Advertising & Analytics Policy

AQNOVA MARKETPLACE

Global Legal Footer Framework

Comprehensive Compliance & Platform Governance Reference

(MASTER)

How AqNova Uses Analytics & Advertising Technologies — Your Rights & Controls

Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation

This Advertising & Analytics Policy ("Policy") sets out AqNova's complete disclosure regarding: (a) the analytics tools and technologies AqNova deploys to understand Platform performance and user behavior; (b) the advertising measurement technologies AqNova uses to assess the effectiveness of its own marketing campaigns; (c) how interest-based advertising operates and AqNova's participation therein; (d) the industry self-regulatory programs AqNova adheres to; and (e) the rights and controls available to users globally regarding analytics tracking and advertising-related data uses.

This Policy should be read alongside the Cookie Policy (Section 3.2), the Cookie Preference Management document (Section 3.3), and the Privacy Policy (Section 3.1). Together, these documents provide the complete picture of AqNova's data practices in the advertising and analytics space.

3.7.1 AqNova's Advertising Model — What We Do and Do Not Do

Transparency about AqNova's advertising model begins with a clear statement of what kind of advertising business AqNova is — and what it is not. Many users are justifiably skeptical of e-commerce platforms that monetize their data through advertising. AqNova's model is materially different from the dominant advertising-supported platform model.

A. AqNova's Revenue Model — Not Advertising

AqNova's revenue derives from Platform Fees charged to Vendors (transaction commissions, subscription fees, and optional value-added service fees) and not from advertising revenue. This fundamental difference means AqNova does not have a financial incentive to maximize user data collection for advertising resale — our commercial interests are aligned with providing a marketplace that Buyers trust and Vendors want to participate in.

B. Sponsored Listings on AqNova

AqNova may offer Vendors the option to pay for "Sponsored Listing," "Featured Product," or equivalent paid placement visibility enhancements within Platform search results and category pages. These placements are:

Clearly labeled with a "Sponsored," "Featured," or "Promoted" tag wherever they appear, consistent with FTC Endorsement Guide requirements, EU DSA transparency obligations, UK ASA CAP Code requirements, and equivalent global advertising standards.

Based on Vendor payment for placement — not on behavioral profiling of Buyers. A Vendor who pays for a Sponsored Listing will have their products displayed more prominently; Buyers will not see ads targeted at them based on their personal data.

Limited to the AqNova Platform. AqNova does not display Vendor sponsored listings on third-party websites or apps.

Subject to AqNova's listing content standards and the Acceptable Use Policy (Section 2.3). AqNova does not accept payment for sponsored listings of products that would violate Platform policies.

3.7.2 Analytics Technologies — Tools, Data & Purposes

Analytics technologies enable AqNova to measure how the Platform is performing, understand how users navigate and interact with features, and make data-driven decisions about product development and user experience improvements. AqNova deploys analytics at two levels: internal first-party analytics (data stays within AqNova's own systems) and third-party analytics (data is shared with specialist analytics providers subject to DPAs and consent requirements).

A. First-Party Analytics

AqNova operates its own internal analytics infrastructure to capture detailed session-level Platform data. First-party analytics data:

Remains entirely within AqNova's own controlled infrastructure — it is not transmitted to or accessible by third-party analytics providers.

Is processed in pseudonymized form: raw session data is linked to a rotating pseudonymous identifier, not to your account name or email address, except where AqNova's analytics team specifically needs to investigate a reported issue affecting your account.

Is aggregated for analysis: individual session data is consolidated into aggregate datasets (e.g., daily active users, page view counts, conversion funnel step completion rates) within 30 days; raw session data is deleted after 30 days.

Is used for: measuring product feature adoption; identifying technical errors and performance issues; evaluating A/B test results; understanding broad user journey patterns; and making product roadmap prioritization decisions.

Is never used for advertising profiling or for any purpose other than internal Platform improvement.

B. Third-Party Analytics

AqNova uses the following third-party analytics services, each of which is disclosed in full in the Cookie Policy (Section 3.2.4) and is activated only with user consent (Category 3 cookies):

C. Analytics Data Minimization Practices

AqNova applies the following data minimization practices to all analytics processing:

IP address truncation: all IP addresses used for geographic analysis are anonymized by removing the last octet before any analytics processing or storage. Full IP addresses are retained in server access logs for security purposes only (see Data Retention Schedule, Section 3.4).

Cross-site tracking prevention: AqNova does not implement cross-site tracking that follows users across the web. Analytics data is limited to behavior on the AqNova Platform.

Disable demographics and interests reports: AqNova has disabled Google Analytics' demographics and interests reports feature, which would link Platform behavior to Google's advertising profile for the user.

Disable Google Signals: AqNova has disabled Google Signals in GA4, preventing Google from associating AqNova Platform analytics data with users' signed-in Google accounts for advertising purposes.

User-level data retention limits: where analytics tools offer configurable data retention periods, AqNova sets retention at the minimum available that supports its analytical purposes (14 months for GA4; 13 months for first-party analytics identifiers).

A. What Is Interest-Based Advertising?

Interest-based advertising (IBA), also known as online behavioral advertising (OBA), targeted advertising, or cross-context behavioral advertising (CCBA under CPRA), is a form of advertising that uses data about individuals' online behavior — including browsing history, purchase history, search queries, and demographic inferences — to select advertisements that are more likely to be relevant to that individual.

Traditional digital advertising serves the same ad to every user visiting a given webpage. Interest-based advertising, by contrast, uses an individual's behavioral profile to select a different advertisement for each user, based on inferences about their interests, intentions, or characteristics.

B. How IBA Works — The Technical Mechanism

Interest-based advertising typically involves the following chain of data flows:

Data collection: a user browses websites and apps. Tracking technologies (cookies, pixels, device IDs) collect data about pages visited, content viewed, searches made, and items purchased.

Profile building: this behavioral data is consolidated — often by a data management platform (DMP) or within an advertising platform (Meta, Google, etc.) — into an interest profile associated with a pseudonymous identifier.

Audience targeting: advertisers upload audience parameters (e.g., 'users interested in sustainable products') or rely on advertising platforms' interest categories. The platform matches these parameters against its user interest profiles.

Ad serving: when a matched user visits a website or app that displays ads, the advertising platform serves an ad relevant to the matched interest category.

Measurement: conversion pixels or server-side APIs record whether the user who saw the ad subsequently performed an action (e.g., visited the advertiser's site, completed a purchase).

C. AqNova's Limited IBA Participation

AqNova's participation in the interest-based advertising ecosystem is specifically limited to the advertiser role — AqNova acts as an advertiser on third-party platforms (Meta, Google, TikTok, Pinterest) to promote its own marketplace. AqNova does not participate in the IBA ecosystem as a data supplier (selling audience data to ad networks) or as a publisher (displaying third-party targeted ads to its users).

D. Custom Audiences — Hashed Customer Lists

AqNova may upload hashed (SHA-256) email addresses to advertising platforms (Meta, Google, TikTok) to create Custom Audiences for the purpose of serving AqNova ads to existing Platform users on those platforms. The following safeguards apply to this practice:

Only hashed data: email addresses are one-way hashed with SHA-256 before upload. The hashed value cannot be reversed to reveal the original email address.

Purpose limitation: Custom Audiences are created only for the purpose of serving AqNova's own marketing communications to existing users who may be interested in new Platform features, promotions, or product categories aligned with their expressed interests.

Opt-out honored: users who have exercised the Do Not Sell or Share right (CCPA/CPRA), objected to direct marketing (GDPR Art. 21), or withdrawn marketing consent (other jurisdictions) are excluded from Custom Audience uploads.

Data not retained by advertising platforms: advertising platforms that receive Custom Audience data are contractually restricted from using that data for their own purposes and must delete it upon completion of the audience matching process.

Transparency: this practice constitutes the 'sharing' of personal data for cross-context behavioral advertising purposes under CPRA. California residents may opt out via [aqnova.co/privacy/do-not-sell].

E. Retargeting

Retargeting (also called remarketing) is the practice of showing AqNova advertisements to users who have previously visited the AqNova Platform, on third-party platforms and websites. Retargeting works by placing a pixel or cookie (e.g., _fbp for Meta retargeting) on the user's browser when they visit AqNova, and later identifying that browser on third-party sites where the advertising platform can serve an AqNova ad.

AqNova uses retargeting for the following purposes:

Cart abandonment recovery: showing AqNova ads to users who added items to their cart but did not complete the purchase.

Product re-engagement: showing users ads featuring products from categories they previously browsed, to prompt return visits.

Retargeting exclusion: AqNova implements retargeting exclusion lists so that users who have recently made a purchase are excluded from retargeting ads for the purchased product for at least 90 days.

All retargeting is subject to user consent through the Category 4 marketing cookie consent mechanism (Cookie Preference Manager). If you decline Category 4 cookies or submit a Do Not Sell/Share request, you will not be subjected to AqNova retargeting campaigns. The retargeting pixel on your browser will be invalidated immediately upon opt-out.

3.7.4 Third-Party Analytics Tools — Detailed Disclosure

In compliance with transparency obligations under GDPR Articles 13–14, DSA Article 26, CCPA, and equivalent global requirements, AqNova provides the following detailed disclosure of all third-party analytics and measurement tools currently deployed on the Platform. Each tool is identified with its provider, country of data processing, the data it collects, and the applicable opt-out mechanism.

3.7.5 Advertising Measurement & Campaign Analytics

Advertising measurement is the process of determining whether a marketing campaign resulted in user actions — such as visiting the Platform, viewing a product, or completing a purchase. AqNova uses advertising measurement technologies exclusively to assess the return on investment of its own marketing spend. This helps AqNova allocate its marketing budget efficiently and ensures that it reaches users who are genuinely interested in sustainable commerce — rather than wasting spend on irrelevant audiences.

A. Campaign Measurement Technologies

B. Attribution Modeling

Advertising attribution is the process of determining which marketing touchpoint — which ad, platform, or channel — should receive credit for a conversion (e.g., a completed purchase). AqNova uses the following attribution approaches:

Last-click attribution (default): credits the last marketing channel the user interacted with before converting. Simple and transparent but does not reflect the multi-touchpoint nature of most purchase journeys.

Data-driven attribution (Google): where data-driven attribution is available in Google Analytics and Google Ads, AqNova may use it to distribute credit across multiple touchpoints based on their statistical contribution to conversions. This model uses aggregate, anonymized data and does not require individual-level behavioral profiling beyond what the consent framework permits.

First-party data attribution: AqNova's own analytics platform records the marketing source (UTM parameters) from which a user arrived at the Platform for the first time and the last session before converting, enabling first-party attribution that does not depend on third-party cookies.

3.7.6 On-Platform Personalization — Recommendation Engines

AqNova's on-Platform personalization system — which powers product recommendations, search result ranking, homepage content, and sustainability product curation — is fundamentally different from behavioral advertising. It operates exclusively on data generated within the AqNova Platform itself, does not share user profiles with third parties, and is designed to help users discover products aligned with their genuine interests.

A. How Platform Personalization Works

AqNova's recommendation engine considers the following signals to personalize the Platform experience:

Explicit preferences: product categories and sustainability certifications you have indicated an interest in through AqNova's optional preferences questionnaire or through account settings.

Browse and search history within AqNova: products you have viewed, searched for, or added to your wishlist on the AqNova Platform (not across other websites).

Purchase history within AqNova: the categories and brands of products you have previously purchased, which indicate established interests.

Sustainability profile: your expressed sustainability values and the sustainability credentials (certifications, categories) of products you have engaged with.

Aggregated preference signals: anonymous, aggregate signals from users with similar browsing and purchase patterns, used to supplement individual signals and discover potentially relevant products (collaborative filtering).

B. What Personalization Does NOT Use

AqNova's on-Platform personalization engine does NOT use:

Data from third-party websites or apps: AqNova does not receive behavioral data from advertising networks, data brokers, or third-party websites about your activity outside of AqNova.

Sensitive personal characteristics: political views, religion, health conditions, financial status, sexual orientation, or similar sensitive characteristics are not used as personalization signals.

Inferences about protected characteristics: AqNova's recommendation algorithms are designed to avoid making or relying on inferences about race, ethnicity, gender, age, or other protected characteristics.

Real-time bidding data: AqNova does not participate in advertising exchanges, meaning no external behavioral data is injected into the personalization system.

C. Opting Out of Personalization

Users may opt out of AqNova's on-Platform personalization at any time through Account > Privacy Settings > Personalization Preferences > Disable Personalized Recommendations. When personalization is disabled, you will see AqNova's default search results ranking (based on relevance, recency, Vendor rating, and Platform policy compliance metrics) and generic, non-personalized homepage content. Your ability to browse, search, and purchase is in no way affected by disabling personalization.

3.7.7 Industry Self-Regulatory Programs — DAA, NAI & IAB TCF

AqNova participates in or adheres to the principles of the following industry self-regulatory programs for online advertising and data-driven marketing:

A. Digital Advertising Alliance (DAA) — AdChoices Program

The Digital Advertising Alliance (DAA) is a coalition of advertising industry associations that administers the AdChoices self-regulatory program for online behavioral advertising in the United States. The AdChoices program provides consumers with enhanced transparency and choice regarding interest-based advertising through the AdChoices icon — a small "i" icon or the AdChoices logo displayed on interest-based ads — that links to an opt-out mechanism.

AqNova's DAA participation: AqNova adheres to the DAA's Self-Regulatory Principles for Online Behavioral Advertising. Where AqNova's advertising appears on third-party websites through advertising platforms (e.g., Google Display Network, Meta Audience Network), those platforms' AdChoices implementations govern. AqNova's own Platform does not display third-party interest-based advertising, so the AdChoices icon is not displayed directly on AqNova's Platform pages. However, AqNova's use of advertising measurement technologies complies with DAA's data collection transparency principles.

DAA Opt-Out Tool: US consumers may opt out of interest-based advertising from DAA member companies at: optout.aboutads.info. This opt-out applies to DAA member advertising networks and does not prevent AqNova from running its own marketing campaigns, but will suppress interest-based ad targeting where the relevant third-party advertising platform is a DAA member.

DAA AppChoices: For mobile app interest-based advertising opt-out: youradchoices.com/appchoices.

B. Network Advertising Initiative (NAI)

The Network Advertising Initiative (NAI) is an industry self-regulatory organization that establishes and enforces standards for interest-based advertising among member ad networks and data companies. The NAI's Code of Conduct sets requirements for member organizations regarding data collection, use, and user choice.

NAI Opt-Out Tool: US consumers may opt out of interest-based advertising from NAI member companies at: optout.networkadvertising.org. As with the DAA opt-out, this applies to NAI member networks.

AqNova's advertising measurement partners (Google, Meta, TikTok, Pinterest) are members of or participate in standards developed by the NAI and DAA. Their respective compliance with these standards is governed by their own privacy policies and self-regulatory commitments.

C. Interactive Advertising Bureau (IAB) Transparency and Consent Framework (TCF) v2.2

The IAB Europe Transparency and Consent Framework (TCF) is the standard consent and transparency framework used by publishers, advertisers, and technology providers in the EU and UK to communicate user consent signals in a standardized machine-readable format. TCF v2.2 supports the GDPR and ePrivacy Directive consent requirements for advertising and analytics technologies.

AqNova's Cookie Consent Manager is built on a TCF v2.2 compatible Consent Management Platform (CMP). This means that consent signals generated by AqNova's Cookie Consent Manager are propagated to all integrated advertising and analytics vendors in a format they can technically parse and honor — including Google (for Consent Mode v2) and Meta (for Consent Mode). AqNova's CMP is registered with the IAB Europe TCF.

TCF Global Vendor List: The IAB maintains a Global Vendor List of all technology vendors that have registered with the TCF framework and committed to honoring consent signals. All advertising and analytics vendors integrated into AqNova's Platform that are listed on the Global Vendor List will receive and honor the consent signals generated by AqNova's CMP.

D. Australia — OAIC Online Behavioral Advertising Guidelines

The Australian Office of the Australian Information Commissioner (OAIC) has published guidelines on the collection and use of personal information in online behavioral advertising. These guidelines, developed under the Australian Privacy Principles, set out best practices for Australian operators including: clear disclosure of OBA practices; provision of easy opt-out mechanisms; and prohibition on using sensitive information for OBA targeting. AqNova's advertising practices comply with OAIC's OBA guidelines for Australian users.

E. Japan — JIAA Online Behavioral Advertising Guidelines

The Japan Interactive Advertising Association (JIAA) administers an opt-out mechanism and code of conduct for online behavioral advertising in Japan, consistent with the APPI. JIAA member companies commit to providing clear disclosure of OBA practices and an accessible opt-out mechanism. AqNova's advertising measurement practices align with JIAA guidelines for Japan-based users. Japan-based users may access the JIAA opt-out tool at: optout.jiaa.org.

F. Canada — AdChoices Canada

The Digital Advertising Alliance of Canada (DAAC) administers the AdChoices program in Canada, providing Canadian consumers with transparency and opt-out rights regarding online behavioral advertising. Canadian users may access the AdChoices Canada opt-out at: youradchoices.ca/choices. AqNova's advertising practices comply with DAAC's Canadian Self-Regulatory Principles.

3.7.8 Children & Advertising — Special Protections

AqNova implements stringent protections regarding advertising directed at or involving children, consistent with its general commitment to children's privacy (addressed in Privacy Policy Section 3.1.12) and the requirements of applicable law worldwide.

A. Sponsored Listings & Children's Products

Vendors who offer products primarily designed for children (toys, children's clothing, children's educational products) may purchase Sponsored Listings on AqNova. However, the following restrictions apply:

Sponsored Listings for children's products must not contain language, imagery, or techniques specifically designed to appeal to children in a manner that bypasses parental decision-making.

Sponsored Listings for children's products must include all required safety disclosures (age appropriateness, hazard warnings, regulatory certifications such as ASTM F963, EN 71, or equivalent).

AqNova does not target Sponsored Listings to specific users based on inferred parental status or household composition.

A. Disclosure Obligations — Legal Framework

Where AqNova engages influencers, content creators, or brand ambassadors to promote AqNova or AqNova Vendor products through social media, blogs, video content, or other channels, all such content must comply with applicable advertising disclosure requirements, including:

United States (FTC Endorsement Guides, 16 C.F.R. Part 255): any material connection between AqNova (or a Vendor) and an endorser (influencer) must be clearly and conspicuously disclosed in proximity to the endorsement, in language understandable to the audience (e.g., '#ad,' '#sponsored,' 'Paid partnership with AqNova,' 'I received this product for free.'). The FTC's 2023 revised Endorsement Guides impose civil penalties up to USD $51,744 per violation for deceptive endorsements.

United Kingdom (ASA CAP Code Rule 2.3 / BCAP Code Rule 3.2): marketing communications must be obviously identifiable as such. Influencer posts must use clear labels such as '#Ad' before any other content. 'Gifted,' 'Collab,' or 'Affiliate' alone may be insufficient; the relationship must be explicitly identified as a commercial arrangement.

European Union (UCPD 2005/29/EC; DSA Art. 26): using editorial content to promote products without making the commercial nature clear is an unfair commercial practice. DSA Article 26(2) requires that advertising shown on platforms be clearly identifiable and disclose the basis for targeting.

Australia (ACCC Influencer Marketing Guidelines; ASA Code): commercial arrangements with influencers must be disclosed. The ACCC has taken enforcement action against undisclosed influencer promotions.

Canada (Competition Act s. 74.01; ASC Guidelines on Testimonials and Endorsements): material connections between endorsers and brands must be disclosed. The Competition Bureau has published guidance on influencer marketing transparency.

India (ASCI Guidelines for Influencer Advertising in Digital Media, 2021): influencers must disclose material connections using labels such as '#Ad,' '#Collab,' '#Promotion,' '#Sponsored.' Disclosure must be in the language of the content.

B. AqNova's Influencer Policy

AqNova requires all influencers, content creators, and brand ambassadors engaged by AqNova or through AqNova's Vendor partner programs to:

Include clear, prominent disclosure of the commercial relationship in all content promoting AqNova or AqNova-platform Vendor products, using platform-appropriate and locally compliant disclosure language.

Disclose the nature of the relationship: paid partnership, gifted product, affiliate commission relationship, or other material connection.

Not make false or misleading claims about AqNova's products, services, or sustainability credentials that AqNova itself cannot substantiate.

Comply with FTC, ASA, UCPD, ACCC, ASCI, and all applicable advertising standards in the territories where their content is distributed.

Not target content primarily to children without implementing age-appropriate disclosure and content measures.

C. Sponsored Listings — On-Platform Transparency

As noted in Section 3.7.1, AqNova may offer Vendors paid Sponsored Listing placements within Platform search results and category pages. These placements are clearly labeled with a "Sponsored," "Featured," or "Promoted" badge in every instance where they appear. AqNova's sponsored listing labels comply with:

FTC guidance on native advertising (2015): sponsored listings are clearly distinguished from organic search results.

EU DSA Article 26(1): the commercial nature of promoted listings is identifiable by the consumer.

UK ASA CAP Code: promotional content is identifiable as such.

Google's definition of advertorial/native content transparency standards (applicable to AqNova's in-feed product placements).

3.7.10 Opt-Out Rights & Mechanisms — Global Framework

AqNova provides users with a comprehensive set of opt-out and control mechanisms covering analytics tracking, advertising measurement, retargeting, and on-Platform personalization. The following table provides a complete reference to available opt-out mechanisms by type and jurisdiction:

3.7.11 Regulatory Compliance Matrix — Advertising & Analytics by Jurisdiction

The following matrix sets out the key regulatory requirements applicable to AqNova's advertising and analytics activities in each principal jurisdiction and AqNova's compliance approach:

3.7.12 Vendor Advertising Obligations on the Platform

Vendors who participate on the AqNova Platform — whether through organic listings, Sponsored Listings, or promotional features — are bound by AqNova's advertising standards as set out in the Vendor Agreement (Section 2.2) and the Acceptable Use Policy (Section 2.3). The following advertising-specific obligations apply to all Vendors:

A. Advertising Content Standards

All Vendor product listings and promotional materials must be truthful, accurate, and not misleading in any material respect, consistent with applicable advertising law in all jurisdictions where the product is offered.

Vendors may not make health, efficacy, safety, or performance claims about their products that cannot be substantiated by competent and reliable scientific evidence, consistent with FTC, EU, UK, and equivalent advertising standards.

Sustainability and environmental claims ("eco-friendly," "carbon neutral," "organic," "sustainable") must be substantiated per the requirements of Section 2.2.2.C of the Vendor Agreement and applicable green marketing regulations.

Comparative advertising (claiming superiority over competitor products) must be truthful, verifiable, and not misleading, consistent with EU Comparative Advertising Directive 2006/114/EC, FTC Act, UK CAP Code, and equivalent national standards.

Pricing representations ("original price," "sale price," "X% off") must be accurate and comply with applicable pricing regulation, including EU Omnibus Directive requirements for price history disclosure, UK pricing law, CPRA and FTC pricing guidance.

B. Sponsored Listing Content Requirements

Vendors purchasing Sponsored Listing placements on AqNova must ensure that their sponsored content:

Accurately represents the product being promoted — the Sponsored Listing content must be consistent with the full product listing page.

Does not use false urgency tactics ("Only 1 left!" when stock is plentiful; "Limited time offer!" for offers that run indefinitely) in the Sponsored Listing copy.

Complies with applicable country-specific advertising content restrictions (e.g., alcohol advertising restrictions where applicable; health product claim restrictions; financial product advertising regulations).

Does not target advertising at children through Sponsored Listing parameters or promotional copy designed to appeal primarily to minors.

C. Vendor Use of AqNova Data for Advertising

Vendors are strictly prohibited from using buyer data received through the Platform (pursuant to order fulfillment) for any advertising or marketing purpose, including retargeting buyers through external advertising platforms based on their AqNova purchase behavior. This prohibition is set out in the Vendor Agreement (Section 2.2.3) and constitutes a material breach if violated.

A. Policy Review Cycle

AqNova reviews this Advertising & Analytics Policy at least annually and updates it whenever: a new analytics tool or advertising measurement technology is added to the Platform; a material change occurs in applicable advertising law or self-regulatory standards; a new self-regulatory program membership or certification is obtained; or AqNova's advertising practices change in a material way. Updates are communicated through the Policy Change Log at [aqnova.co/privacy/changelog] and, for material changes, through user notifications consistent with the Privacy Policy amendment procedure.

AqNova Marketplace | Global Legal Footer Framework | Section 3.7: Advertising & Analytics Policy

© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.