Conversant Description of Methodology IQG 2.2

The following Description of Methodology (DOM) applies to Conversant internet-based advertising.

Conversant is a member of the Trustworthy Accountability Group’s (TAG) Inventory Quality Guidelines (IQG) program. In an effort to promote transparency in digital advertising, Conversant initially coordinated with the Interactive Advertising Bureau (IAB) to develop and comply with the IAB’s Quality Assurance Guidelines (QAG) program that later became the foundation of the IQG program.

This certification program requires Conversant to verify that adherence to the requirements defined by the TAG IQG program. This document contains information about our processes, options and certification related to the TAG IQG requirements.

What IQG Certification Means

To receive IQG Certification, Conversant has performed the following:

• Adhere to the Trustworthy Accountability Group’s (TAG) Inventory Quality Guidelines (IQG); and
• Perform an internal audit on a quarterly basis to ensure that the guidelines are being followed; and
• Submit 2 public affidavits to the TAG annually, one from the Compliance Officer and one from the Conversant Executive overseeing this program.

Conversant self-certifies against these guidelines and thus are providing marketers & agencies with a standardized approach that is designed to make buying easier and to give increased control over where ads are placed. Marketers & Agencies will have greater brand safety assurances that ads will not appear next to content that they decide is inappropriate.

The following disclosure is made in connection with our self-certification and is intended to provide publishers and advertisers with an understanding of our capabilities and practices that are compliant with the Inventory Quality Guidelines.

This document is not intended to replace our standard Terms & Conditions or the Insertion Order, which are contractual documents, but is intended to supplement those documents to disclose our practices under the Inventory Quality Guidelines.

Inventory Acquisition

Transaction Party Source Identification and Relationships

Conversant must disclose their relationship with the owner of the source of media if applicable to the buy. This relationship may be either direct, indirect or programmatic on either the sell side or the buy side. Source relationships are defined in the following:

Seller:

• Direct - Owns inventory to be sold or formerly represents the owner in a contractual agreement. Publishers or Authorized Publisher Agents (APA) are direct sellers.
• Indirect - Sells inventory that it doesn’t own or directly represent. A network or exchange with no direct relationship to inventory owner is an example of an indirect seller.
• Programmatic - Mimics a seller, either direct or indirect, but is represented by an automated technology platform in real-time transactions.

Buyer:

• Direct - The party that owns or represents advertisements to be placed on the seller’s available media inventory. Advertisers or Authorized Advertiser Agencies (AAA) are direct buyers.
• Indirect - Purchases inventory on behalf of a direct buyer but lacks an authorized direct relationship with the advertiser.
• Programmatic - Mimics a buyer, either direct or indirect, but is represented by an automated technology platform in real-time transactions.

Publisher Protection: Conversant may make inventory available to advertisers via an exchange-based resale. This is disclosed in the buyer/seller agreement. Publishers have the ability to opt out of this form of monetization at any time by contacting the Conversant Publisher team.

• Direct: If required under the terms and conditions of the insertion order all ads for a specific buy will run on publishers that Conversant has a direct relationship. This is not standard for Conversant and would require explicit approval prior to the start of the campaign.
• Indirect: Some or all of the ads for a specific buy may run on publishers where Conversant does have a contractual agreement in place. Indirect inventory will only be utilized in situations where Conversant is not contractually required to have a direct relationship with the publisher under the terms and conditions of the insertion order.

Across Conversant’s network, both direct and indirect relationships with our publishers and advertising are served across all publishers regardless of this relationship unless explicit approval is given prior to the start of the campaign and agreed to in the Terms and Conditions of the insertion order, to specifically target or block publishers based on their relationship with Conversant.

Note: A direct relationship is where we have a contractual agreement to acquire inventory directly from the publisher or an authorized publisher agent (APA).

Source-level Transparency

Conversant provides the advertiser information about the source of its inventory as needed, below is a list of options that are offered:

• Full disclosure (certain site list): Conversant can provide the advertiser with a complete disclosure of all websites prior to running impressions (at least specifying the domain name) where ads may run. The advertiser will not necessarily run on all sites listed, but the advertiser will not run on any sites other than those listed. If this is required by the advertiser, this needs to be included as a requirement in the IO. The full site list will be attached to the insertion order or sent via email to the advertiser if required. Note to advertiser: not all publishers wish to be disclosed. Inventory availability may be affected by choosing to run only on disclosable sites.
• Partial disclosure (representative site list): Conversant can provide the advertiser with a list of representative sites where ads will run. The advertiser may run on sites other than those listed but the advertiser will not necessarily run on all sites listed. If this is required by the advertiser, this needs to be included as a requirement in the IO. The partial site list will be attached to the insertion order or sent via email to the advertiser if required.
• Minimal or No disclosure (blind/no site list): Conversant will not provide the advertiser with a list (either full or partial site list) of where the ads will run.

Technical Context

The technical context of the inventory includes whether the inventory is intended for display in a browser, digital in-stream video, mobile specific or unknown. For Conversant the inventory may display in any of the contextual technology platforms.

Inventory Evaluation

Content Type

The content type describes the type of content that is displayed either near the ad, or immediately before or after the ad is displayed. Conversant does not currently provide the content type in our reporting back to our advertisers.

Content Classification (Taxonomy)

Content Classification is disclosed by the publisher, both direct and indirect, upon sign up and validated for accuracy during the review process. In cases where the request is passed to us by a programmatic seller, that content classification is disclosed in appropriate ORTB bid request parameter. Reporting on the contextual content for where ads are displayed may be provided under some circumstances and where it cannot be identified, then the content classification can be disclosed as “unknown”, any reporting requirements must be specified in the IO.

Content Taxonomy Tiers - Conversant comply with the top two Tiers of the IAB Tech Lab Content Taxonomy for targeting.

Tier 1: Primary content definition for the targeting levels of category, site, or section. This level defines the general category of the content.

Tier 2: Secondary content level, nested under Tier 1.

Targeting Depth

Conversant offers the following targeting levels available to buyers:

• Category/Portal Level - Target a grouping of sites within a specific buy. Any site level targeting requirement by buyers would need to be established in the terms and conditions of the buy prior to campaign start.
• Site Level - Targeting to endemic sites where the majority of the content is on a specific topic that can be targeted at site level. Any content or contextual level targeting requirement by buyers would need to be established in the terms and conditions of the buy prior to campaign start.

Content Rating

Every publisher, with whom Conversant has a direct or indirect relationship, goes through an inventory vetting process that establishes the following:

• Rating system for website content.
• Descriptions for non-standard website content and non-standard site characteristics.
• Descriptions regarding illegal content prohibited from sale.

The following ratings system is applied to all member websites, based on the following broad groupings (Refer to Exhibit A for additional detail):

• All – All Audiences
• Everyone over 12
• Mature – Mature Audiences

The site rating is determined when the site/app first joins the Conversant network. The review process involves vetting the property against the list of non-standard content and is verified to be an appropriate site for our network and is rated appropriately. Additional procedures are performed on a periodic basis to ensure that the site ratings stay current and publishers are also reviewed on a periodic basis as part of Conversant’s internal audit.

Conversant does not accept publishers into the network that contain:

• Content related to engaging in, promoting or facilitating illegal or legally questionable activities such as drugs, bombs, theft and online pirating, hacking, spamming, and infecting as governed by United States Federal law.
• P2P, torrent sites, illegal music downloads, pirated software
• Content that is misrepresentative, defamatory, libelous, or that violates any applicable law or regulation,
• Content that infringes or violates any copyright, trademark, patent, right of publicity, right of privacy, moral right, or other right of any third party,
• Hate material or inappropriate or controversial subject matter of any nature, including without limitation that which pertains to illegal activity or to hacking, cracking, or warez

Refer to Exhibit B for additional details.

Non-Standard Classification

With the exception of unmoderated user generated content (UGC), Conversant does not run alongside any content containing:

• Extreme Graphics or Explicit Violence
• Pornography
• Profane Content
• Hate Content
• Properties Under Construction
• Incentivized Traffic

By default, all advertisers are excluded from running on content with non-standard classification with the exception of user generated content. User Generated content is identified and can be excluded based on the requirements of the buy. This requirement must be stipulated in the Terms and Conditions of the Insertion order prior to campaign launch. Refer to Exhibit C for the characteristics of inventory labeled as “non-standard.”

Placement Details

Conversant does not disclose placement details for Display Ads, Native Ads, Video Ads, or Mobile Ads. Conversant is not able to accept requirements in the IO that require disclosures of placement details.

Creative Specifications

Creatives specifications are disclosed prior to the start of the campaign with accordance to Open RTB Specifications. The creative specifications are disclosed to publishers throughout the campaign duration and publishers are able to implement blocks to stop campaigns that have the characteristics they don’t want display on their site.

The creative specifications are disclosed prior to the start of the campaign (which are taken from the OpenRTB Specification – Refer to Exhibit D):

Creative Evaluation (i.e., Buyer Disclosures)

Disclosures related to the contextual details for creative disclosed by the buyer are outlined in the following sections.

Creative Classification

The contextual nature of the ad can be disclosed in all media types, whether browser-based, video, or mobile. If the contextual nature of the ad displayed can’t be identified, then the creative classification is disclosed as “unknown.” Per the OpenRTB Specification, the IAB Tech Lab Content Taxonomy used to describe the seller’s inventory is used to describe the buyer’s creative until another taxonomy is created.

Creative Rating

Conversant does not accept advertiser creatives that contain:

• Profanity
• Provocative Images
• Nudity
• Violence

Conversant does accept creatives that contain images of alcohol. Creatives that contain images of alcohol are identifiable and passed in the bid request if required by seller regardless of source relationship. Any publisher looking to block Mature creative rating would block requests identified as alcohol.

Non-Standard Classification

Conversant does not serve creatives that meet the definition of Non-Standard Classification (Refer to Exhibit C)

Creative Attributes

Creative attributes are disclosed in the buyer-seller agreement prior to running impressions unless the source level transparency is “full, real-time disclosure,” in which case creative attributes are disclosed in real time.

The creative specifications are disclosed prior to the start of the campaign (which are taken from the OpenRTB Specification – Refer to Exhibit D):

Transaction Execution

Once inventory has been identified for acquisition and evaluated for contextual content classification and placement, how data is to be collected and used is disclosed in the buyer-seller agreement. In addition, programmatic exchange details are disclosed, but these details may be disclosed in real-time at the time of transaction.

Data

• Conversant has contractual agreements with our publishers in which consent is explicitly given to aggregate behavioral data for the purposes of using this information for behavioral or interest-based targeting. What information is collected and how it is used is outlined in Conversant’s General Publisher Agreement. Conversant may use User Data so long as such use is in compliance with all applicable privacy policies, laws, rules, regulations and industry self-regulatory regimes.
• Conversant has a great deal of data from our internal business operations, however we may also buy data from Third-Party Data providers for targeting purposes. Any client that requests to have details on what data is being utilized on a given campaign or requests specific data be used on a given campaign can request that prior to the campaign launch. These instructions must be included in the IO.

Programmatic Buying/Auction Mechanics

Conversant adheres to standard ORTB standards in what is provided in the bid request and bid response.

• Seller has the ability to pass attributes to Conversant in the bid request, providing the buyer transparency that can be used in the decisioning of the bid
• Buyer has the ability to pass parameters specific to the details of the campaign and creative in the bid response for the seller to decide if they are going to accept the buyer’s bid.
• Both the buyer and seller have the option to no bid on any request and walk away from the transaction.

Conversant passes the following attributes in the bid request as outlined in the OpenRTB Specification when they are provided by the seller. Note: Additional attributes may be passed based on agreements.

Bid Request

Object: Bid Request

The top-level bid request object contains a globally unique bid request or auction ID. This id attribute is required as is at least one impression object. Other attributes in this top-level object establish rules and restrictions that apply to all impressions being offered.

Attribute (Type): Description

• Site (object): Details via a site object about the publisher’s website. Only applicable for websites
• App (object): Details via an app object about the publisher’s app (i.e., non-browser applications). Only applicable for apps
• Device (object): Details via a device object about the user’s device to which the impression will be delivered
• User (object): Details via a user object about the human user of the device; the advertising audience
• Bcat (string array): Blocked advertiser categories using the IAB content categories. Refer to List 5.1
• Badv (string array): Block list of advertisers by their domains (e.g., “ford.com”)

Note: A bid request cannot contain both a Site and an App object (refer to the Site and App objects below).

Object: Site

This object should be included if the ad supported content is a website as opposed to a non-browser application.

Attribute (Type): Description

• Id (string): Exchange-specific site ID
• Name (string): Site name (may be aliased at the publisher’s request)
• Domain (string): Domain of the site (e.g., “mysite.foo.com”)
• Cat (string array): Array of IAB content categories of the site
• Page (string): URL of the page where the impression will be shown

Object: App

This object should be included if the ad supported content is a non-browser application (typically in mobile) as opposed to a website.

Attribute (Type): Description

• Id (string): Exchange-specific site ID
• Name (string): App name (may be aliased at the publisher’s request)
• Domain (string): Domain of the app (e.g., “mysite.foo.com”)
• Storeurl (string): App store URL for an installed app
• Cat (string array): Array of IAB content categories of the site

Object: Device

This object provides information pertaining to the device through which the user is interacting. Device information includes its hardware, platform, location, and carrier data. The device can refer to a mobile handset, a desktop computer, set top box, or other digital device.

Attribute (Type): Description

• Ua (string): Browser user-agent string
• IP (string): IPv4 address closest to device (IP address of the user)
• Devicetype (integer): The general type of device

Object: Banner

The presence of a Banner as a subordinate of the Imp object indicates that this impression is offered as a banner type impression.

Attribute (Type): Description

• btype (integer array): Blocked banner ad types
• battr (integer array): Blocked creative attributes

Object: Video

The presence of a Video as a subordinate of the Imp object indicates that this impression is offered as a video type impression.

Attribute (Type): Description

• battr (integer array): Blocked creative attributes

Bid Response

A SeatBid object contains one or more Bid objects, each of which relates to a specific impression in the bid request via the impid attribute and constitutes an offer to buy that impression for a given price. The following attributes are related to the creative evaluation and applicable in a programmatic environment.

Conversant uses the following attributes in the bid response as outlined in the OpenRTB Specification when they are provided by the buyer.

Object: Bid

The bid response consists of the top-level bid response object and optional objects that depict the specific bids. An empty HTTP response constitutes a no-bid and is in fact the most bandwidth friendly form of this signal. A malformed response or a response that contains no actual bids will also be interpreted as no-bid.

Attribute (Type): Description

• adomain (string array): Advertiser domain for block list checking (e.g., “ford.com”)
  • This can be an array of for the case of rotating creatives, exchanges can mandate that only one domain is allowed

Compliance

To maintain Conversant’s self-certification through compliance with the TAG Guidelines, a quarterly internal audit is coordinated by Conversant’s “compliance officer.” The compliance officer is a manager (or above) who is in an objective role, outside the influence of sales. Internal audits ensure that:

• The guidelines are consistently and completely followed
• That error situations are detected in a timely fashion
• That appropriate corrective measures are taken in a timely fashion
• Internal audits also include a risk analysis of certain control functions to assess how much testing should be conducted to validate adherence
• Internal audits include actual testing of data (sites/pages/ads/logs), both statistically and judgmentally based, to validate that the existing control structure is effective

On an annual basis, both the Compliance Officer and the Conversant Executive overseeing this program, file an affidavit with the TAG attesting to the following:

1. That quarterly internal audits have been conducted.
2. Acquiring Inventory: Accurately label inventory in accordance with established content framework along 3 criteria:
   1. Transaction Party Source Identification and Relationships
   2. Source Level Transparency
   3. Technical Context
3. Contextual Classification & Targeting: accurately categorize content in accordance with Tiers 1 & 2 of IAB Tech Lab Content Taxonomy, and specify the depth (e.g. site level vs. page level) of categorization. If Conversant elects to use a different taxonomy, a mapping of this taxonomy to the IAB Tech Lab Content Taxonomy will be communicated to a buyer.
4. Inventory Vetting: Accurately label content in accordance with established guidelines in and exclude illegal content from sale.
5. Data Disclosure: Accurately disclosed to publisher partners who are contributing data and to advertisers when using third party data.
6. Where applicable, complying with the Programmatic Buying/Auction Mechanics and Audience Targeting.

If you have any concerns regarding compliance, please send an email to Conversant’s Compliance Officer at tagcompliance@conversantmedia.com.

Exhibit A

Content Rating System

The following are definitions of the rating categories:

All Audiences

Appropriate for all segments of the general public. For this rating, all of the following must apply:

• No profanity
• No sexual content
• No violence
• No depictions of alcohol, tobacco, weapons, gambling, or drug use

Everyone over 12

May contain material considered inappropriate for young children. Any of the following may be present:

• Implicit references to vulgar language
• Kissing
• Violence to animated characters
• Journalistic references to alcohol, tobacco, weapons, gambling, or drug use

Mature Audiences

May contain material suitable only for mature audiences. Any of the following may be present:

• Profanity
• Provocative images
• Nudity
• Violence to human beings or animals
• Depictions of alcohol, tobacco, weapons, gambling or drug use, etc.

Exhibit B

Illegal Content Prohibited from Sale

• Illegal Content - Content related to engaging in, promoting or facilitating illegal or legally questionable activities such as drugs, bombs, theft, and online pirating, hacking, spamming, and infecting as governed by United States Federal law.
• Warez - P2P, torrent sites, illegal music downloads, pirated software.
• Spyware/Malware - Distribute or promote spyware or malware.
• Copyright Infringement - Infringes on copyrights (for example by hosting and streaming infringing copyrighted content).

Exhibit C

Non-Standard Definitions

• Extreme Graphic/ Explicit Violence - The depiction of especially vivid, brutal and realistic acts of violence. It may be real, simulated live action, or animated. Graphic and/or Explicit Violence goes beyond lesser forms of violence due to its clear and unabashed nature of the violence portrayed.
• Pornography - Sexually explicit material whose primary purpose is designed to produce sexual arousal. Types of content can include, but is not limited to, representations of sexual acts and exposed body parts, sexual coercion, and illegal sexual acts.
• Profane Content - Excessive or inappropriate use of profane language.
• Hate Content - Speech or hate graphic content.
• Under Construction - Sites that are under construction.
• Incentivized - Sponsor "incentivized clicks," or “pay-to-surf" programs.
• Unmoderated UGC - UGC sites that do not have a clear set of posted guidelines on what type of content is acceptable and do not take an active position in reviewing content for compliance with posted guidelines. For the purposes of these guidelines, User Generated Content (UGC) is defined as forums as well as the uploading by users of video, audio or photographic content that is either user-created or created by a third-party.

Exhibit D

Creative Specifications

The following creative specifications are disclosed prior to the start of the campaign (which are taken from the OpenRTB Specification):

• Audio Ad (Auto-Play)
• Audio Ad (User Initiated)
• Expandable (Automatic)
• Expandable (User Initiated - Click)
• Expandable (User Initiated - Rollover)
• In-Banner Video Ad (Auto-Play)
• In-Banner Video Ad (User Initiated)
• Pop (e.g., Over, Under, or Upon Exit)
• Provocative or Suggestive Imagery
• Shaky, Flashing, Flickering, Extreme Animation, Smileys
• Surveys
• Text Only
• User Interactive (e.g., Embedded Games)
• Windows Dialog or Alert Style
• Has Audio On/Off Button
• Ad Can be Skipped (e.g., Skip Button on Pre-Roll Video)

Last Reviewed/Updated: December 2018