

•We retain your information only as long as necessary to fulfill the purposes outlined in this Policy or as required by law.

•When it is no longer needed, we securely delete or anonymize your TikTok data.

5. How to Manage or Delete Your TikTok Data

•Unlink Your TikTok Account: At any time, you can choose to unlink your TikTok account from the Rocky app. Once unlinked, we will no longer have access to new TikTok data.

•Request Data Deletion: You may also request the deletion of any TikTok-related data stored by Rocky. Please note that we may need to retain certain information for record-keeping purposes or to comply with legal obligations. For more information on how to submit such a request, see the “HOW TO CONTACT US” section.

•TikTok Settings: You can also manage how your data is shared and used within TikTok by reviewing TikTok’s own privacy settings and policies.

6. Security Measures

•We use industry-standard security measures (including encryption in transit via HTTPS) to protect the data you share with us through TikTok’s APIs.

•We maintain strict access controls so that only authorized team members can access your TikTok data, and only for the purposes described in this Policy.

7. Third-Party Platform Compliance

•Our use of TikTok’s APIs is governed by TikTok’s Developer Terms, Community Guidelines, and Privacy Policy. For more information on how TikTok processes your personal data, please visit TikTok’s Privacy Policy.

6. Inferences

We may collect or receive inferences, which are assumptions or extrapolations that have been drawn from your information to create a profile which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

II. HOW ELSE WE USE YOUR Information

In addition to the use cases mentioned above, we may use your personal information to operate and administer our business, which includes:

•Contacting you as per your request to respond to questions, deliver our newsletter, provide information regarding new or improved products or services, and/or otherwise communicate with you;

•Providing customer support, troubleshoot problems, debug the Digital Properties, and help ensure the security and integrity of the Digital Properties and the business;

•Engaging in marketing, advertising, and tracking activities, targeted advertising, and to evaluate our efforts, provided that, where required under applicable law, we will obtain your prior opt-in consent to send electronic marketing communications; and

•Verifying, analyzing and maintaining the quality of the Digital Properties and Products and implement improvements.

III. WHEN AND HOW WE MAY SHARE YOUR INFORMATION WITH THIRD PARTIES

1. General Principles

We will only share your information as provided in this Privacy Policy, as otherwise disclosed to you, or as required under applicable law. We will share your information as follows:

•With third-party contractors and service providers that provide services to us in the operation of our business, such as marketing and advertising companies, consulting service organizations, IT and cloud service providers;

•To process aggregated, anonymous, user statistics and other information and disclose such data and information to third parties for lawful purposes;

•To protect and secure our rights and the rights of our Clients;

•To share with our parent company, subsidiaries, affiliates and/or other companies under common control with us;

•To fulfill our legal and regulatory obligations under applicable law, such as to comply with a subpoena, or similar legal process, protect or enforce our rights, investigate a security incident, or respond to a government, law enforcement, or judicial request;

•To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets; and

•Otherwise with your consent.

If you are an End User who has created User Generated Content on the Platform, we will make this content, as well as your user name, available to Brands on our Platform. Your user name may be displayed to all Platform users for certain pieces of content, but your Profile Information will not be shared with other End Users on our Platform. Please refer to the Terms of Service for Creatives for more information.

2. Profile Information

As mentioned above, we associate your Profile Information (except for your first and last name) with your user name. We share this information with the brands for which you have created content.

3. Reaction to Content

You have the opportunity to react to certain content while on our Digital Properties. If you do so, we may share your reaction with the Brand Users. Your reactions will not be attributable to your account specifically, but you will be included in groups of End Users that share attributes from your Profile Information.

IV. Modifying Information and Communications Preferences

You may exercise your choices as follows:

•You may correct or update the personal information that Rocky has about you by contacting us as directed at the end of this Privacy Policy.

•If you would like us to delete any or all information, please email us at brands.help@wearerocky.com . To the extent compatible with our legal or regulatory record keeping requirements, we will use commercially reasonable efforts to process such requests in a timely manner.

•You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails or by contacting us as directed at the end of this Privacy Policy. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely modify information in our databases. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

•You may opt out of targeted advertising by certain companies that participate in third-party industry groups by visiting the Network Advertising Initiative consumer opt-out page or the Digital Advertising Alliance's consumer choice tool. Your device settings may also offer you additional privacy settings. Please note that even if you opt out of receiving interest-based advertising, you will still receive advertisements, but they will be more general in nature.

V. How We Protect Your Information

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, emails sent to or from the Digital Properties may not be secure, and you should therefore take special care in deciding what information you send to us via email.

VI. Children’s Privacy

We do not knowingly collect personal information from any person under the age of 13. If an individual under the age of 13 has provided us with personal information, a parent or guardian of that child may contact us and request that such information be deleted, and we will endeavor to delete that information from our databases.

VII. External Websites and Third Parties

Unless explicitly stated otherwise, our Privacy Policy addresses only our use and disclosure of information we collect from and/or about you in your interactions with the Digital Properties. If you choose to disclose information to third parties, the use and disclosure restrictions contained in this Privacy Policy will not apply, as we do not control the privacy policies of such third parties, nor are we subject to them.

Rocky may allow certain hyperlinks to third-party websites, mobile apps or other online resources to appear on the Digital Properties (“External Websites”). If you click on a link for any External Site, you will be redirected to a third-party site. The information collected by such third parties or that you choose to provide, is governed by the third-party site’s privacy policy and practices. We have no control over the privacy policies or practices, the content, or the products and services, of any External Websites we provide or allow hyperlinks on our Digital Properties. As such, we are not responsible for the content or the privacy policies of those External Websites. You should check the applicable third-party privacy policy and terms of use when visiting any External Websites.

VIII. Do Not Track

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access our Digital Properties. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

IX. Notice to Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at brands.help@wearerocky.com with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note, however, that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

X. NOTICE TO CALIFORNIA RESIDENTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at brands.help@wearerocky.com. Please note, however, that we do not share your personal information with third parties for direct marketing purposes, nor have we done so in the past.

XI. IMPORTANT NOTICE TO ALL NON-US RESIDENTS

Our Digital Properties are intended for visitors located within the United States, and our servers are located in the US. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Digital Properties, you do so at your own risk.

XII. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the “last update” date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Digital Properties after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

XIII. HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at brands.help@wearerocky.com with “Privacy Policy” in the subject line.