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Howl U.S. State Privacy Notice

Effective as of November 3, 2026.

1. Overview

This U.S. State Privacy Notice (this “Notice”) explains how Connexity, Inc., doing business as Howl (“Howl”, “we”, “us” or “our”), collects, uses and discloses Personal Information about residents of U.S. states with consumer privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), and other U.S. state privacy laws to the extent they apply (together, “U.S. State Privacy Laws”). It also explains the rights you may have under those laws and how to exercise them.

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This Notice supplements the Howl Privacy Policy at https://www.howl.link/privacy and applies to the Howl platform, website, mobile applications and browser extension (the “Services”). Capitalized terms not defined here have the meanings given in the Privacy Policy. It also covers creators who have not yet joined Howl (“Prospective Partners”) about whom we collect information from data providers and public sources. “Personal Information” means information that identifies, relates to, or could reasonably be linked with you or your household, as defined by the applicable U.S. State Privacy Law.

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This Notice does not cover information we process on behalf of Merchants, or information about Connexity job applicants, employees or contractors. Rights and definitions differ from state to state, and some rights may not apply to you depending on where you live and how you use the Services.

2. Personal Information we collect (notice at collection)
We may use your personal information for the following purposes or as otherwise described at the time of collection:
‍Services delivery and operations. We may use your personal information to: provide and operate the Services and our business; personalize the Services, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Services; establish and maintain your user profile on the Services; verify Partners’ profiles on social media; verify your identity and your eligibility to receive payments; pay you and meet our tax reporting and withholding obligations; facilitate your invitations to friends who you want to invite to join the Services; communicate with you about the Services, including by sending Services-related announcements, updates, security alerts, and support and administrative messages; communicate with you about events or contests in which you participate; understand your needs and interests, and personalize your experience with the Services and our communications; and provide support for the Services, and respond to your requests, questions and feedback.
‍Creator insights and matching. We may use your personal information, including your performance on the Platform, Channel Data, Profile Data, Social Profile Data and Publicly Available Data, to create profiles, scores, rankings, recommendations and other insights about Partners and their Channels, and to match Partners with Merchants, Campaigns and other opportunities on the Platform. We may share these insights with Merchants for that purpose.
‍Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
‍Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
‍Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
‍Events, promotions and contests. We may use your personal information to: administer promotions and contests; communicate with you about promotions or contests in which you participate; and contact or market to you after collecting your personal information at an event.
‍Services improvement and analytics. We may use your personal information to analyze your usage of the Services, improve the Services, improve the rest of our business, help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services.
‍Compliance and protection. We may use your personal information to: comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Services; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
‍Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
‍Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
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Category
Examples
Sources
Disclosed for a business purpose to
Sold or shared?
Retention
Identifiers
Name, email address, postal address, account username, IP address, device and advertising identifiers, taxpayer identification number
You; your devices; our service providers
Service providers; affiliates; payment service providers; Merchants (profile name and image only)
No
Account identifiers (name, email address, postal address, username and taxpayer identification number): life of account plus 7 years after final payment. IP address, device and advertising identifiers: up to three years from collection.
Customer records (Cal. Civ. Code § 1798.80(e))
Name, address, telephone number, bank account details, tax information
You
Payment service providers; service providers
No
Life of account plus 7 years after final payment.
Commercial information
Campaigns you join, sales attributed to your Partner Links, Commissions earned and paid, payment history
You; Merchants; our affiliates (including Skimlinks) and the affiliate networks they work with; our Platform
Service providers; Merchants (Campaign performance); payment service providers
No
Commission and payment history: 7 years after the year of the transaction. Executed Campaign agreements: 10 years after they expire.
Internet or other electronic network activity
How you use the Services, pages viewed, clicks on Partner Links, interactions with our emails
Your devices; our service providers
Service providers
No
Up to three years from collection, then deleted or de-identified.
Social media and professional profile information
Channel names, social media handles, website URLs, follower counts, engagement data, aggregate audience insights (such as audience demographics and location distribution), verification status
You; social media platforms, including through our social account connection service provider; data providers and publicly available sources
Service providers; Merchants
No
Life of account plus up to three years. Information about Prospective Partners: up to three years from collection unless they join Howl.
Audio, visual or similar information
Profile photo, content you post or share through the Services
You; social media platforms
Service providers; Merchants
No
Life of account, then deleted within three years after the account closes.
Geolocation data
General location derived from your IP address when you log in or click Partner Links
Your devices
Service providers
No
Up to three years from collection.
Inferences
Creator-level profiles, scores and recommendations derived from your activity on the Platform, your Channels and publicly available information
Derived from the information above
Service providers; Merchants
No
Life of account, then deleted within three years after the account closes.
Sensitive Personal Information
Social security number or other taxpayer identification number; account log-in credentials
You; your devices
Payment service providers; service providers
No
Taxpayer identification number: life of account plus 7 years after final payment. Account log-in credentials: life of account.
3. How we use Personal Information

We collect and use Personal Information for the following business and commercial purposes:

  • Providing and operating the Services, including creating and maintaining your account, matching you with Campaigns, and tracking sales and Commissions.
  • Verifying your identity, your social media accounts and your eligibility for Campaigns and payments.
  • Paying you, and meeting our tax reporting, withholding and record-keeping obligations.
  • Communicating with you about the Services, your account and Campaigns, and sending marketing where permitted.
  • Detecting security incidents and protecting against fraudulent, malicious or illegal activity, including Commission fraud.
  • Debugging and fixing errors, quality control, and maintaining the security of the Services.
  • Analytics, internal research, and developing and improving our products and services.
  • Creating profiles, recommendations and other insights about creators and their Channels to match them with Merchants, Campaigns and other opportunities, and identifying and contacting prospective creators.
  • Complying with law, legal process and our contractual obligations, and establishing, exercising or defending legal claims.
  • Carrying out a merger, acquisition, financing or other corporate transaction.
4. Sensitive Personal Information
We use Sensitive Personal Information only to provide the Services you request, to pay you and meet our tax obligations, to verify your identity, to keep your account secure, and for other purposes permitted under Cal. Civ. Code § 1798.121 and its regulations. We do not use or disclose Sensitive Personal Information to infer characteristics about you. Because of this, we do not offer a right to limit the use of Sensitive Personal Information.
5. How we disclose Personal Information

We disclose Personal Information for business purposes to the following categories of recipients:

  • Service providers that process Personal Information on our behalf, such as hosting, data storage, analytics, customer support, email delivery, identity and account management, and our social account connection service provider.
  • Payment service providers, such as Modern Treasury and its banking partners, which receive your bank account and tax information to pay you on our behalf.
  • Merchants, which receive information about your profile, Channels, Campaign performance and creator insights so they can work with you. We do not share your bank account or tax information with Merchants.
  • Affiliates, including Taboola.com Ltd. and its subsidiaries.
  • Government authorities and other parties where required by law or legal process, or to protect our rights, our users or the public.
  • Parties to a corporate transaction, such as an acquirer or successor, in connection with a merger, acquisition, financing or sale of assets.
6. Sale and sharing of Personal Information
We do not sell your Personal Information or share it for cross-context behavioral advertising, and we have not done so in the last 12 months.

The Services are not intended for anyone under 18, and we do not knowingly sell or share the Personal Information of consumers under 16.
7. Your rights

Depending on where you live, you may have the right to:

  • Know and access the categories and specific pieces of Personal Information we have collected about you, the categories of sources, our purposes, and the categories of third parties we disclose it to.
  • Delete Personal Information we have collected from you, subject to exceptions, for example where we must keep tax records.
  • Correct inaccurate Personal Information.
  • Data portability, meaning a copy of your Personal Information in a portable format.
  • Non-discrimination. We will not discriminate against you for exercising any of these rights.
8. How to exercise your rights
Submitting a request. Email termsofuse@howl.link with the subject line “U.S. Privacy Request” and tell us which right you want to exercise.
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Verification. We will verify your identity before responding. If you have an account, we may ask you to confirm your request through your account. Otherwise, we may ask for information that matches what we hold about you. We use information you provide for verification only for that purpose.

Authorized agents. You may use an authorized agent to submit a request. We may require the agent to provide your signed permission and may ask you to verify your identity directly with us.

Timing. We will confirm receipt of your request within 10 business days and respond within 45 days. If we need more time, we will tell you why and may take up to 45 more days.

Appeals. If we decline your request, you may appeal by replying to our decision or emailing termsofuse@howl.link with the subject line “Privacy Request Appeal”. We will respond to your appeal within the time required by your state’s law. If we deny your appeal, you may contact your state attorney general.Fees. We do not charge a fee to respond to your request unless it is manifestly unfounded, excessive or repetitive.
9. Other California privacy rights
California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) lets California residents request information about our disclosure of Personal Information to third parties for their own direct marketing purposes. We do not disclose Personal Information to third parties for their own direct marketing purposes. To make a request, email termsofuse@howl.link.
10. Changes to this Notice
We may update this Notice from time to time. We will post the updated Notice on this page and change the “Last Updated” date above. We review this Notice at least once every 12 months.
11. Contact us
Email: termsofuse@howl.link
Mail: Connexity, Inc. (Howl), Attn: Legal, 520 Broadway #200, Santa Monica, CA 90401, United States
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