Privacy Policy

Effective Date: January 13,2026

Introduction

Thank you for choosing to learnmore about the privacy policies of DB Sub, LLC (“DB,” “we,” “us,”“our” or “Company”).

This privacy policy (“Privacy Policy”) explains how we may collect, store, use, and disclose information when you access or use this Privacy Policy webpage (“Webpage”) or DB’s products and services (collectively referred to as “Services”).

Our affiliates and parent company, ParTech, Inc., have their own privacy policies that apply to information they collect from the products, services, sites and applications they provide. DB may collect, use, and disclose information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular consumer or household (“Personal Information”) in connection with the Webpage or Services.

By accessing or using the Webpageor Services, or otherwise providing us with Personal Information, you acknowledge and agree to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all prior notices and statements regarding our privacy practices with respect to the Webpage or Services. If you do not agree to the terms and conditions of this Privacy Policy, please do not access or use the Webpage or Services.

Certain portions of this Privacy Policy also apply to other Personal Information collected or maintained by DB; for example, if you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia please see the  “State-Specific Information and Rights” below for more specific information about yourprivacy rights under these U.S. Privacy Laws.

Policy Updates and Changes

We reserve the right, at anytime, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Webpage and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Webpage.

Contact Information

If you have any questions aboutthis Privacy Policy, our Webpage, or our practices relating to our Services, please contact us through one of the methods listed below:

           DB Sub, LLC

           1209 Orange Street

           Wilmington, DE 19801

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How we Collect, Use, and Disclose Information from Visitors to our Webpage

Through our Webpage, we collect information you choose to provide us, as well as information that is automatically collected, in order to enhance our Webpage and our Services.

Information You Choose to Provide Us Through the Webpage

DB offers visitors to our Webpage the opportunity to reach out to us in various ways, including the opportunity to contact us with questions or comments, or to request information from us about our business. In connection with these opportunities, you may provide – and we will therefore necessarily collect certain Personal Information, including:

-      Name;

-      Email address; or

-      Phone number.

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We will use the information you choose to provide us through our Webpage for legitimate business purposes, including to:

-      Analyze, improve, and customize the Services;

-      Send you announcements, newsletters, promotional materials, and other information about the Services;

-      Respond to your questions or comments; or

-      Provide you with the requested information. 

As a general matter, we will not disclose any of the Personal Information you provide us through our Webpage to any third parties. However, we reserve the right to do so when necessary orrequired by the circumstances, such as (i) to protect or defend the legal rights of DB; (ii) to protect against fraud or for risk management purposes; (iii) to comply with applicable law or respond to legal process; or (iv) if DB undergoes bankruptcy or dissolution. Additionally, if DB sells, merges, or transfers all or part of its business or assets, we may transfer the information you provided us through our Webpage to the parties involved in that transaction.

Unless otherwise required by applicable law, we will retain the Personal Information you choose to provide us through our Webpage only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. You may opt not to receive newsletters orother promotional emails from us at any time by contacting us or by following the “unsubscribe” instructions in any promotional email you receive from us.

Information We Automatically Collect Through Our Webpage

When you visit the Webpage, we may automatically collect certain information through cookies and similar technologies (including pixels, tags and web beacons) (collectively, “Cookies”). Cookies are small text files stored by your browser on your computer, phone, tablet, or other device you use to access our Webpage. The Cookies on our Webpage collect information related to the device you used to access our Webpage such as the IP address and type of device. Cookies allow us to identify visitors, track aggregate behavior, and recognize certain types of information on your computer, such as a Cookie number, time and date of a page view, and a description of the page where a Cookie is placed.

The Cookies on our Webpage also may collect the following categories of information:

-      IP addresses;

-      Domain servers;

-      Types of computers accessing the Webpage;

-      Referring/exit websites;

-      Operating systems;

-      Internet Service Providers (ISPs);

-      Types of web browsers used to access the Webpage; and

-      Geographic location information.

The length of time a Cookie will stay on your browser or device depends on whether it is a “persistent” or “session” Cookie. Session Cookies will only stay on your device until you stop browsing. Persistent Cookies stay until they expire or are deleted. The expiration time or retention period applicable to persistent Cookies depends on the purpose of the Cookie collection and tool used. Unless otherwise required by applicable law, we will retain any Personal Information collected through Cookies only for as long as necessary to fulfill the purposes outlined in this Privacy Policy.

We will use the information we automatically collect through Cookies on our Webpage for legitimate business purposes, including to:

·      Analyze, improve, and customize the Services and the Webpage; and

·      Market the Services.  

We use three types of Cookies onour site: 1) strictly necessary Cookies, 2) performance and functional Cookies and 3) marketing Cookies.  

-      Strictly Necessary

These Cookies are required to enable the basic features of our website such as navigating to pages or accessing secure areas. Without these Cookies our Webpage cannot function properly. Strictly necessary Cookies are always stored on your browser as they are essential for enabling the basic functionalities of our Webpage.

-      Performance and Functional Cookies

Performance and functional Cookies are served by us and our partners, such as Google Analytics. Performance and functional Cookies help us understand how you use the Webpage and how we can provide a better experience. The information collected from these Cookies helps us analyze trends in usage of the Webpage and remember your choices regarding the Webpage (such as your preferred language and what region you are in) to provide enhanced, personal features.  

-      Marketing Cookies

Our Webpage uses Cookies served by us and our third-party partners to help us show relevant advertising to you more effectively and to measure the performance of ads. The information collected via these Cookies will be used to show you better and more personal advertisements on the Webpage and other sites you visit and analyze traffic to the Webpage. We may share this information with our advertising partners.

-      Your Choices Regarding Cookies

You have the right to choose whether or not to accept all Cookies except strictly necessary Cookies which are essential for enabling the basic functionalities of our Webpage.  To manage your choices regarding Cookies other than strictly necessary Cookies on the Webpage (the “non-essential Cookies”), please visit our Privacy Preference Center. You can also modify the settings onyour browser to limit the types of Cookies you encounter. Check out the documentation for your browser to learn more. Please note that if you disable non-essential Cookies certain features of our Webpage may be limited or may notwork at all.

For further information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, you can visit https://www.youradchoices.com/.

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How We Collect and Use Information in Connection with The Services

 As part of its provision of Services, DB allows its clients (“Clients”) to anonymously individualize purchases, providing them with their customers’ purchase history, demographics, location, spend, and other calculated attributes derived from this information. 

To provide our Services, we utilize (i) Personal Information provided to us by or on behalf of our Clients (“Client Information”) solely for their own use, and (ii) Personal Information that we license from third parties (“Licensed Information”). We also use Licensed Information to provide products and services to participants in the DB media network (the “DB Participants”). 

In addition, we utilize deidentified information that cannot reasonably be linked to you in connection with our Services and the DB media network. When such deidentified information is, directly or indirectly, associated or combined with Personal Information, such deidentified information will be considered Personal Information for purposes of this Privacy Policy.

We do not knowingly collect,share, sell, disclose, or otherwise maintain any sensitive personal information or protected information, as those terms are defined by applicable U.S. state privacy laws.

Except as described in this Privacy Policy (Section: How we Collect, Use, and Disclose Information from Visitors to our Webpage), DB does not collect Personal Information directly from consumers. 

Client Information

The businesses who use our Services to understand and advertise to their customers may provide us with Client Information when they use our Services. This Client Information is collected from transactions you have made with those businesses or through loyalty or purchase accounts you have with those businesses, and may include:

• Identifiers, such as your name, email, phone number, delivery address, loyalty program number, online order number, and payment or tender details (but not financial account numbers or full credit card numbers); and
• Commercial Information, such as your historical item level purchase history, store location and spend.

We use this Client Information to identify and understand you as a customer of a particular Client, and to provide our Services. We may combine information received from our Clients withother Licensed Information. The business purpose for collecting and utilizing the Client Information is to provide Services to our Clients. Our Clients may use the Services and the Client Information for analytics purposes or for advertising and marketing purposes such as to create and advertise to specific audiences of their customers or to provide personalized offers or messages.  

Licensed Information

We also collect, license, or otherwise receive information about you from several third parties. This Licensed Information may include:

• Identifiers, such as your name, postal and email addresses, telephone number, loyalty program number, online order number, and payment or tender details (but not financial account     numbers or full credit card numbers); and online identifiers such as device IDs and IP addresses;
• Characteristics, such as information about interests, gender, socioeconomic information, marital status and other lifestyle information;
• Commercial Information, such as your historical item level purchase history, and information about your purchasing tendencies;
• Internet or Other Network Activity, such as information regarding your interaction with a website;
• Geolocation Information, such as the retail location where purchases were made;
• Professional or Employment Information, such as your industry sector or segment and salary range;
• Education Information, such as your education level; and
• Inferences that have been drawn from the above-listed information, such as inferences about your interests, preferences, behavior, attitudes, and characteristics.

The business purpose for collecting and utilizing the Licensed Information is to provide our Services to our Clients. For example, we may allow our Clients to use Licensed Information to segment consumers to activate an ad campaign targeting a specific segment of consumers or to perform analytics on a certain subset of consumers.  

DB Media Network

In connection with our DB media network, we receive information from retailers (the “Retailers”) which includes some or all of the types of information listed in the Identifiers, Geolocation Information, and Commercial Information sections above (“DB Licensed Information”). The Retailers who provide us with the DB Licensed Information collect information about you from transactions you have made with them or loyalty or purchase accounts you have with those businesses.

We utilize the Licensed Information to run the DB media network including by selling licenses to subsets of Licensed Information to DB Participants. DB Participants are parties who want to use Licensed Information for marketing or analytics purposes including for cross-context behavioral and targeted advertising. We only allow DB Participants to access Licensed Information if we have obtained the requisite permissions from the corresponding DB Retailer(s). Our agreements with DB Participants prohibit them from using DB information except as specifically authorized.  

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How We Disclose Personal Iinformation in Connection with the Services

With regard to Client Information, we disclose (and during the last 12 months have disclosed) each of the categories of Client Information listed above solely as directed by the applicable Client.  We do not ‘sell’ or ‘share’ Client Information as those terms are defined by applicable U.S. state privacy laws. 

We may disclose, process and/orstore some or all of the Licensed Information and Client Information we collector receive to third-party service providers, who help us provide our Services, such as cloud computing providers, data analytics providers, ad platforms, or marketing service providers in order to execute our Services on behalf of our Clients. These service providers have executed agreements with DB and/or our Clients to not access, use, or disclose DB information except as specifically authorized and directed by the agreement.

In addition, we may share Licensed Information, and inferences drawn from Personal Information included within Licensed Information, with our Clients, with our marketing partners and with DB Participants for marketing and analytics purposes including for cross-context behavioral and targeted advertising.  This sharing may constitute a ‘sale’ of Personal Information as those terms are defined by applicable U.S. state privacy laws. We never expose any consumer contact information (name, email, phone number, address) in Licensed Information to Clients or DB Participants. 

We may also disclose your information:

• For legal reasons, including when we must do so to comply with applicable law, legal processes or investigations, to exercise or defend a legal claim, to cooperate with law enforcement, to enforce any applicable terms, or to protect rights belonging to you, the Company, or our Clients;
• To our affiliates, including parents, subsidiaries, business units, and other companies that share common ownership with us;
• If another individual is managing your account on your behalf (for example, an employee managing the account of a manager), as authorized by you or as a personal representative under applicable law;
• In connection with a sale, merger, restructuring, or other corporate transaction; and
• When you permit or direct us to share this information with a third party.

Security of Personal Information

We have put in place reasonablesecurity measures to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. The measures we use may include storing Personal Information on secured servers, transmitting Personal Information using encryption technologies, and auditing and reviewing our Information collection and storage practices. The Webpage has security measures in place, including but not limited to the use of a Secure Sockets Layer (SSL) software to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee absolute security.

We have and require our service providers with whom we may disclose Personal Information to have administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration.

Retention Information

Unless otherwise required byapplicable law or regulation, we will retain Client Information and Licensed Information only for as long as necessary to provide the Services and to fulfill the purposes outlined in this Privacy Policy. The criteria used to determine the period of time we retain such Personal Information includes the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, as well as on the basis of applicable legal, regulatory, tax, accounting or other requirements (such as applicable statutes of limitation).

Third-Party Websites

The Webpage may contain links to other websites. This Policy is only applicable to the Services and the Webpage. The information practices or content of other third-party websites is governed by the privacy policies and statements of other such respective websites. Ifyou choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

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Notice Concerning Children

We do not knowingly collect Personal Information from children under the age of 16. If we learn we have collected or received Personal Information from a child under the age of 16 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under the age of 16, please contact us.

State-Specific Information and Rights

Depending on what state youreside in, you may have certain rights with regards to your Personal Information. This section generally applies to residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia (the “States”) whose personal information is subject to the California Consumer Privacy Act as amended, Colorado Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Act Relating to Consumer Data Protection, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Protection Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Privacy Statement for Utah Residents as required by the Utah Consumer Privacy Act, Virginia Residents as required by the Virginia Consumer Data Protection Act (“U.S. State Laws”) and certain exceptions within such laws, as applicable. If you are not a resident of the above-mentioned states, the rights described in this section do not apply to you.

The provisions below supplement the information provided in the generally applicable portion of our Privacy Policy and apply solely to individuals that are residents of the States and qualify as a “Consumer”, or equivalent term under the applicable U.S. State laws respectively. This State-specific section provides additional information about how we collect, use, disclose and otherwise process the Personal Information of these individuals, either online or offline, within the scope of the applicable U.S. State Laws. Terms in this section are to be understood in a manner consistent with applicable U.S. State Laws including the definitions of such terms in the U.S. State Laws. Such terms may have a different definition or meaning in other portions of this privacy policy because U.S. State Laws may not apply to those sections.

Categories of Personal Information Processed

Please refer to the appropriate section of this Privacy Policy. In addition, we do not knowingly collect, share, sell, disclose, or otherwise maintain any sensitive personal information or protected information, as those terms are defined by applicable U.S. state privacy laws.

Purposes of Processing

Please refer to the appropriate section of this Privacy Policy.

Categories of Information Disclosed to Third Parties

Please refer to the appropriate section of this Privacy Policy.

Categories of Third Parties We Share with Whom We Have Shared Your Personal Information

Please refer to the appropriate section of this Privacy Policy.

-      California Residents’ Privacy Rights

If you are a California resident pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), this section applies to you. For purposes of this section, “Personal Information,” has the meaning given in the CCPA and does not include information excluded from the CCPA’s scope.

Information Regarding Consumer Information Requests. In 2025, DB received:

-      0 requests to delete;

      -     For requests where sufficient information was provided, DB denied none of these requests, complied with all of these requests in full.

-      0 requests to know or access;

      -     For requests where sufficient information was provided, DB denied none of these requests, complied with all of these requests in full.

-      0 requests to opt out; and

      -     For requests where sufficient information was provided, DB denied none of these requests, complied with all of these requests in full.

The median number of days it took DB to substantively respond to the above requests is not applicable. The mean number of days it took DB to substantively respond to the above requests is not applicable.

If you are a California resident, DB extends the following rights and choices to you regarding your Personal Information:

Right to Know. You have the right to know and see what information we have collected about you over the past 12 months, including;

-      The categories of Personal Information we have collected about you;

-      The categories of sources from which the Personal Information is collected;

-      The business or commercial purpose for collecting your Personal Information;

-      The categories of third parties with whom we have shared your Personal Information; and

-      The right to access the specific pieces of Personal Information we have collected about you in a portable format.

-      Information regarding the categories of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting your Personal Information and the categories of third parties whom we have shared your Personal Information can be found in the corresponding section of this Privacy Policy. 

Right to Delete. You have the right to request that we delete the Personal Information we have about you.

Right to Opt-Out. You have the right to opt out of the “selling” or“sharing” of your Personal Information, as those terms are defined in the CCPA. You may do so by submitting a request through one of the means described below. 

Right to Correct. You have the right to request that we correct inaccurate Personal Information.

Other Rights. You can request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your California Privacy Rights. To request access to, deletion,or correction of your Personal Information, to opt out of the sale or sharing of your Personal Information for cross-context behavioral advertising, or to exercise any other rights under California law, please contact us using one of the following methods:

-      Email us at privacy@partech.com  

-      Call us toll-free at 1-800-448-6505, option #5

Verification. When we receive your request, we may need to collect additional information from you to verify your identity and eligibility before processing your request. You may also designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof of authorization.

Response Timing and Format. You may request access to your Personal Information twice in any 12-month period, measured from the date we receive your first request. If you submit a request to obtain your Personal Information more than twice in any 12-month period, we will either: (i) proceed with honoring your request; or (ii) deny your request in writing. We aim to respond to consumer requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing. We will respond to requests to opt out of the sale of your Personal Information within 15 business days.

Shine the Light Law

Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining Services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the consumer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of consumer information and the names and addresses of those businesses with which we shared consumer information for the immediately prior calendar year (e.g., requests made in 2025 will receive information regarding 2024 sharing activities).

To obtain this information please use the “Contact Information” above with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested applicable information to you at your e-mail address in response to any need to verify whether these rights apply to you.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information covered will be included in our response.

Selling or Sharing of Personal Information

With respect to our “sale” or “sharing” of Personal Information other than that collected by Cookies and other tracking technology, we will, upon a verifiable request made through one of the methods provided in the “Contact Information” section above, not allow your Personal Information to be “sold” or “shared,” as those terms are defined by CCPA.

·      Right to Delete. Upon a verifiable request, made through one of the methods provided in the “Contact Information” section above, we will delete Personal Information we have collected directly from you and direct our service providers and processors to delete your Personal Information from their records.

·      Right to Correct. Upon a verifiable request, made through one of the methods provided in the “Contact Information” section above, we will correct inaccurate Personal Information that we maintain about you.

We will not discriminate against you for exercising any of your privacy rights.

-       States’ Privacy Rights

If you are a resident of one of the States pursuant to the U.S. State Laws, this section applies to you. This section describes the rights you have with respect to your Personal Information under the applicable U.S. State Laws. For purposes of this section, “Personal Information,” has the meaning given in the applicable U.S. State Laws and does not include information excluded from the applicable U.S. State Law’s scope. If you are a resident of one of the States, DB extends the following rights and choices to you regarding your Personal Information:

Right to Know. You have the right to know and see what Personal Information we have collected about you in a portable format.

Right to Delete. You have the right to request that we delete the Personal Information we have collected about you. 

Right to Opt-Out. You have the right to opt out of targeted advertising and the sale of your Personal Information (as those terms are defined under applicable U.S. State Laws). You also have the right to have an authorized agent opt out on your behalf. We may deny a request from an authorized agent that does not submit adequate proof of authorization.

Right to Correct. You have the right to request that we correctinaccurate Personal Information.

ExercisingYour Privacy Rights. To exercise your Information rights under Colorado law, please contact us using one of the following methods:

-      Email us at privacy@partech.com  

-      Call us toll-free at 1-800-448-6505, option #5

Verification. When we receive your request, we may need to collect additional information from you to verify your identity and eligibility before processing your request.

Response Timing and Format. We aim to respond to consumer requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing. We will respond to requests to opt out of the sale of your Personal Information within 15 business days.

Appeal.  To appeal a refusal to take action on your request, please see the instructions in our response to your request.  

-       Nevada Residents’ Privacy Rights

Nevada residents have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. You may contact us via the “Contact Information” section of the Privacy Policy and provide your name, Nevada address, and email address to be verified and exercise your opt-out rights. If you change your email address or other contact information, contact us in the same manner to update your contact informationto help facilitate your opt-out. Changing your contact information elsewhere (e.g., informational requests, account information) will not update your Nevada opt-out information, and we will only use the information provided to our opt-out program for managing opt-outs. It is your responsibility to keep your opt-out information current. If after opting out you direct us to share your covered information with others, we will do so regardless of your prior opt-out.

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