PRIVACY POLICY

1. SCOPE OF THIS POLICY

This Privacy Policy describes how EZ‑AD Inc. ("EZ‑AD," "we," "our," or "us") collects, uses, shares, and protects personal information when you:

• visit any EZ‑AD websites (including ezadtv.com, localecommerce.com, saturntext.com, ezai.io, and their sub‑domains);
• use the EZ‑AD TV in‑store digital‑signage platform, our mobile applications, or any SaaS dashboards we provide;
• interact with the EZ‑AD Digital Commerce platform ("LocaleCommerce") or SaturnText SMS marketing tool; or E-mail Address
• communicate with us through support channels, email, social media, or events.

This Policy applies globally. Additional region‑specific disclosures are embedded in Section 8.

By continuing to use the Services, you acknowledge that you have read and understood this Policy.

2. INFORMATION WE COLLECT

We collect information that falls into the categories below.

We do not deliberately collect biometric identifiers or images; our screens do not perform facial recognition.

3. HOW & WHY WE USE PERSONAL DATA (LAWFUL BASES)

4. RETENTION OF PERSONAL DATA

Unless a longer period is required by law, we retain data for the periods below and then securely delete or anonymise:

• Account & billing records – 7 years after account closure;
• Payment tokens – 7 years (for tax/audit);
• Usage analytics (Google Analytics, Hotjar) – 26 months;
• Support tickets & call recordings – 3 years;
• Advertising cookie IDs – as per cookie expiry listed in Section 5.

5. COOKIES & TRACKING TECHNOLOGIES

We use cookies, web beacons, pixel tags, HTML5 local storage, and legacy Flash cookies (where supported) for analytics and security.

5.1 Cookie Categories:

• Essential – required for the site to function (e.g., session tokens).
• Functional – remember preferences such as language.
• Analytics – measure site performance (Google Analytics, Hotjar). Off by default in EEA/UK.
• Advertising – measure conversions & deliver personalised ads (Google Ads, Facebook Pixel). Off by default in EEA/UK. Opt‑out = "Do Not Share" under CPRA.

5.2 Cookie Inventory

You can control cookies via our banner ("Accept all", "Decline all", "Adjust my preferences") or through your browser settings. See “Cookie Settings” link in the footer.

6. SHARING OF PERSONAL DATA

We do not sell personal information. We may “share” it for cross‑context advertising as defined by CPRA (Advertising cookies above). We disclose data only to:

• Service Providers acting under written DPAs (Google Cloud – USA; Stripe – USA; Mailgun – USA/EU; Twilio – USA; Hotjar – EU; Meta Platforms – USA);
• Third-party integrations. If you choose to link an external account (e.g., YouTube, Facebook) to EZ-AD, we will share and receive information as authorized by you through the OAuth consent screen. You can disconnect any integration at any time by visiting the respective feature page.
  1. Business partners you authorise (e.g., your POS vendor);
  2. Legal authorities when required;
  3. Successors in the event of a merger or acquisition (notice will be provided).

All transfers are governed by 2021 Standard Contractual Clauses where applicable.

7. INTERNATIONAL DATA TRANSFERS

Our primary servers are in the United States. When we transfer personal data from the EEA/UK to the U.S. or another third country, we rely on:

• Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914);
• Adequacy decisions, where available; or
• Your explicit consent (Art 49 GDPR) for specific transfers.

8. YOUR PRIVACY RIGHTS

8.1 EU / UK Residents (GDPR)

You have the right to request access, rectification, erasure, restriction, objection, and portability of your personal data, and to withdraw consent at any time. You can submit requests in any of the following ways:

• Online form (erasure, restriction, or objection): https://ezadtv.com/forget-me
• Dashboard (access, rectification, portability): log in, open Settings → Account, and click “Download your Data – Request Data.” From the same page you can edit your profile details.
• Other inquiries: email us at privacy@ezadtv.io.
• Email marketing opt-out: click the “Unsubscribe” link at the bottom of any marketing e-mail. Because EZ-AD TV signage licences are held by independently owned retail stores, you may need to unsubscribe separately from each store that contacts you. Transactional messages (order confirmations, product-recall notices, account or service updates) will still be sent even if you opt out of marketing.

We will acknowledge your request within 48 hours and provide a substantive response within 30 days.

8.2 California Residents (CCPA/CPRA)

You have the right to Know, Delete, Correct, Opt‑Out of Sharing, and Non‑Discrimination. To exercise these rights:

• Online form (Delete or Opt-Out of Sharing ): https://ezadtv.com/forget-me
• Dashboard (Know or Correct): log in, open Settings → Account, and click “Download your Data – Request Data.” From the same page, you can edit your profile details.
• Other inquiries: email us at privacy@ezadtv.io.
• Email marketing opt-out: click the “Unsubscribe” link at the bottom of any marketing e-mail. Because EZ-AD TV signage licences are held by independently owned retail stores, you may need to unsubscribe separately from each store that contacts you. Transactional messages (order confirmations, product-recall notices, account or service updates) will still be sent even if you opt out of marketing.

We confirm receipt within 10 business days and fulfil verified requests within 45 days.

9. SECURITY MEASURES

• TLS 1.3 encryption in transit; AES‑256 at rest
• Role‑based access control & MFA for staff
• Quarterly penetration testing & annual SOC 2 Type II audits
• Daily encrypted backups stored off‑site

10. ACCOUNT SECURITY & ANTI-PHISHING REMINDER

Choose a strong, unique password for your EZ-AD account and keep it confidential. EZ-AD will never ask you to reveal your password, credit-card details, or other sensitive information by email, SMS, or phone. If you receive a message that appears to come from EZ-AD requesting such data, please treat it as phishing and delete it. If you believe your account credentials have been lost, stolen, or misused, contact us immediately at privacy@ezadtv.io or +1 888-800-5593.

11. CHILDREN’S PRIVACY

Our Services are not directed to children under 16 in the EEA/UK or under 13 in the U.S. If we learn we have collected such data, we will delete it.

12. BREACH NOTIFICATION COMMITMENT

In the event of a personal‑data breach likely to result in risk, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay, consistent with GDPR Art 33‑34 and applicable U.S. state laws.

13. CHANGES TO THIS POLICY

We may update this Policy. Material changes will be notified via banner or email 30 days before they take effect. The "Last Updated" date reflects the latest revision.

14. CONTACT US

Data Controller: EZ-AD TV, Inc.101 West Big Beaver Ave, Floor 14 Troy, MI 48084

Email: privacy@ezadtv.io

Phone: +1 888‑580‑5593

15. GLOSSARY

"Personal Data" – information relating to an identified or identifiable individual.

"Processing" – any operation performed on Personal Data.

*"Service Provider" / "Processor" – third party that processes Personal Data on our behalf.

*"Sell" / "Share" – as defined in the California Privacy Rights Act.

"Contract (Art 6(1)(b) GDPR)" – processing necessary to deliver the products or services you request, or to take steps at your request prior to entering into a contract.

"Legitimate Interest (Art 6(1)(f) GDPR)" – processing based on our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

"Legal Obligation (Art 6(1)(c) GDPR)" – processing required to comply with a legal or regulatory obligation, such as tax or accounting rules.

"Consent (Art 6(1)(a) GDPR)" – processing carried out only when you have given clear permission, which you may withdraw at any time.