DataProcessingAddendum.

1. Introduction and Scope

This Data Processing Addendum ("DPA") forms part of the agreement between Trillboards, Inc. ("Trillboards", "we", "us") and you ("Earner", "Screen Owner", "you") governing the processing of personal data in connection with audience sensing and advertising services provided through the Trillboards platform.

This DPA applies to all data processed by Trillboards display devices, including tablets, smart TVs, and connected screens enrolled in the Trillboards network.

2. Definitions

• "Audience Data" means anonymous, aggregated statistical data derived from on-device sensing, including face count, attention duration, dwell time, and demographic estimates.
• "On-Device Processing" means computation performed locally on the display device using embedded AI models, where raw sensor data (images, audio) never leaves the device.
• "Aggregated Data" means statistical summaries that cannot identify any individual person.
• "Advertising Partners" means demand-side platforms, ad exchanges, and direct advertisers that purchase advertising inventory through the Trillboards platform.

3. Data Collection and On-Device Processing

Trillboards display devices use on-device AI to collect anonymous audience metrics. The following principles govern all data collection:

• Camera-based detection counts faces, estimates attention, and measures dwell time. No images or video frames are stored, transmitted, or made accessible to any party.
• Audio analysis measures ambient noise levels and environment classification. No audio recordings are captured, stored, or transmitted.
• Demographic estimation (age range, gender distribution) is performed entirely on-device using local AI models. Raw biometric data never leaves the device.
• Only anonymous, aggregated statistical summaries are transmitted to Trillboards servers.

4. Purpose Limitation

Audience Data collected through the platform is used exclusively for:

• Measuring advertising campaign effectiveness (impressions, attention, engagement)
• Optimizing ad delivery timing and content relevance
• Generating anonymized performance reports for advertising partners
• Improving the Trillboards platform and screen owner revenue

Trillboards does not use Audience Data for individual tracking, surveillance, facial recognition, or identification of any person.

5. Data Sharing with Advertising Partners

We share the following categories of data with advertising partners:

• Aggregated impression counts (number of viewers, not individual identities)
• Average attention duration and engagement scores
• Anonymized demographic distributions (e.g., "60% estimated age 25-34")
• Screen performance metrics (uptime, content delivery success rates)

All shared data is aggregated and anonymized. No individual-level data, images, audio, or personally identifiable information is shared with any advertising partner.

6. Data Retention

Aggregated Audience Data is retained for up to 400 days for analytics and reporting purposes. On-device sensor data (raw frames, audio samples) is processed in real-time and immediately discarded — it is never written to disk or transmitted. You may request deletion of your account and associated aggregated data by contacting privacy@trillboards.com.

7. Security Measures

Trillboards implements the following technical and organizational measures to protect data:

• All data in transit is encrypted using TLS 1.2 or higher
• All data at rest is encrypted using AES-256
• On-device processing uses sandboxed AI models with no network access to raw data
• Access to aggregated data is controlled through role-based authentication
• Regular security audits and penetration testing
• Employee access is restricted on a need-to-know basis

8. Your Rights

As a screen owner, you have the following rights regarding data processing on your devices:

• Right to disable audience sensing entirely through the Trillboards portal (revenue may be affected)
• Right to request a copy of aggregated data associated with your screens
• Right to request deletion of all data associated with your account
• Right to withdraw consent for data processing at any time

To exercise any of these rights, contact privacy@trillboards.com or use the controls in your Trillboards portal dashboard.

9. GDPR and CCPA Compliance

Trillboards is designed to comply with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Because Audience Data is anonymous and aggregated, it generally does not constitute "personal data" under GDPR or "personal information" under CCPA. However, we apply the protections of these regulations as a matter of best practice.

10. Changes to This DPA

We may update this DPA from time to time. Material changes will be communicated via email to registered screen owners and posted on this page. Your continued use of the platform after changes constitutes acceptance of the updated DPA.

11. Contact

For questions about this Data Processing Addendum or our data practices, contact us:

Data Protection Officer: For privacy and data processing inquiries, contact our DPO at privacy@trillboards.com