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Ventura Data Policy

Last Updated: September 3, 2026

Company agrees to comply with the following policies, responsibilities, and restrictions relating to Company making its Apps available on the Ventura OS under the application distribution agreement between Company and TTD (the “Agreement”):

  1. Company represents and warrants that its collection, processing, and use of any data originating from the Ventura OS (including, for purposes of clarity, any data Company collects solely via its Apps) will comply with Company’s privacy policy and applicable Law, including the Video Privacy Protection Act (“VPPA”), the Children’s Online Privacy and Protection Act, and, as applicable, the Ventura Data Processing Addendum. Company will provide TTD with a copy of Company’s privacy policy for TTD to separately display to end users, upon TTD’s request.
  2. Company represents and warrants that: (a) it has the necessary rights, licenses, and consents required by Law to provide or make available to TTD any data under the Agreement, including any personal information of an End User (including any personal information subject to VPPA), and for TTD to process and use the data in accordance with the Agreement; and (b) it will not provide TTD any data that may be considered protected, sensitive, special, or similar under applicable Laws.
  3. If Company operates any child-directed OTT Apps or otherwise provides child-directed Content (collectively, “Child-Directed Content”), Company represents and warrants that it will comply with the Children-Directed Content Policy and applicable Laws regulating the processing and disclosure of personal information from or about children and the content and ads that may be surfaced to children. Except as permitted by applicable Laws, Company will not collect any personal information from Child-Directed Content without verifiable parental consent, engage in or permit others to engage in targeted advertising on Child-Directed Content, or use, or permit others to use, personal information collected from Child-Directed Content for targeted advertising.
  4. Company may only process End User-resettable identifiers (i.e., the Advertising ID) in compliance with all applicable Laws, including all applicable privacy Laws. If an End User resets their Advertising ID on the Ventura OS, Company agrees not to identify, re-identify, combine, correlate, link, or otherwise associate, either directly or indirectly, the prior Advertising ID (and any data derived from that End User and the reset Advertising ID) with the updated Advertising ID. Company agrees to honor consumer privacy choices Company receives from TTD or the End User (including settings for limited data use, targeted advertising opt-outs, do not sell, and do not share signals) and will ensure any other entities Company contracts with does the same.
  5. Company shall not engage in any automatic content recognition activities on the Devices.
  6. Company shall provide TTD with prior notice of any third-party advertising or analytics service vendors that Company intends to use with respect to any advertising inventory available on Company’s Apps.
  7. Company must delete all data it has collected or received relating to its operation of the Apps for which Company is not an independent controller immediately following termination or expiration of Company’s Agreement with TTD or TTD’s suspension of Company’s Apps.