Chili Piper Privacy Statement

We at Chili Piper, Inc. (“Chili Piper”, “us”, “our”, or “we”) are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as how you can manage the personal information we collect. This Privacy Notice applies to your interactions with us (“Communications”) or your use of our websites, including www.chilipiper.com, apps.chilipiper.com, fire.chilipiper.com, and any other websites we offer that directly link to this Privacy Notice, and your use of our products, services, and apps either online or offline (collectively, our “Services”).

We reserve the right to change our Privacy Notice from time to time by posting the updated Privacy Policy. If we choose to amend this Privacy Notice, we will revise the Last Updated date at the bottom of this Privacy Notice when we post the updated version. We may also provide you with notice by prominently posting on our website, via email or both, if we make any significant changes to this Privacy Notice. We may also highlight those changes at the top of this Privacy Notice and provide a prominent link to it for a reasonable length of time following the change.

1. TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you when you provide it to us or when you use or interact with our Services or otherwise engage in Communications with us: personal information and non-personal information.

Personal information includes all information that relates to you or which are opinions about you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may collect the following types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services, such as your:

• Contact Information. Name, mailing address, email address, phone number, company name, and other contact information.
• Device Information. IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers.
• Geolocation Data. This is imprecise geolocation information that permits us to determine your general location.
• Billing Information. Credit and debit card numbers and other financial information necessary to receive payment for Services purchased, including the number of individuals within the organization that will be using the Services.
• Account Information. If you create an account, we may store and use your username, password, hints, and other personal information you may provide to authenticate your account. You can modify some of the personal information associated with your account. If you believe that someone has created an unauthorized account, you can request its removal.
• User Content. This is information such as your Communications with us and any other content you voluntarily provide, including survey responses, comments, reviews, and testimonials.

Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). Non-personal information includes optional information that you may choose to provide us and does not identify any individual, including company annual revenues, number of employees, or industry/sector. When we combine non-personal information with personal information, we treat the combined information as personal information.

You can always refuse to provide personal information, but please note that some personal information is necessary to provide our Services or to otherwise engage in Communications.

2. HOW WE COLLECT PERSONAL INFORMATION

Sources of Information

We collect your information in three ways: (1) directly from you when you engage with our Services or Communications; (2) automatically using online technologies when you engage with our Services or Communications; and (3) from certain third parties.

We collect your personal information in three ways: (1) directly from you when you engage with our Services or Communications; (2) automatically using online technologies when you engage with our Services or Communications; and (3) from certain third parties.‍

• Directly From You. We collect information directly from you when you:
  • Visit our website or use our Services;
  • Register for an account or membership;
  • Correspond with us in any way, including through surveys and promotions and other Communications;
  • Sign up to receive our newsletter or promotional information;
  • Interact with us in any other way, online or offline, including through our Services.
• Automatically Using Online Technologies. When you visit our websites, use ourServices, open or click on Communications we send you, or interact with our advertisements, we or other third parties may automatically collect certain information about you using online tracking technologies such as cookies, pixels, web beacons, software developer kits, and related technologies (for more information, see the section entitled “Cookies” below). Automatically collected information includes data related to Website features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and your IP address.
• From Third Parties. We collect information from certain third parties, such as our business customers that implement our Services, data analytics providers, marketing or advertising providers, fraud prevention service providers, and vendors that provide services to us including security, and account onboarding.

Cookies

What Are Cookies. Like many websites and apps, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use the website. We use this information for analytics purposes which allows us to improve your browsing experience. The information we collect through these technologies will also be used to manage your session. Out of these cookies, the cookies that are categorised as “necessary” are stored on your browser as they are essential for the working of basic functionalities of the website. These necessary cookies cannot be disabled.

Cookie Opt-out. You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies, if you opt-out from cookies, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”),on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Offline Interactions and Other Sources

We also may collect personal information from other sources, such as our partners or third party service providers, or from our offline interactions with you for the purposes listed in the How We Use Personal Information section below, including to enable us to verify or update information contained in our records and to better customize theServices for you.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, including the information listed in the Types of Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet”button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.

Surveys

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third party sponsor involved in the survey, we may provide certain personal information to the third party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Notice. By participating in any such surveys you will become subject to those rules, including but not limited to receiving emails containing survey communications.

3. HOW WE USE PERSONAL INFORMATION

We may use personal information to do any or all of the following:

• provide you with our Services;
• facilitate your interactions and transactions with us;
• respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
• administer our relationship with you, including creating and managing your account;
• administer and manage our business and relationships with business partners and customers;
• maintain and improve our Services;
• measure the performance of our Services;
• develop new products, features, and services;
• better understand the preferences of our customers;
• provide personalized Services, including content and ads;
• provide you with, and improve, relevant marketing offers or information from us or relevant third parties;
• facilitate your participation in our surveys and promotions;
• ensure our systems and premises are secure;
• develop and manage relationships with our business partners;
• operate tools and suppressors to exclude individuals from direct marketing after unsubscribing;
• respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
• prevent, detect, or investigate unauthorized use of our Services and ensure compliance with the lawand our policies;
• defend, protect or enforce our rights or applicable terms of service or to fulfill our legal orcontractual obligations;
• manage any dispute and accidents and take legal or other professional advice;
• prevent fraud or the recurrence of fraud;
• assist in the event of an emergency;
• comply with applicable law; or
• any other purpose with your consent.

Please note that personal information subject to Chili Piper’s Master Subscription Agreement with business customers will only be used and shared for the purpose of providing our Services to such business customers, including remediating any technical issues with ourServices and assisting users and business customers seeking to use our Services in connection therewith.

We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.

Except as otherwise permitted or required by applicable law, we only retain personal information for as long as we need to use the information for the purposes listed above, including, for legal, regulatory, backup, archival, accounting, and/or audit purposes.

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.

4. HOW WE SHARE PERSONAL INFORMATION

We may share personal information with our third party service providers, suppliers, vendors, professional advisors and business partners, which may include IT service providers, financial institutions and payment providers, customer relationship management vendors, other cloud-based solutions providers, lawyers, accountants, auditors and other professional advisors. We contract with such vendors and advisers to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information. We share personal information with these third parties to help us:

• with the uses described in the How We Use Information section above;
• in the operation, management, improvement, research and analysis of our Services;
• with our marketing and promotional projects, such as sending you information about products and services you may like and other promotions (provided you have not unsubscribed from receiving such marketing and promotional information from us); and
• comply with your directions or any consent you have provided us.

We may share personal information with law enforcement and regulatory authorities or otherthird parties as required or permitted by law for the purpose of:

• responding to a subpoena, court order, or other legal processes;
• defending, protecting, or enforcing our rights;
• assisting in the event of an emergency; and
• complying with applicable law.

In accordance with applicable law, we may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet ourbusiness needs.

5. HOW WE PROTECT PERSONAL INFORMATION

We are dedicated to ensuring the security of your personal information. We use physical, electronic, and administrative security measures appropriate to the risks and sensitivity of the personal information we collect. We aim to provide secure transmission of your personal information from your devices to our servers. We have processes to store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over theInternet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.

6. DATA TRANSFERS

We are a global business. As such, information we collect may be transferred to, stored, and processed in any country or territory where one or more of our business partners or service providers are based or have facilities which may be a different to your home country. In certain circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws that country. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal information that we transfer in line with this Privacy Notice.

7. CHILDREN’S PRIVACY

Our Services are not for children or those under the age of 13. We do not knowingly collect personal information from children or other persons who are under 13 years of age. Individuals who are children or those under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 13, please contact us immediately.

8. DATA RETENTION

We keep your information for as long as is necessary in accordance with the purpose for which it was collected, our business needs, as required under contracts with our business customers and as necessary to meet our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.

9. YOUR CHOICES

We offer you certain choices in connection with our Services.

Updating your personal information

The accuracy of the personal information we have about you is very important. To submit are quest to update or correct your information, please contact us using the information below.

Email Communications / Direct Marketing

You may have the opportunity to receive certain communications from us related to ourServices. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these necessary emails, if lawful and appropriate, even if you unsubscribe from our optional marketing communications.

Cookies / Beacons

If you wish to minimize information collected by cookies or beacons, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that someServices may not work properly if you reject cookies. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. For more information about how our Services use cookies, please see our Cookie section above.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt-out of certain network advertising programs through the Network AdvertisingInitiative (NAI) Opt-Out Page or through the Digital Advertising AllianceOpt-Out Tool. Please note that even if you choose to remove your personal information (opt-out) you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt-out of certain online behavioral advertising, please visit https://youradchoices.com/.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

10. THIRD PARTY WEBSITES AND APPS

Our website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

11. DISCLOSURE FOR CALIFORNIA RESIDENTS

The following disclosures are made pursuant tothe California Consumer Privacy Act, as amended by the California PrivacyRights Act and its implementing regulations (collectively, the “CCPA”).

Definitions

Personal information. This is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.

Sensitive personal information. This is information such as your social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications you have with us, genetic data, biometric information, health information, or information that concerns your sex life or sexual orientation.

Sell, sale, or sold. This means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.

Share, shared, or sharing. This means the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Relationship With You

Under the CCPA, we are a covered business in limited circumstances when not processing information on our business customer’s behalf. This includes information we collect through our website.

In all other instances we are a service provider that is limited

Your Rights

As a California resident, you have the following rights under the law:

• ‍Right to Know. You have a have a right to request that we disclose, subject to certain exceptions, information concerning: (1) the categories of personal information we have collected from or about you; (2) the categories of sources from which we have collected that personal information, and the business or commercial purpose for the collection; (3) the categories of third parties with whom we have shared, sold, or disclosed your personal information, including the business or commercial purpose for said sharing, selling, or disclosure; and (4) specific pieces of your personal information, subject to appropriate exceptions.
• Right to Correct. You have a right to request that we correct your personal information, subject to certain exceptions.
• Right to Opt-Out of the Sale or Sharing of Personal Information. Certain of our online tracking technologies may be considered a “sale” or a “share” of your information to third parties under the CCPA. Visitors to our Websites can therefore opt-out of being tracked by these technologies by sending an e-mail to support@chilipiper.com. We have no actual knowledge that we sell the personal information of California residents who are under 16 years of age. You may also opt-out by using an opt-out preference signal, such as the Global Privacy Control (GPC) on your browser. To download and use a browser supporting the GPC, you may click here. If you choose the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
• Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against under the CCPA.‍

Exercising Your Rights

Requests To Us. Where we collect you information for our own behalf including with respect to our website, you or an authorized agent you designate on your behalf may submit the individual requests outlined below. Upon receipt, we will take reasonable steps to verify you and your authorized agent’s identity prior to responding to the request, which may include in certain circumstances you signing a declaration under penalty of perjury. If an authorized agent is submitting a request on your behalf, you must submit a copy of: (1) a written authorization demonstrating you have authorized the agent to submit a request on your behalf; and (2) provide separate proof verifying your identity.

Requests to Business Customers. Where you are using our Services in connection with a service or any engagement with one of our business customers that have implemented our Services, all requests should be directed to the respective business customer. In the event you submit a request to us that should be directed towards a business customer, we will inform you of such requirement and redirect your request to the applicable business customer if known by us.

Submitting Requests. To submit a request, you may send an e-mail to support@chilipiper.com.You may also designate an authorized agent to submit a request on your behalf by sending an e-mail with written proof of such authorization to support@chilipiper.com. Once you have submitted your request, we will respond within the time frame permitted by applicable law.

Notice of Collection

• To learn more about the categories of personal information we collect about California residents, please see Types of Information We Collect above.
• For more information about how we use those categories of personal information, please see How We Use Personal Information above.
• For more information about how we collect categories of personal information, please see How We Collect Information? Cookie, Online Analytics, Offline Interactions and Other Sources, Social Media Integration, and Surveys.
• To learn more about how we disclose categories of personal information, and the categories of third parties with whom we disclose such information, please see How We Share Personal Information? above.
• To learn more about how long we keep your information, please see Data Retention above.

Notice of Disclosure for a Business Purpose

To learn more about the categories personal information we have disclosed for a business purpose, and the categories of third parties with whom we’ve disclosed such information, please see How Do We Disclose Your Information? above.

Notice of Sale or Sharing of Personal Information

When we are engaged by our business partners we execute agreements with contract provisions necessary to establish us as a “service provider” under the law. Any disclosure of personal information in connection with our Services to business partners is not considered a sale.

With respect to our website and analytics tools related to our Services, certain of our online tracking technologies may be considered a “sale” or a “share” of your information to third parties under the CCPA. The categories of personal information we may “sell” or “share” in these circumstances includes your IP address, persistent online identifiers, ad identifiers, similar information about your devices and browsers, and information about your engagement with ourServices.

We have no actual knowledge that we sell the personal information of California residents who are under 16 years of age.

Notice of Financial Incentives

We do notcurrently offer any financial incentives in exchange for personal information.

Notice of Use of Sensitive Personal Information

We do not use California resident sensitive personal information for any purpose other than is permissible under the CCPA. Specifically, we do not use sensitive personal information of California residents to derive characteristics about California residents.

12. ACCESSIBILITY

To print a copy of this Privacy Policy, please click here.

If you require a copy of this Privacy Policy in an alternative format, please Contact Us.

13. CONTACT US

We welcome requests, questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have requests, questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

Email

support@chilipiper.com

Mail

Chili Piper Privacy

228Park Ave S # 78136

NewYork, New York 10003-1502

United States

Effective Date: 07/29/2021

Last Updated:  03/29/2024