Scope

This comprehensive set of disclosures underscores GumGum’s Contextual Platform commitment to transparency and accountability in its service operations. These policies aim to maintain a high level of trust with subscribers by ensuring complete reports and addressing errors, disclosing accreditation status, and providing detailed error logs. Additionally, the Contextual Platform's practices, such as content-level verification and alignment with industry standards, are outlined to provide a clear understanding of its methodology and operational principles.

1. Contextual reports are always issued in their entirety, ensuring completeness. In the event of any errors or known omissions, we have established a remediation control system that includes error notification and data reissuance policies to address and rectify these issues promptly.

2. To ensure transparency and avoid subscriber confusion, GumGum Contextual takes efforts to fully disclose the accreditation status of its services. In compliance with the minimum requirements, any report covering non-accredited services will be distinctly different from those used for accredited services. Additionally, each non-accredited report will prominently display the following statement on the outside front cover, inside front cover, or the opposite page: "This service is not part of a regular syndicated rating service accredited by the MRC, and GumGum Contextual has not requested accreditation. However, the Contextual Platform does provide one or more syndicated services that are accredited by the MRC."

3. GumGum Contextual maintains an error log for a duration of two years, as required. This log includes comprehensive documentation of errors, encompassing the duration of the error's impact on published figures, its absolute and relative effects, the cause of the error, the corrective actions taken, and any disclosures made to subscribers, including copies of notices. If a decision was made not to disclose an error, the record will indicate the underlying reason for this choice.

4. GumGum Contextual, within its data reissuance and error notification policies, ensures that users of the System are alerted to audience estimates that may have suspect reliability, particularly in cases of less than minimum reportability. Additionally, GumGum Contextual reports clearly delineate any changes in the minimum requirements for reporting and reliability, which can occur due to the customizable nature of System analyses, including indicating the minimum number of sample returns required for each analysis.

5. GumGum Contextual operates independently of the bidstream and focuses solely on digital content for contextual and brand safety analysis and classification reporting. While GumGum Contextual does not measure IVT-related practices, it maintains adequate disclosures to enable buyers to comprehend the removal of General Invalid Traffic (GIVT), reported valid traffic, and Sophisticated Invalid Traffic (SIVT) at the campaign level, as well as requested specific transaction-level information.

6. GumGum’s Contextual Platform Description of Methodology (DOM) includes information on the frequency of processes and granularity (with a preference for impression level), updating processes, the nature and scope of process and transaction auditing (both internal and external), as well as error correction and reissue criteria. Additionally, partner qualification controls and material business partner relationships are addressed in policies made available to all employees. These disclosures ensure transparency and provide buyers with a comprehensive understanding of GumGum Contextual’s methodology and processes.

7. Notification of any issues to the seller will be conducted in accordance with the contractual terms established between the buyer and seller. GumGum Contextual ensures that these communication terms, as outlined in the contract agreements, are followed and retains the relevant information pertaining to such notifications.

8. GumGum Contextual maintains a classification appeal and verification process that allows sellers to report inaccuracies and false positives, enabling them to request corrections. This process ensures that sellers have a mechanism in place to address any concerns they may have regarding the accuracy of Contextual Platform’s classifications.

9. GumGum Contextual, as a content-level service provider, discloses that its verification service is performed at the content level, focusing on the specific content rather than site or domain-level verification. This disclosure ensures transparency regarding the depth of verification performed by Contextual.

10. Contextual disclosures when a significant verification finding is reported relative to a certified/accredited organization by an independent third party and that finding has implications on measurement of the transaction.

11. GumGum maintains a comprehensive documentation center that includes all necessary disclosures, policies, processes, procedures, instructions, and relevant information pertaining to our Contextual Platform service. This documentation covers various aspects of our service, including potential avoidance categories, ad verification capabilities and limitations, measurement granularity, data assumptions, verification timing, reporting thresholds, machine learning methodology, genre classification taxonomy, metadata sources, content recognition processes, and more.

12. GumGum Contextual does not consider user-generated content (comments) in its measurement and categorization processes. While GumGum Contextual continuously monitors for potential safety impact, it is important to be aware that user-generated content may still pose safety risks.

13. GumGum Contextual aligns with industry standard taxonomies, including the IAB TL Content Tax and GARM Safety and Suitability Floor, for genre classification and segmentation.

14. GumGum Contextual provides classification data only if sufficient information can be extracted.

15. The Contextual Platform does not provide any third-party data without explicitly disclosing that the data originates from a third-party source.