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CHARLIE AI PRIVACY POLICY

Updated January 31, 2022

Charlie AI LLC (referred to herein as “Charlie AI”, “we”, “our”, or “us”) values and respects the privacy rights of individuals and recognizes the importance of protecting personal information. This privacy policy (“Privacy Policy”) explains what personal data we collect from individuals and how we use it.

By using or otherwise accessing Charlie AI’s website (the “Website”) or automated telephone call receptionist service (the “Service”; collectively, the “Services”), you accept and agree to the following privacy policy (the “Privacy Policy”), and you are consenting to our collection, use, disclosure, retention, and protection of personal information as described in this Privacy Policy as it arises from or relates to your access or use of the Services. If you do not agree to the terms of this Privacy Policy, you shall not access or use the Services.

This Privacy Policy is incorporated by reference into the Charlie AI Terms of Use and is subject to the terms therein.

  1. SCOPE.

    1. This Privacy Policy applies to the collection, use, and disclosure of personal information by us through the Charlie AI Website and/or Service. This Privacy Policy does not apply to any information not collected through the Website or Service.
    2. “Personal information” is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that Charlie AI has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
  2. COLLECTION.

    1. How We Collect. We collect your personal information when you sign up to receive information via the Website, when you sign up for the Service, and during your use of the Service. Charlie AI only collects your Personal Information (i) when applicable, with your consent, (ii) in our role as a service provider, (iii) if we have a legitimate interest in doing so, or (iv) as authorized or required by law. The types of Personal Information we collect about you and the manner of collection depends on how you interact with us. We only collect Personal Information as reasonable and necessary.
    2. What We Collect. The personal information we collect includes, but is not limited to:

      1. Identifying information such as name, e-mail address, and/or other unique personal identifiers;
      2. Information transmitted to us during your sign up for and use of the Service;
      3. Information you provide when contacting us for help; and
      4. Device IDs, IP Addresses, and/or other unique technical identifiers.
    3. Sources. Sources of Personal Information that we collect may include (but are not limited to) the following:

      1. From you, when you communicate with Charlie AI, such as your identifying and contact information when you request information via the Website, and your payment information when you sign up for Service. We collect this information with your consent, and we use it for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you direct marketing communications.
      2. From you, when you use the Service, such as via communications related to your subscription, information related to your account, or data collected by your phone. We collect this information with your consent, and use it to provide and improve the Service.
      3. From you while on a phone call with Charlie AI. We may record the call for quality monitoring, training, to improve the Service (including but not limited to for training machine learning algorithms), and other internal business purposes. You will be notified if your call is being recorded. By staying on the line after receiving the notification, you consent to the call recording. If you do not consent to call recording, you may end the call or ask to not be recorded.
      4. From callers, in Charlie AI’s capacity as a service provider. Our Service may collect Personal Information from callers on behalf of Customers via our virtual receptionist, such as caller contact information and other caller Personal Information. Such collection is per Customer’s instruction, and use thereof shall be limited to as permitted by our agreements with Customer or as permitted by law.
      5. From automated logging and tracking technologies. This information may be used to pursue legitimate interests, to provide and/or improve the Service.
    4. Children. Charlie AI is aware of the importance of protecting the privacy and safety of children who may use our Services. In that regard, we do not knowingly solicit data from or market to children under the age of 18. In the event a child’s parent and/or legal guardian becomes aware that their child has provided us with information without their consent, please contact us immediately at support@CharlieAI.com. Once notified, we will delete the information as soon as reasonably possible.
  3. USE, RETENTION, AND CORRECTIONS.

    1. How We Use Personal Information. We will never sell personal information to third-parties for advertising or marketing purposes. Personal information provided and otherwise collected will be used to provide and improve the Services, to personalize the Services for you, and for other legitimate interests. This includes, but is not limited to, making the Services operable, providing customer service, corresponding with you, to protect the integrity and operation of the Services, protecting Personal Information, enforcing this Privacy Policy and the Terms of Use, and if necessary to comply with a law, regulation, or court order. Charlie AI may also use personal information for other uses such as for validating a user account, fraud prevention, other data safety precautions, for data analysis, auditing, and research to improve the Services.
    2. Duration of Retention. We will keep personal information as long as there is a reasonable basis to do so, whether to enforce any relevant law, the provisions of any agreement, to resolve any past, current, or future dispute, or any other business, tax, or legal purpose. When we dispose of personal information, we will do so in a secure manner.
    3. Corrections. You may request correction of any personal information that is incorrect by contacting us at support@CharlieAI.com. Such requests regarding such personal information may only be made by the subject thereof. We may require verification of your identity before proceeding with the request.
    4. Non-Personal Information. Charlie AI collects information that in and of itself does not permit direct association with any specific person. In the case of non-personal information, Charlie AI has the right to collect, transfer, use, and disclose this information for any purpose.
  4. YOUR CHOICES.

    1. Decline to Provide Information. You may decline to submit personal information, however, doing so may prevent you from using the Service or the Website. You acknowledge and agree that your inability to use the Service or take advantage of any features of the Website to your refusal to submit any required personal information shall not be grounds for any claim of breach, damages, or other liability; nor shall it in any way relieve you of your obligations to Charlie AI.
  5. STORAGE OF PERSONAL INFORMATION.

    1. How Secure It Is. Charlie AI shall use commercially reasonable measures inline with industry standards to protect personal information, including but not limited to electronic and administrative safeguards designed to help make personal information secure. We will make reasonable attempts to provide you with notice in the event of a security breach.

      When you use the Service as a caller, all personal information you provide may be provided to the designated recipient. You are responsible for the personal information you choose to share or submit in these instances.

    2. Where and How It’s Stored. The information you provide Charlie AI may be processed in the United States or any other country in which Charlie AI, its subsidiaries, affiliates, and/or service providers maintain facilities.

      As a result, Charlie AI its subsidiaries, affiliates, and/or service providers may transfer information we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Consequently, when you register to use the Website you acknowledge and consent to Charlie AI transmitting your information to the United States or to any country in which Charlie AI and/or its subsidiaries, affiliates, and/or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

      In turn, Charlie AI uses commercially reasonable standards, measures and/or protocol to keep the information collected secure. Charlie AI cannot ensure the security of any information submitted or transmitted by you to Charlie AI nor can we guarantee that said information may not be disclosed, destroyed, and/or altered.

  6. DISCLOSURE.

    1. When Will We Disclose Personal Information. We may share personal information with third-parties when necessary to provide the Services, when we have a good faith belief it is necessary by law or to respond to legal process, to protect the safety and lives of people, to protect the rights or property of Charlie AI, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and with the subject’s consent. We shall not disclose personal information to third-parties for their advertising and marketing purposes.

    2. Disclosure to Recipient. If you are a caller, you consent to our disclosure of your personal information to the designated recipient.

    3. Disclosure to Sub-Contractors and Agents. Charlie AI may use the services of other companies in order to provide the Services. Such companies shall be given only the personal information needed to perform those services, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. We have contracts in place holding such companies to the same standards of confidentiality by which Charlie AI is governed. Charlie AI shall make commercially reasonable efforts to enforce such terms on such companies. However, Charlie AI shall not be liable to you for such companies’ failure to adhere to such confidentiality terms.

      Such third-party service providers may include, but are not limited to:

      1. Cloud storage providers;
      2. Data analytics providers;
      3. Research partners; and
      4. Consultants, accountants, lawyers, and other professional service providers.
    4. Business Affiliates and Transfers. Charlie AI may share information from or about you with its subsidiaries, joint ventures, or companies under common control, in which case we will require them to adhere to this Privacy Policy. In the event Charlie AI is acquired in total or by a substantial amount of its assets, we will make best efforts to ensure that the purchaser will assume the rights and obligations of this Privacy Policy. However, Charlie AI does not make any guarantees or promises with respect to a purchaser adopting the current rights and obligations of this Privacy Policy.
    5. Investigations. Charlie AI reserves the right to provide and/or disclose necessary information for investigatory matters. Examples include but are not limited to: 1) compliance with law enforcement or the necessary legal process; 2) behavior and/or use violative of the Terms of Service, and 3) instances whereby it is necessary to protect our rights and obligations.
    6. Per User Request. Charlie AI may share your information if requested or consented to by you.
  7. TERMS FOR EEA, CALIFORNIA, AND CANADIAN USERS.

    1. Additional Rights. Under the California Consumer Privacy Act (“CCPA”), the EU General Data Protection Regulation (“GDPR”), and Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), California, EEA, Switzerland, UK, and Canada residents may have certain rights regarding their data, including:

      1. To know the categories of personal information collected and disclosed and the sources from which such information was collected (see Section 2.2);
      2. The know the business purpose for using or sharing personal information (see Section 3.1);
      3. To request corrections of incorrect personal information (see Section 3.3);
      4. The categories of third parties with whom personal information has been and will be disclosed (see Section 6);
      5. The ability to know and delete certain pieces of personal information (see below).
    2. Exercise of Rights. California, EEA, Switzerland, UK, and Canada residents may exercise the above rights, subject to Charlie AI’s receipt of a verifiable consumer privacy request, and subject to any applicable exceptions and limitations.

    3. Consumer Privacy Request. You may submit requests to access, edit, delete, or expert your personal information via the Service itself. If may also exercise your rights under applicable privacy laws by submitting a request to us via e-mail: support@CharlieAI.com; or via the webform at the following link: Privacy Policy. The foregoing means may also be used to revoke consent to use your personal information. All requests are subject to verification.

      If we process your personal information in our capacity as a service provider or data processor to a customer, we may be required to instruct you to submit your request to that customer.

    4. Basis for Processing.
      1. Charlie AI takes reasonable steps to ensure that the personal information we collect is reliable for its intended use, accurate, complete, and up to date. Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. We collect and use your personal information to pursue our legitimate interests, in order to enter into or perform a contract with you, with your consent, or to comply with our legal obligations. If you wish to learn more about specific legal grounds we rely on to process your personal information for any particular purpose (including any legitimate interests we have to process this information), please contact us as provided herein.
      2. You have the right to lodge a complaint with the data protection authority about our collection and use of your personal information in relation to the General Data Protection Regulation (GDPR) and other applicable law. For more information or to submit a complaint, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available at the following link: https://ec.europa.eu/newsroom/article29/items/612080. Contact details for the Information Commissioner’s Office in the United Kingdom are available at the following link: https://ico.org.uk/make-a-complaint/.
  8. OTHER.

    1. Correcting Personal Information. You agree to notify Charlie AI of personal information that you are aware has errors.
    2. Changes. We reserve the right to make changes to this Privacy Policy at any time. Your continued use of our Services will signify your acceptance of any changes to our Privacy Policy.
    3. Third-Parties. This Privacy Policy applies to Charlie AI’s use of personal information but does not apply to the activities of any third-party. If you disclose personal information to others, whether as a result of any purchase transaction, ad-click, or otherwise, such third-party’s privacy policies and practices will apply. Charlie AI shall not be liable or in any way otherwise responsible for any use of personal information by such third-parties.

    4. Contact Us. If you have any questions, concerns, or complaints related to or regarding the above please contact us at:

      ATTN: Privacy Officer
      CharlieAI LLC
      300 East Davis
      McKinney, Texas 75069
      support@CharlieAI.com

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