PRIVACY POLICY

This “Privacy Policy” describes the privacy practices of CharmIQ, Inc. and our subsidiaries and affiliates (collectively, “CharmIQ”, “Charm”, “we”, “us”, or “our”) and the rights and choices available to individuals with respect to their information in connection with the www.charmiq.ai website, and any other website that we own or control and which posts this Privacy Policy (any, a “Site”).

Charm may provide additional or supplemental privacy policies to individuals for specific products or services that we offer. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service. This Privacy Policy does not apply to employee or contractor data.

We provide important information for individuals located in Europe in the section titled “Additional Information for Individuals in Europe” below.

Table of Contents

• Personal Information We Collect

• Cookies and Similar Technologies

• Do Not Track Signals

• How We Use Your Personal Information

• How We Share your Personal Information

• Your Choices

• Security

• International Transfer

• Other Site and Services

• Changes to this Privacy Policy

• Contact Us

• Your California Privacy Rights

• Additional Information for European Users

Personal Information We Collect

Information you give us

Personal information that you may provide through the Site or otherwise communicate with us, including via our pages on social networks, includes:

• Personal and business contact information, such as your first name, last name, mailing address, phone number, and email address

• Information about your business, such as company name, industry, product and service offerings, goals, and financial information

• Information about your professional experience, such as places and length of employment, professional responsibilities and accomplishments, and other information of the type that would be included on a resume or curriculum vitae

• Feedback and correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online

• Demographic information, such as your city, state, country, and postal code and ethnicity (if you choose to provide it)

• Profile information, such as the username and password that you may set to establish an online account with us, and your preferences

• Usage information, such as information about how you use the Site and interact with us, including any information that you submit to us through the Site

• Marketing information, such as your preferences for receiving marketing communications, details about how you engage with marketing communications, and your responses to our marketing research

Information that we receive about third parties

We may receive information about individuals who do not interact with us directly. For example, our users, vendors, and partners may provide us with personal information about persons other than themselves when using the Site. We require these parties that provide us with personal information about other individuals to obtain the individual’s permission or otherwise have lawful authority to share the personal information with us for processing as described in this Privacy Policy. The types of information we receive about third parties includes:

• Personal information about other company owners, officers, or employees, such as the name and contact information of these individuals

• Contact information of referrals submitted by our users

Information we obtain from third-party platforms and social media networks

We may maintain pages for our company, and our products and services on third-party platforms, such as Facebook, LinkedIn, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. You may choose to provide us with information through the third-party platform, and we will treat such information in accordance with this Privacy Policy. If the third party platform provides us with information about our pages on those platforms or your interactions with them, we will also treat that information in accordance with this Privacy Policy.

Information automatically collected

When you access our Site, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity on our Site. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our Site, general location information such as city, state or geographic area; and information about your use of and actions on our Site, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected using cookies and similar technologies. Please refer to the Cookies and Similar Technologies section for more details.

Cookies and Similar Technologies

What are cookies?

Cookies are small data files stored on your computer or mobile device by a website. Our Site may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers or business partners on our Site, and can be used by such service providers or business partners to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Essential cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality cookies

These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.

Analytics and performance cookies

These cookies collect information about traffic to our Site and about how individuals use our Site. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.

We use Google Analytics for this purpose, and Google uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

Social media cookies

These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.

Targeted and advertising cookies

These cookies track your browsing habits to enable us and third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests or browsing behavior. Based on the cookies that the third-party advertising network sets on our Site and other sites, advertisers can display advertisements that may be relevant to your interests on our Site and while you are on third party websites.

You can choose to disable cookies, as described in the “Disabling cookies” section below, or to opt out of the use of your browsing behavior for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Policy.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” menus). Many browsers are set to accept cookies until you change your settings

For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

Other Technologies

In addition to cookies, our Site may use other technologies, such as Flash technology to pixel tags to collect information automatically.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a web page was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Site, so that we can manage our content more effectively.

Do not track signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

How We Use Your Personal Information

To provide our Site

If you use our Site, we use your personal information to:

• operate, maintain, administer and improve the Site

• facilitate communications between users of the Site

• match users with third parties we think may be helpful to our users, such as mentors, experts, service providers, and other small businesses

• provide information about our products and services

• process and manage registrations you make through the Site, including requests to receive additional information

• better understand your needs and interests, and personalize our content on the Site and in our communications

• provide support and maintenance for the Site

• respond to your requests, questions and feedback

To communicate with you

If you request information from us (such as by signing up for our newsletter or marketing emails or registering to attend one of our events), we may send you Charm-related marketing communications as permitted by law. You will have the ability to opt out of our marketing communications.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your personal information where required by law. If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us at privacy@charmiq.ai. If you have consented to receive marketing communications from one of our partners, you may withdraw your consent by contacting the partner directly.

To create anonymous data for analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Site; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share your Personal Information

Affiliates

We may disclose your personal information within the Charm group of companies, including to Charm's corporate parents, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Other Site users

We use your personal information you provide to display a profile for you or your business on the Site. We may provide controls that enable you to change the visibility of certain information on the profile.

Third parties we think may be relevant to you or with whom you request to interact
We use your personal information to help match you with third parties we think may be relevant to you or with whom you request to interact. For instance, we may match you with mentors, experts, service providers, other small businesses, or other third parties, based on the information you provide us.

Service providers

We may employ third party companies and individuals to administer and provide services on our behalf (such as customer support, hosting, email delivery, and database management services). These third parties may use your information only as directed by Charm and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety Charm may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Site; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business transfers

Charm may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy. (Note: Charm will not sell you personal information as a general business practice for purposes of generating revenue).

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within Member States of the European Union, countries in the European Economic Area, and the United Kingdom (collectively, “Europe” or “European”) may read additional information about their rights in the section titled “Additional Information for Individuals in Europe” below.

Access, update, or correct your information

You may also contact us at privacy@charmiq.ai to access, update or correct the personal information that Charm maintains about you, or if you have additional requests or questions.

Marketing communications

You may opt out of marketing-related emails by clicking on the opt-out or unsubscribe link at the bottom of each such email, or by contacting us at privacy@charmiq.ai. You may continue to receive service-related and other non-marketing emails.

Targeted online advertising

Some of the business partners that collect information about users’ activities on our Site may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide services or the Site to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the services by designating it as required in or on the Site or through other appropriate means.

Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Children

Our Site is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@charmiq.ai. We will delete such information from our files as soon as reasonably practicable.

International Transfer

Charm is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European Union users should read the important information provided below in the “Cross-Border Data Transfer” section below about transfer of personal information outside of the European Economic Area.

Other Site and Services

The Site may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Site.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or concerns about our Privacy Policy or privacy practices, please feel free to email us at privacy@charmiq.ai. You may also write to us via postal mail at:

Attention: Privacy

CharmIQ, Inc.
220 N. Green Street, Suite 2011
Chicago, IL 60607

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at privacy@charmiq.ai. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Additional Information for Individuals in Europe

The information provided in this “Additional Information for European Users” section is provided for individuals located in Europe.

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller

CharmIQ, Inc. is the controller of your personal information for purposes of European data protection legislation.

Legal bases for processing

We use your personal information only as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@charmiq.ai.

Processing purpose

Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal data”.

Legal basis

To provide our Site

Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

To communicate with you

To create anonymous data for analytics

For compliance, fraud prevention and safety

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law

Processing is necessary to comply with our legal obligations.

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at privacy@charmiq.ai.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to race, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on the Site, or otherwise to us.

If you send or disclose any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Site.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your Rights

European data protection laws give European Union users certain rights regarding their personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct. Update or correct inaccuracies in your personal information.

• Delete. Delete your personal information.

• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

• Restrict. Restrict the processing of your personal information.

• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.

You can submit these requests by email to privacy@charmiq.ai. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of Europe to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based:

• Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules

• Pursuant to the consent of the individual to whom the personal information pertains

• As otherwise permitted by applicable European requirements.

You may contact us at privacy@charmiq.ai if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.