Channel Partner Policies

For each active Program Exhibit, Channel Partner must deliver the following metrics at the reporting cadence specified in the Exhibit:

Note: While Channel Partner tracks Offer Activations (click-throughs), the Controlling Measurement System (or Program Sponsor's system of record) governs Confirmed Conversions for billing and attribution purposes.

• Reports must be delivered in the format specified in the applicable Program Exhibit (Excel, CSV, dashboard access, or API feed).
• Each report must include: Program Exhibit number, campaign period start and end dates, Channel Partner name, and the name of the individual certifying the data.
• Estimated data must be clearly labeled. Any metric that cannot be confirmed directly from system records and is instead estimated, modeled, or interpolated must be flagged as estimated. CR will not use unlabeled estimated data as the basis for billing.
• Reports are considered accepted by CR if CR does not issue a written dispute or clarification request within five (5) business days of receipt.
• Failure to deliver a required report within three (3) business days of the designated reporting date is a reporting failure subject to the Incident Response Protocol in Section 2.

CR reconciles Channel Partner delivery data (top-funnel) against Program Sponsor Conversion data and the designated Controlling Measurement System to produce a definitive Reconciled Campaign Report for each billing period. CR acknowledges that material variances between top-funnel delivery metrics (such as Offer Activations) and bottom-funnel Conversion data are common and expected due to differences in measurement methodologies, attribution windows, audience leakage, and natural funnel dynamics.

Where only one data source is available for a given billing period (including situations where the Controlling Measurement System is directly linked to the Program Sponsor's conversion system), CR shall produce the Reconciled Campaign Report using that source as the single source of truth, document the absence of additional sources, and apply the measurement hierarchy in Section 3.2. Single-source periods are subject to the same reconciliation and dispute processes as multi-source periods.

CR shall document the data sources and weighting methodology applied in each Reconciled Campaign Report and shall apply all reconciliation methodologies consistently and in good faith.

Upon Channel Partner's discovery of a reporting failure — or upon receipt of written notice from CR — Channel Partner must, within one (1) business day:

• Provide CR with written notice at reporting@collectivereachadvisors.com identifying: the incident, estimated onset time, known or suspected cause, scope of impacted campaigns and Channels, and a preliminary estimate of affected records;
• Designate a named technical point of contact with internal escalation authority; and
• Confirm whether the failure is ongoing or resolved.

Within seventy-two (72) hours of the Level 1 notice, Channel Partner must:

• Formally isolate the impacted data set — identifying the specific date range, campaign line items, and Channel segments affected — and flag these records as "Under Review" in all reporting delivered to CR;
• Confirm in writing that all uncontested data continues to be reported on its normal schedule without interruption; and
• Deliver to CR a written Remediation Plan including: (a) preliminary root cause analysis; (b) estimated resolution timeline; and (c) the specific audit methodology Channel Partner will employ to identify impacted customers and transactions.

CR will review and respond to the Remediation Plan within two (2) business days. Approval will not be unreasonably withheld. During Level 2, CR continues to reconcile and bill all uncontested data on its normal schedule.

If the reporting failure cannot be resolved through system correction at Level 2, Channel Partner must conduct a Level 3 Enhanced Audit, which must include:

• A comprehensive review of all available proxy data sources, including: server-side logs, email deployment records, click logs, landing page analytics, loyalty platform transaction records, tag manager logs, and any available partner-side or Third-Party Vendor data;
• Cross-referencing of available Channel Partner data against Program Sponsor's Conversion data (as provided through CR) to identify members who can be confirmed as having activated or redeemed the Offer during the impacted period; and
• A written Level 3 Audit Report delivered to CR within thirty (30) calendar days of Level 2 containment, documenting: methodology used, data sources reviewed, number of impacted members identified, confirmed Conversions, and a complete financial reconciliation.

Following completion of the Level 3 Audit:

• Underpayment to CR: If the audit confirms Conversions occurred during the impacted period that were not captured in Channel Partner's reporting, Channel Partner is obligated to pay CR for those confirmed activations.
• Overbilling of Program Sponsor: If the failure resulted in CR billing Program Sponsor for events the audit cannot confirm occurred, Channel Partner must reimburse CR for any amounts CR is required to credit back to Program Sponsor.
• Member remediation: If the failure resulted in members not receiving a promised Offer benefit, Channel Partner bears financial responsibility to the extent such failure is attributable to Channel Partner's tracking, reporting, or delivery systems, for ensuring those members receive the benefit.
• CR's non-liability: In no event shall CR bear financial liability for any billing error, customer harm, or data loss resulting from Channel Partner's tracking or reporting failure, or from the failure of a Third-Party Vendor engaged by Channel Partner.

If Channel Partner fails to deliver the Level 3 Audit Report within thirty (30) days, CR may, in its sole discretion:

• Treat the impacted period as confirmed delivery and bill Program Sponsor based on the 30-day historical average (or pro-rated Program Exhibit commitment for new campaigns), with Channel Partner liable for any resulting disputes or credits;
• Suspend Channel Partner from new Program activations until the audit is completed and accepted by CR; and/or
• Exercise any other remedy available under the Agreement.

The party that contracted with and manages a Third-Party Vendor bears primary responsibility for that vendor's failures. All Level 1/2/3 obligations above apply to Channel Partner regardless of whether the underlying failure originated in Channel Partner's own systems or in a Third-Party Vendor's systems. Channel Partner may not use a vendor's independent legal status or uncooperativeness as a defense against its notification or remediation timeline obligations.

Where a Third-Party Vendor failure simultaneously implicates multiple parties — for example, a privacy investigation arising from a shared tracking pixel — Channel Partner must notify CR within five (5) business days of receiving any related regulatory notice and cooperate in any joint response effort as required under the applicable Channel Partner Agreement.

Before any campaign launches, the party responsible for implementing the primary tracking method must:

• Complete a test conversion or test click through the tracking system and confirm the event is registered in the Controlling Measurement System;
• Confirm the backup tracking method is operational; and
• Provide CR with written confirmation (email acceptable) that both primary and backup systems are live and recording correctly.

CR recognizes that material variances between Channel Partner delivery data (top-funnel impressions, clicks, Offer Activations, and sends) and Program Sponsor Conversion data (bottom-funnel sign-ups, purchases, redemptions, or other verified actions) are common and often substantial due to differences in measurement methodologies, attribution windows, audience leakage, natural funnel drop-off (including users who do not complete the journey after leaving the Channel Partner's environment), interstitial friction, and other behavioral factors.

If the Controlling Measurement System data and Program Sponsor Conversion data differ by more than ten percent (10%) over any billing period, an automatic Level 2 Containment is triggered per Section 2.2. However, where the systems are disconnected, variances significantly larger than 10% are expected and do not, by themselves, indicate error or trigger formal remedies. Variances of 10% or less in connected or closely aligned systems are reconciled by CR using a weighted average of available data sources, with the Controlling Measurement System receiving primary weight where available. CR shall document the data sources and weighting applied in the Reconciled Campaign Report.

Channel Partner acknowledges that the 10% threshold is a commercially reasonable trigger for initiating review in cases where the data sources are expected to be closely aligned, but that larger variances are normal and anticipated when measuring disconnected top-funnel and bottom-funnel systems. CR shall apply all reconciliation methodologies consistently and in good faith, using commercially reasonable practices for attribution and billing discrepancy management.

The attribution window must be designated in each Program Exhibit. The default attribution window, absent a specific designation, is thirty (30) days from the date of the member's first click or activation. Conversions occurring outside the attribution window are not credited to Channel Partner and are not billable to Program Sponsor. Where a Program Exhibit designates multiple Conversion types with materially different attribution cycles, the Program Exhibit may specify a different attribution window per Conversion type. In the absence of a per-type designation, the default window applies to all Conversion types under that Program Exhibit.

Channel Partner must submit all creative materials to CR at creative@collectivereachadvisors.com no later than the Creative Approval Deadline in the applicable Program Exhibit. Each submission must include all ad units, email templates, push notification copy, banner images, landing page mockups in production-ready format, all promotional copy including offer headlines and FTC disclosures, all destination URLs and tracking links, and identification of any talent or third-party content included.

CR coordinates up to two (2) consolidated rounds of revisions per creative set at no additional charge. After the completion of two (2) complimentary consolidated revision rounds, if additional revision rounds are required due to Channel Partner's changes — rather than CR's or Program Sponsor's feedback — CR reserves the right to bill additional revision time at $175 per hour, with advance written notice to Channel Partner before incurring any such charge.

• No creative may be deployed prior to written approval from CR. Email confirmation is acceptable.
• Approval of one version of a creative does not constitute approval of any modified version.
• Channel Partner may not make any changes to approved creative — including resizing, copy edits, URL substitutions, or FTC disclosure modifications — without resubmitting for approval.
• CR and Program Sponsor reserve the right to withdraw approval of previously approved creative at any time if new legal, regulatory, brand, or reputational risk arises. Withdrawal does not entitle Channel Partner to any fee adjustment for promotions not yet deployed.

Channel Partner is solely responsible for obtaining all rights, licenses, permissions, and clearances necessary to use any content it includes in creative materials, including third-party images, music, copy, and talent. Channel Partner represents and warrants that its creative materials do not infringe any third-party intellectual property right and that all claims made are accurate, substantiated, and compliant with applicable advertising law.

Channel Partner has five (5) business days from receipt of a Reconciled Campaign Report to submit a written dispute to CR at billing@collectivereachadvisors.com. A dispute must identify the specific line items or date ranges being contested, state the basis for the dispute with reasonable specificity, and include all supporting data or documentation available at the time of submission.

Upon receipt of a written dispute, CR will: (a) acknowledge receipt within two (2) business days; (b) review the disputed line items against all available data sources within ten (10) business days; and (c) issue a written determination identifying CR's findings, any adjustments to the Reconciled Campaign Report, and the basis for CR's determination.

Uncontested portions of any Reconciled Campaign Report are not affected by a dispute. To the extent any Promotional Fee or other compensation is due to Channel Partner under the applicable Program Exhibit, CR will proceed to remit payment to Channel Partner for all uncontested line items on their normal schedule, regardless of any active dispute over other portions of the same report. CR's payment obligation to Channel Partner for any contested portion is suspended until resolution of that dispute. CR will use commercially reasonable efforts to resolve all disputes within thirty (30) days of receiving the initial dispute notice.

If CR's determination does not resolve the dispute, Channel Partner may escalate in writing to CR's senior management within five (5) business days of CR's determination. CR will arrange a good-faith resolution call within ten (10) business days. If the dispute cannot be resolved through good-faith negotiation, it is subject to the governing law and venue provisions of the Channel Partner Agreement.

CR may apply historical average billing as a temporary reconciliation mechanism pending final audit resolution — without a fully reconciled report — when: Channel Partner fails to deliver a required report within three (3) business days of the designated date and does not cure within 24 hours of CR's written notice; Channel Partner fails to complete a Level 3 Audit within thirty (30) days per Section 2.3; or Channel Partner's reporting is materially incomplete and Channel Partner has not initiated the Level 1/2/3 protocol.

Historical average billing is calculated at the historical average delivery rate for the affected campaign during the preceding thirty (30) days (or such shorter period as is available), provided such average is commercially reasonable given the campaign's delivery pattern. For campaigns with fewer than thirty (30) days of delivery history, CR will use the pro-rated Program Exhibit delivery commitment as the baseline. CR will notify Channel Partner in writing before applying default billing and will reconcile against actual data if and when it becomes available. Any billing applied on a historical average basis shall be adjusted to reflect confirmed actual delivery data upon completion of the applicable audit or reconciliation process.

• Channel Partner is solely responsible for obtaining all required consents and providing all required disclosures to its members and customers before delivering any Program-related promotional communication.
• Where applicable law requires opt-in consent for email or push notification marketing, Channel Partner must have obtained that consent prior to including a member in any Program promotion.
• Channel Partner must maintain records of member consent sufficient to demonstrate compliance with applicable law upon CR's reasonable request.

Where a material connection exists between Channel Partner and Program Sponsor — including where Channel Partner is receiving compensation, a Promotional Fee, or other value in connection with promoting Program Sponsor's Offer — Channel Partner must include a clear and conspicuous disclosure in all promotional communications, consistent with current FTC Endorsement Guides. Required disclosure language must be submitted as part of the creative review process per Section 4 and must receive CR's written approval before deployment.

Channel Partner may not use any data obtained in connection with any Program for any purpose other than performance of its obligations under the applicable Program Exhibit. Specifically, Channel Partner may not use Program data to retarget or build audience segments based on members' interactions with Program Sponsor's Offer; share Program performance data with third parties without CR's prior written consent; or use any Program data for employment, credit, health, insurance, housing, or education eligibility decisions.

Any tracking tags, pixels, cookies, or similar technologies deployed in connection with a Program must be disclosed to and reviewed by CR prior to deployment (as part of the creative review and Program Exhibit execution process); comply with all applicable laws including CCPA and CAN-SPAM; collect only the data necessary for Program attribution; and not circumvent user privacy controls or opt-outs.

Channel Partner shall not direct or knowingly permit any Program promotion to be delivered to individuals under the age of sixteen (16), or such higher age as required by applicable law. Channel Partner is responsible for implementing appropriate age-screening or exclusion mechanisms within its Channels.

Channel Partner shall maintain reasonable and appropriate technical and organizational security measures to protect any member or customer data processed in connection with any Program. In the event of any actual or suspected data breach that may involve Program-related member data, Channel Partner shall notify CR in writing within forty-eight (48) hours of becoming aware of the incident and shall cooperate with CR in any required regulatory notification or remediation effort.

Channel Partner shall flow down materially equivalent privacy, data security, and compliance obligations to any Third-Party Vendor it engages in connection with any Program, including obligations covering data use restrictions, tracking technology standards, breach notification, and member consent requirements consistent with Sections 6.1 through 6.6 of these Policies. Channel Partner remains directly responsible to CR for any Third-Party Vendor's failure to comply with flowed-down obligations.

Channel Partner shall not place, display, or deploy any Program promotion adjacent to content that: depicts or promotes violence, graphic harm, or illegal activity; contains sexually explicit or adult content; promotes controlled substances or regulated products inconsistently with applicable law; expresses hate speech or discrimination; is defamatory, harassing, or invasive of a third party's privacy; or a reasonable person would view as materially inconsistent with Program Sponsor's brand values or reputation, or any content that would reasonably be expected to cause material reputational harm to Program Sponsor or CR.

Where Channel Partner's promotional channels include sections containing user-generated content, Channel Partner shall use commercially reasonable efforts to implement content moderation or placement exclusion logic sufficient to prevent Program promotions from appearing adjacent to prohibited content. Channel Partner must respond to any reported violation within twenty-four (24) hours by removing the adjacency.

If CR or Program Sponsor identifies a placement that appears to violate these brand safety standards, CR will notify Channel Partner in writing. Channel Partner must respond within one (1) business day confirming removal or remediation. Repeated violations — three (3) or more confirmed violations across any rolling ninety (90)-day period — constitute a material breach of the Agreement.

Where Program Sponsor provides specific brand safety or adjacency guidelines to CR for a Program, CR will include those guidelines in the applicable Program Exhibit. Channel Partner acknowledges that Program Sponsor may have category-specific sensitivities beyond the baseline standards in Section 7.1 and agrees to comply with such guidelines as a condition of participation in that Program.

CR's attribution applies to all Conversions resulting from promotion of an Offer developed, structured, or activated by CR under any CR-managed Program, regardless of the marketing channel that delivers the Conversion. The relevant question is not which tracking identifier was used — it is whether the promotion that drove the Conversion specifically references or promotes the CR-managed Offer.

If a paid media placement (by either the Program Sponsor or Channel Partner) promotes the CR-managed Offer, any resulting Conversion is reasonably attributable to CR's Program and counts toward CR's billing to the Program Sponsor and any applicable performance thresholds or compensation calculations in the Program Exhibit.

Where a Program Exhibit includes a Conversion volume commitment or performance threshold, all Conversions from promotion of the CR-developed Offer — across all channels, owned and paid — count toward that threshold. Neither party may exclude Offer-specific paid media Conversions from performance threshold calculations. A party's decision to amplify the CR-developed Offer with paid media cannot be used to engineer a performance shortfall or inflate Conversion counts in a manner that distorts CR's performance benchmark.

The only Conversions excludable from CR's attribution are those resulting from a party's general brand or customer acquisition campaigns that do not specifically reference, incorporate, or promote the CR-managed Offer. A campaign that promotes the CR-developed Offer, even partially or in combination with other messaging, is not excludable.

To request an exclusion, the party must submit written notice to CR at billing@collectivereachadvisors.com identifying the campaign name, channels, and an explanation of why the campaign does not promote the CR-developed Offer. CR will confirm the exclusion in writing within five (5) business days or identify its objection with specific reasons. Pending CR's written confirmation, the campaign shall remain included in CR's attribution calculations. Disputes over whether a campaign qualifies for exclusion are governed by the dispute resolution process in Section 5 of these Policies.

CR strongly encourages parties to implement CR-designated identifiers in paid media placements promoting the Offer. Where CR-designated tracking is not used in a paid placement, CR may use a commercially reasonable estimation methodology — including comparison against baseline periods and Program Sponsor's inbound Conversion data — to identify attributable Conversions, subject to the reconciliation and dispute processes in Section 5.

CR will not count the same Conversion twice. Where a member encounters the Offer through multiple channels before converting, that Conversion is counted once in CR's Reconciled Campaign Report. CR's default attribution methodology is last-click within the designated attribution window unless the Program Exhibit specifies otherwise.