Services Privacy Policy

SYNTHESI SERVICES PRIVACY POLICY

Last Updated: December 1, 2025

This Privacy Policy explains how Synthesi collects, uses, shares, and protects Personal Information in connection with our advertising technology services and data products (the “Services”). This policy applies only to Personal Information processed through our Services, which are provided to our business customers. Because our Services are designed for use by businesses, we do not typically interact directly with individual consumers or collect data directly from you.

For information about Personal Information collected through Synthesi’s corporate website, business-to-business interactions, or data processed for employment-related purposes, please refer to the Synthesi Corporate Privacy Policy.

ABOUT SYNTHESI
SOURCES OF PERSONAL INFORMATION
TYPES OF PERSONAL INFORMATION
USE OF PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION
AGGREGATED AND DE-IDENTIFIED INFORMATION
GEOGRAPHIC SCOPE
HOW LONG DO WE RETAIN PERSONAL INFORMATION
DATA SECURITY
OPT-OUT REQUESTS
YOUR PRIVACY CHOICES
PROCESS FOR SUBMITTING PRIVACY REQUESTS
REVISIONS TO THIS PRIVACY POLICY
CONTACT INFORMATION

1. ABOUT SYNTHESI

Synthesi operates a semantic intelligence platform that analyzes digital content and users’ consumption of it to build content and user profiles using advanced machine learning. The platform enables our customers (and companies that work with them, including advertisers and advertising technology companies) to generate revenue through use of our services and data products, most typically for digital advertising and analytics.

Our data products include audience and contextual segments, and our customers may also use our services to create their own segments or other data products. These may be used internally or shared with third-party platforms for purposes such as targeted advertising and analytics. Customers may integrate our services within their own apps, websites, or platforms, or separately purchase our data products. While this privacy policy covers how Synthesi uses your data, the apps, websites, and platforms you visit may also collect and use your data under their own privacy policies.

To help explain how we may use your data, we’ve outlined a few key concepts below.

Profiling and Identity Matching. We use data collected over time from various sources to create user profiles, which may include linking information across different devices or sources to identify the same person. This helps us better understand interests and behavior patterns to support more relevant experiences.

How We Recognize Meaningful Patterns. Our platform analyzes online behavior by converting it into numerical patterns that place users in a virtual space based on the content consumed. We associate content consumption behavior with digital identifiers, and part of our service is to link these identifiers to what we believe is the same person.

How We Group Data: Our platform can be used to create different data groupings, including audience segments which are groups of users with similar characteristics, interests, or behaviors used by advertisers for targeted advertising, or contextual segments which are groupings of websites or URLs by topic using semantic similarity which help advertisers place ads on relevant sites without targeting specific individuals.

Automated Decision-Making. We use automated technologies to analyze patterns in online activity. In some jurisdictions, this may be considered profiling, which refers to using automated tools to evaluate consumer interests or preferences. Our platform stitches data points together based on semantic similarity. We do not use automated technologies in ways that produce legal effects or other similarly significant impacts on individuals, such as decisions about credit, employment, housing, or access to essential services.

2. SOURCES OF PERSONAL INFORMATION

Synthesi does not directly collect the Personal Information used with our Services. Instead, we receive data from third-party sources, including consumer data compilers and resellers who aggregate information from other providers (including advertising networks and publishers that collect data through user interactions with digital content), identity graph partners, advertising technology companies, and business customers who use our Services.

These sources may collect information over time from non-affiliated websites, mobile apps, and internet-connected technologies such as computers, smartphones, and smart TVs. It is typically gathered using automated technologies like cookies, tracking pixels, web beacons, tags, or software development kits (SDKs), which help identify browsers or devices and associate activity across different sources and devices, a process known as cross-device tracking.

3. TYPES OF PERSONAL INFORMATION

The table below describes the types of Personal Information in our databases. We only use online data and do not collect or store offline details such as your name, address, or phone number.

Device identifiers - A device identifier is a unique string of characters assigned to your device or browser by means of a cookie or other storage technologies. It may be created or accessed to recognize your device, e.g. across web pages from the same site or across multiple sites or apps.

Device characteristics - These are technical characteristics about your device. These are tied to your device identifier but are not unique to you, such as language, time zone, or operating system.

IP addresses - Your IP address is a number assigned by your Internet Service Provider. While it may not always be specific to your device or stable over time, we may use it to infer your general location to develop our data products, understand your data rights, and share with our customers as part of our data products. Please note that we do not collect precise location data, which refers to your location within approximately 1,850 feet.

Third party identifiers - These identifiers may be probabilistic (generated by analyzing patterns across multiple data points using statistical models) or deterministic (based on authenticated data like hashed email addresses). We do not create these identifiers but may synchronize with them. We use third-party identifiers to help recognize users across devices and platforms and to ensure our data can be used consistently across different advertising platforms.

Behavioral data - Browsing Data. Information about your online activity, such as websites visited, apps used, searches made, and interactions with content or ads.

Transaction Data. Records of products or services you’ve purchased or considered online.

Survey Data. Self-reported information, such as interests, opinions, or demographic details.

Demographic data - This data includes attributes such as age, gender, occupation, current or past fields of employment, household composition, marital status, or income levels.

Inferred data - Our data sources may share, and we may generate, inferred data which means predictions about your interests, preferences, or characteristics. We may use any of the types of data in our databases to create inferences, including behavioral data and demographic data.

Sensitive Data. The definition of sensitive Personal Information varies by law, but often includes information about race, religion, ethnicity, sexual orientation, gender identity, political or philosophical beliefs, health conditions, or trade union membership. These categories may also overlap with protected classifications under state or federal law.

Synthesi does not knowingly collect sensitive Personal Information, does not create nor allow its clients to create audiences based on such data, or use it to infer sensitive characteristics or profiles. The inferences and profiles we generate are designed to reflect general interests or behaviors and not sensitive traits. To help reduce the likelihood of processing sensitive data, we follow industry-recommended filtering practices, including advertising classification frameworks such as the IAB’s audience and content taxonomies. Our customers are responsible for creating and using audience segments appropriately and ensuring their use of our services and data products complies with applicable laws and regulations.

Children and Teen Data. Our services and data products are not developed for, nor directed at, minors under the age of 18. We do not knowingly collect any Personal Information from minors and do not employ or offer advertising solutions directed towards minors. If you are a parent or legal guardian and believe your child has provided us with their personal information, please contact us at privacy@synthesi.com and we will use reasonable efforts to remove such information.

4. USE OF PERSONAL INFORMATION

Synthesi collects, sells, shares, and discloses your Personal Information in operating our Services. Our purposes in using your Personal Information depends on, among other things, our relationship or interaction with our data sources and business customers. We describe our commercial and business purposes in using your Personal Information below.

A. Commercial Purposes

Profiling. We use Personal Information to create or supplement user profiles in our databases.

Matching or Linking Personal Information from Different Sources. We may link browsers and devices that are likely associated with the same user to better understand cross-device behavior. This may involve using identity graphs or tables that connect online identifiers and signals to help locate users across different platforms and channels.

Audiences. We create audiences for use with targeted advertising. This includes modeled audiences where we create the audiences by inferring that individuals in the audiences may have similar interests or characteristics as individuals who have expressed an interest in the particular topic of the advertisement.

Contextual Segments. We model contextual segments. This means we analyze the content of URLs to determine if they’re relevant to what our business customers are looking for. From this information we can create grouping of relevant URLs for ad targeting.

Custom Algorithms. We analyze digital content and user data to generate numerical profiles called vectors, which represent users and digital content. The vectors capture semantic patterns in behavior and are used to train custom algorithms to learn how users engage with content. The resulting models can be applied to new data to predict interests, group users into audiences, and assess content relevance. Business customers may use our vector technology within their own websites, apps, or platforms to support segment creation, content personalization, or targeted advertising. The resulting scores and segments may also be shared for use across other platforms.

Insights and analytics. We use Personal Information to analyze the performance of our data services and understand and develop insights that help our business customers understand the effectiveness of our Services.

B. Business Purposes

To Develop and Improve our Services. We use your Personal Information for our own internal purposes, such as to operate, analyze, improve, test, update and verify our Services; and develop new services.

Legal Obligations, Security, and Safety. We may use your Personal Information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

For Other Internal Purposes. We also may use Personal Information for auditing for legal and other compliance purposes, aiding in ensuring security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for such purposes, debugging to identify and repair errors that impair existing intended functionality, short-term and transient use, and for the establishment, or the exercise or defense of legal claims.

5. DISCLOSURE OF PERSONAL INFORMATION

A. Commercial Recipients

We may disclose your Personal Information to the following categories of third parties for our commercial purposes, which may be considered a "sale" or "sharing" under applicable privacy laws, including for targeted advertising. Please note that Synthesi does not directly deliver ads for targeted advertising or directly personalize content. These activities are carried out by applicable third-party recipients or their partners.

AdTech and Social Platforms. We may disclose our data products to AdTech or social platforms, including intermediaries or resellers of our audiences such as demand side platforms, which enable advertisers to activate audiences by delivering targeted advertising. Where authorized under applicable contract terms, these platforms or their customers may also combine the Personal Information with other datasets.

Machine Learning-Powered Platforms. We may disclose our data products to companies that use advanced data and machine learning technologies to support advertising, personalization, and audience segmentation. These include platforms that help advertisers analyze consumer behavior, build custom audiences, improve content relevance, or optimize ad delivery across websites, apps, and other digital environments.

Third Party Data Marketplaces. We may offer our data products for sale in third party marketplaces.

Business Customers and Advertising Partners. We may share Personal Information with our business customers and advertising partners. These recipients may use the data to personalize content, build audiences, generate insights, or improve future marketing efforts, sometimes in combination with other data. In some cases, sharing is necessary to support how our Services function, including enabling compatibility across platforms.

Outputs That Do Not Contain Personal Information. Because our contextual segments are groupings of URLs (and not user identifiers), they do not include any Personal Information. Similarly, scores generated by our custom algorithms (such as user or page relevance scores) are not tied to identifiable individuals. As a result, these outputs are not considered “sold” or “shared” for purposes of “targeted advertising” under applicable privacy laws.

B. Business Recipients

We may disclose your Personal Information to the following categories of recipients for general business purposes:

Service Providers. We disclose your Personal Information to service providers that provide business, professional, or technical support services, and administer activities on our behalf. Service providers are contractually restricted from using Personal Information for any purpose other than as necessary to provide services to us.
Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
Competent Governmental, Regulatory, and Public Authorities. We may disclose Personal Information to governmental or law enforcement authorities to comply with valid legal or regulatory obligations or requests.

Other Third Parties. We may disclose your Personal Information to other third parties at your direction or consent.

6. AGGREGATED AND DE-IDENTIFIED INFORMATION

We may aggregate or de-identify Personal Information so it can no longer be linked to you or your device. Aggregated or de-identified data may be used to train algorithms, generate insights, or support product development, and may be shared at our discretion. We do not attempt to re-identify this data, except as permitted by law.

7. GEOGRAPHIC SCOPE

Synthesi’s Services are designed for use within the United States and we do not knowingly collect Personal Information from individuals located in other countries. However, in some cases, Personal Information processed through our Services may inadvertently relate to individuals in other jurisdictions. While Synthesi does not currently operate in those markets or intentionally include such data, we take reasonable steps to handle all Personal Information in a privacy-conscious manner.

If you are outside the United States and believe we have collected your Personal Information in error, please contact us at privacy@synthesi.com and we will make reasonable efforts to remove it. As Synthesi grows, we may expand our Services to additional regions and will update this Policy to align with applicable laws and frameworks in those jurisdictions.

8. HOW LONG DO WE RETAIN PERSONAL INFORMATION

We will retain Personal Information for as long as necessary for the purposes outlined in this Policy, including for the purposes of satisfying legal, regulatory, tax, accounting, or reporting requirements. We retain data as required by applicable laws and data may be retained for business continuity, dispute resolutions, or enforcement of agreements.

We apply data minimization principles by limiting retention to what is needed for operational, analytical, or compliance purposes. Retention periods vary depending on the type of data and how it is used.

Digital identifiers are refreshed every 90 days and are automatically deleted if no longer linked to active behavioral data or if we have received an opt-out signal or deletion request. Other data types (such as behavioral data, commercial and survey data, demographic data, inferred data, and non-precise geolocation data) are retained for up to 9 months from the time they were last received or last associated with an active identifier. These data types are not stored independently but are tied to online identifiers to support the functionality of our Services.

All data is subject to automatic deletion in response to a valid privacy request. We may retain an identifier to flag it on a suppression list, to exclude it from future processing or use in accordance with applicable privacy laws.

9. DATA SECURITY

We have implemented appropriate security measures to protect the Personal Information in our databases against any unauthorized access, use or disclosure. However, regardless of any technical and organizational measures Synthesi has put in place to assure that data in its custody is secured, no such steps are foolproof, we therefore cannot guarantee that such data will not or cannot be subject to breach or to hackers.

10. OPT-OUT REQUESTS

No matter where you live, you have the right to opt out of our databases and data sharing practices.

A. Synthesi Opt-Out

Synthesi offers a unified opt-out system that applies across all data processing activities in our databases, subject to the limited exceptions described in this Privacy Policy. While our opt-out system is designed to be comprehensive, we provide the information below about specific opt-out rights to help you understand how they may apply based on your state of residence and the laws that govern your Personal Information. Please visit our Privacy Choices page to opt-out.

Do Not Sell or Share My Personal Information. You may opt out of the sale or sharing of your Personal Information, including its use for targeted advertising (also referred to as “cross-context behavioral advertising” under California law). A “sale” may include data transfers even without monetary exchange.

Opt-Out of Targeted Advertising. You may request that we stop using your data to create audience segments or profiles used for targeted advertising across websites, apps, or platforms.

Limit Use of Sensitive Personal Information. If you are a California resident, you can request that we stop processing or sharing your sensitive Personal Information. Synthesi does not knowingly collect or use this data. However, you may submit a request and we will honor it in accordance with applicable law.

Right to Opt-Out of Profiling. Synthesi does not use Personal Information to make automated decisions that produce legal or similarly significant effects. However, if your state provides a right to opt out of profiling, you may still submit a request, and we will honor it as applicable.

Right to Withdraw Consent. Where we rely on your consent to process Personal Information, you may withdraw it at any time by visiting our opt-out page or submitting a deletion request. Withdrawing consent does not affect the lawfulness of prior processing.

B. Opt-Out Signals

Synthesi honors the Global Privacy Control (GPC) and other privacy signals transmitted through the IAB’s Global Privacy Protocol in the markets where we operate. When we receive a valid opt-out signal, we treat it as a request to opt out of the sale or sharing of Personal Information for that browser or device and any associated profile in our databases.

C. Third Party Opt-Outs

You can also visit advertising industry opt-out pages operated by the Digital Advertising Alliance. We do not control these third-party opt-out tools, and opting-out using industry tools may not eliminate all interest-based advertising.

11. YOUR PRIVACY CHOICES

Individuals may have certain rights regarding their Personal Information under privacy laws that apply based on their location. These rights generally include the ability to access, correct, delete, or limit the use of Personal Information, and in some cases, opt out of specific types of processing such as targeted advertising.

We currently operate in the U.S. market, where certain state laws grant individuals rights over their Personal Information, including the ability to access, correct, delete, or opt out of certain data uses. We comply with applicable U.S. state privacy laws, including those in California, Colorado, Connecticut, Virginia, Texas, Oregon, and others that have enacted consumer privacy protections. For general information on U.S. state privacy laws, you may visit the IAPP U.S. State Privacy Legislation Tracker (an independent resource; we do not control its content). As new privacy laws take effect and we expand our services into additional countries or markets, we will continue to update our practices accordingly.

Depending on your place of residence and the privacy laws that apply to you, you may have certain rights regarding your Personal Information. These rights are subject to specific conditions, limitations, and exceptions under applicable laws.

Right to Opt Out of Certain Data Uses. You may opt out of the sale or sharing of your Personal Information, or its use for targeted advertising (also known as “cross-context behavioral advertising” in California).
Right to Delete. You may request that we delete Personal Information we have collected from you, subject to legal exceptions. We may retain certain data to comply with legal obligations, including maintaining a suppression list to honor your deletion request.
Right to Know / Access. You may request information about the Personal Information we collect, including categories of data, sources, purposes, recipients, and specific pieces of Personal Information we hold. Some states also allow you to request a list of third parties with whom your data has been shared.
Right to Data Portability. You may request access to your Personal Information in a portable format, where technically feasible. If you submit a portability request, we will delete your data in accordance with our deletion process.
Right to Correct. You may request correction of inaccurate Personal Information we maintain about you, subject to verification. Correction requests are processed in accordance with our deletion procedures.
Right to Appeal. If we deny your request, you may have the right to appeal our decision. If your appeal is denied, you may be able to escalate the matter to your state’s Attorney General or privacy regulator.

12. PROCESS FOR SUBMITTING PRIVACY REQUESTS

To submit a privacy request, please visit our Privacy Choices page.

Authorized Agents. If allowed by state law, you may designate an authorized agent to submit a privacy request on your behalf. We may verify both your identity and the agent’s authority, which may include contacting you or requesting documentation.

Verification. For most requests other than opt-outs, we are required to verify your identity and state of residence before processing your request. This may involve requesting additional information. If we are unable to verify your identity or the agent’s authority, we may decline the request as permitted by law.

Fees. We do not charge a fee to process your request unless it is excessive, repetitive, or manifestly unfounded. If a fee is necessary, we will notify you in advance. Some state laws may limit the number of requests you can make within a 12-month period.

Our Response. We will respond to your request within the timeframe required by applicable law (typically 45 days, with extensions as permitted). If additional time is needed, we will notify you within the initial response period and explain the reason for the extension. If we are unable to fulfill your request in full, we will provide an explanation.

Right to Appeal. If we deny your request, residents of certain states have the right to appeal our decision. To submit an appeal, please email privacy@synthesi.com and include:

Your original request
Our response to your request
The reason for your appeal

We will respond within the required timeframe. If you are not satisfied, you may contact your state’s Attorney General or privacy regulator:

Find your State Attorney General: https://www.naag.org/find-my-ag/
California residents can also contact the California Privacy Protection Agency: https://privacy.ca.gov/california-privacy-rights/your-right-to-privacy/

13. REVISIONS TO THIS PRIVACY POLICY

Synthesi may update this Policy at any time by posting changes on this website. We encourage visitors to check this page regularly and refer to the "Last Updated" date at the top of this Policy.

14. HOW TO CONTACT US

You can contact us at privacy@synthesi.com or by mail at the following address:

Synthesi Inc.

1131 Campus Dr.

Morganville, NJ 07751

USA