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GDPR Compliance

October 3, 2022

At Carousel Digital Signage (a division of Tightrope Media Systems, Inc.), we are committed to
being transparent with our customers regarding our privacy practices and complying with all
applicable privacy laws and regulations, such as the European Union (EU) General Data
Protection Regulation (GDPR). We value your trust and are dedicated to protecting your
privacy.

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Our commitment to protecting the privacy of our customer’s data includes:

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● The objective of limiting our use of personal data to only what is necessary to conduct business with our customers. When we do need to collect or use personal data, we do so only to communicate with you and provide to you with the services we offer. We have no interest in your personal data for any other reason.
● All employees and contractors are subject to background checks, sign non-disclosure agreements, and are subject to ongoing security and privacy training.
● Establishing processes and tools for promptly addressing your requests for information about our processing of your personal data.
● A comprehensive Privacy Policy located here, with a commitment to doing annual reviews of this policy going forward.
● Leveraging third-party security experts to conduct annual security tests of our products and systems.
● A strong overall commitment and cultural desire for lawfulness, transparency, integrity, and accountability in our data privacy practices.

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What is GDPR?

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GDPR was adopted in 2018 to strengthen and unify data protection for residents of the European Union (EU), while also addressing the export of personal data outside the EU. Some of our customers are subject to GDPR, and we have implemented measures so that we can process data for them in compliance with GDPR.

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GDPR Compliance Steps

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Here are some of the steps we have taken to enable our customers to comply with GDPR:

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1. We have strengthened our security infrastructure.
2. While not legally required to do so, we have appointed a dedicated Privacy and Security
Officer, who can be reached via email at privacy@carouselsignage.com.
3. We maintain a roster of our third-party sub-processors and have classified the data that
is transferred to them. The roster is available on our website.

4. We have executed Data Processing Agreements or Addendums (DPAs) with sub-
processors to ensure onward transfers of your data is safe.
5. We have adopted our own DPA for the benefit of our customers and users.
6. We have appointed GDPR-Rep.eu as an Article 27 E.U. Representative. They can be
reached at:

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Maetzler Rechtsanwalts GmbH & Co KG
c/o Tightrope Media Systems, Inc.
Schellinggasse 3/10, 1010 Vienna, Austria
Website: https://www.gdpr-rep.eu
Please add the following subject to all correspondence:
GDPR-REP ID: 11082518

7. We have established an online portal for individuals wanting to make requests about their personal data. You can visit this portal here.

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Disclaimer

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The content on this page is provided for informational purposes only and the information shared here is not meant to serve as legal advice or create any contractual or legal obligations for Carousel Digital Signage or its customers and users. You should work with legal and other professional counsel to determine exactly how the GDPR may or may not apply to you. The legal rights and obligations of Carousel Digital Signage and its customers and users are stated
in our Carousel Terms of Use and other online agreements.

Dated: September 30, 2022.

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