Last updated: June 6, 2024

We at Pelles.AI Inc. ("us", "we", or "our")recognize and respect the importance of maintaining the privacy of our customers and their end users. This Privacy Notice describes the types of information we collect from you when you visit our website and/or platform ("Platform") and/or use our services thereon (such services, together with the Site, the "Services"). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the End User License Agreement , available at the following LINK ("Terms"). "You" means an individual using the Services.

"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details whichPersonal Data we collect when we provide the Services to you.

 

1.     Personal Data We Collect

1.1.   In order to use our Services, and/or make a purchase through the Platform you will be required to register and provide us with certain Personal Data, such as end users’ name, email address and date of birth.

1.2.   We also collect Personal Data when you make use of the Platform, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.  If you use the Services by logging in through a third-party login service, such as Meta or Microsoft, we may also receivePersonal Data about you as provided by such third-party login service. Please check such third-party’s policies in order to understand what information we receive. Examples of the Personal Data that we collect from you when you engage in any of the activities detailed above, may include your name, address, birth date, gender, phone number, employer/engaging company, position, role, e-mail address. Such Personal Data may be collected by us through the Platform.

1.3.   We also collect any materials including images and/or pictures and/or photos and/or documents you may upload to the Platform.

1.4.   In addition, when you use the Platform, we may gather certain information automatically about your computer or mobile device, such as your operating system, your IP address, device ID, and subject to your consent as may be required under applicable law, (geo)location, as well as your browsing history and any other information regarding your use, viewing, and purchase history on our Platform.

1.5.   You are under no legal obligation to provide us with any such Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we may not be able to register you to the Platform and/or provide you with certain Services.

 

2.     How We Use Your Personal Data

2.1.   General. We and any of our trusted third-party subcontractors and service providers use the PersonalData we collect from and about you for any of the following purposes: (1) to provide you with the Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, targeted offers, and advertising on theSite/App/Platform, on other third-party sites or apps you may visit, or via e-mail, (5)  to contact you with informational newsletters and promotional materials relating to our Platform and Services; (5) to review the usage and operations of ourPlatform and Services; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) to prevent fraud, protect the security of our Platform and Services, and address any problems with the Platform and/or Services and (8) to provide customer support.

2.2.   Statistical Information and Analytics We and/or our service providers use analytics tools, including Google Analytics, to collect and analyze information about the use of the Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users.This helps us improve our Services by allowing us to identify new trends and customer needs, which in turn allows us to consider new products and services or tailor existing products and services accordingly. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

3.     Sharing the Personal Data We Collect

We share your information, including PersonalData, as follows:

3.1.   Affiliates. We share information, including your Personal Data, with our affiliated company, Pelles.AILtd. where this is necessary to provide you with our product sand Services, and for business management purposes.

3.2.   Service Providers and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using ourServices.

Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis

3.3.   International Transfers. By accepting thisPrivacy Notice, you acknowledge and agree that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data).

3.4.   BusinessTransfers. Your Personal Data may be disclosed aspart of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

3.5.   Law Enforcement Related Disclosure. We may share your Personal Data with third parties:(i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.

3.6.   Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

3.7.   Advertisers. When you click on an ad, whether or not it's on our Site, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it was you by using certain mechanisms, like cookies. We may share Personal Data with such advertisers as follows: (i) with your consent (ii) hashed IDs and/or device identifiers; or (iii) Personal Data available to all users of our Site and/or Services, such as profile data and other information you make available.Advertisers are able to combine the Personal Data they collect independently with the Personal Data we share.                                                                                      

3.8.   Other Uses or Transfer of Your Personal Data. If you use our Platform and/or Services with or through a third-party service, site and/or mobile application, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third parties outside of our Platform and/or Services, their own terms and privacy policies will govern your use of those services.

 

4.     Security

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

 

5.     Your Rights

Subject to applicable law, you may request to see any Personal Data you have providedto us and request that such Personal Data be corrected, updated, or deleted by emailing us at info@pelles.ai.

 

6.     Data Retention

6.1.  Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

6.2.  In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

7.     Cookies and Similar Technologies.

We use cookies and similar technologies for a number of reasons, including to help personalize your experience. Third parties through which we provide the Services and/or our business partners maybe placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting this Platform, you shall be notified of the use and placement of cookies and other similar technologies on your device as specified herein.

 7.1.   What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

7.1.1.   A"session cookie" is temporary and will remain on your device until you leave the Platform.

7.1.2.   A"persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.

7.1.3.   We may use the terms "cookies" to refer to all technologies that we mayuse to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or"pixel tags".

7.1.4.   First-party cookies are placed by us, while third-party cookies may be placed by a thirdparty. We use both first- and third-party cookies.                                                                                      

7.2.   How We UseCookies. We use cookies and similar technologies for a number of reasons,as specified below.

The specific names and types of the cookies, web beacons, andother similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

Type of Cookie:

Necessary

These  cookies are necessary in order to allow the Platform to work correctly. They  enable you to access the Platform, move around, and access different  services, features, and tools. Examples include remembering previous actions  (e.g. entered text) when navigating back to a page in the same session.  These cookies cannot be disabled.

Functionality

These cookies  remember your settings and preferences and the choices you make (such as  language or regional preferences) in order to help us personalize your  experience and offer you enhanced functionality and content.

Security

These  cookies can help us identify and prevent security risks. They may be used to  store your session information to prevent others from changing your password  without your login information.

Performance/Analytics

These  cookies can help us collect information to help us understand how you use our  Platform, for example whether you have viewed messages or specific pages and  how long you spent on each page. This helps us improve the performance of our  Platform.

Advertising

These  cookies are placed in order to deliver content, including ads relevant and  meaningful to you and your interests. They may also be used to deliver  targeted advertising or to limit the number of times you see an  advertisement. This can help us track how efficient advertising campaigns  are, both for our own Services and for other websites. Such cookies may track  your browsing habits and activity when visiting our Platform and those of  third parties.

7.3.   How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at anytime. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

 

7.4.   By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under"privacy" or "ads" in your device's settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements; it only means the advertisements that you do see will be less relevant to your interests.

 

8.    Third-Party Applications andServices

All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies.

9.    Communications

We reserve the right to send youservice-related communications, including service announcements andadministrative messages, without offering you the opportunity to opt out ofreceiving them. Should you not wish to receive such communications, you maycancel your user (account).

 

10.    Children

We do not knowingly collect Personal Data from children. In the event that you become aware that an individual who is a child has enrolled without parental permission, please advise us immediately.

11.    Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any update son this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to thisPrivacy Notice, we will seek to inform you by notice on our Site or via email.

 

12.    Comments and Questions

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at info@pelles.ai.

 

Supplemental Privacy Notice for California Residents

Last updated: June 20, 2024

This Supplemental Privacy Notice for California Residents ("CA Supplement") supplements and forms an integral part of our general privacy notice ("Privacy Notice").This CA Supplement describes how we collect, share, and store personal information about California residents who use our Site and/or Services, as well as the rights they have with respect to that information. If not otherwise defined herein, capitalized terms have the meaning given to them in our Privacy Notice.Please read the Privacy Notice for additional terms that may apply to you. Any reference to a 12-month period herein shall mean the period within such12-month period in which the Site or your user has been active (as applicable).

"Personal Information"means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, oras otherwise may be defined by applicable law.

Depending on your usage, we collect different types of information and we and any of our third-party sub-contractors and service providers use the information we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Information, but if you refuse to provide such Personal Information, we may not be able to register you and/or provide you with the Services or part thereof.

 

This CA Supplement will cover the following topics:

  1. Categories of Personal Information We Collect
  2. How We Share Your Personal Information
  3. Your Rights - How to Access and Limit Our Use of Certain Personal Information
  4. How to Contact Us

1.    Categories of Personal Information We Collect

In the past twelve months, wehave collected the following Personal Information from users of our Site and/orServices who are using the Site as performers. This Personal Data is used forthe purposes described in the Privacy Notice.

 

1.1.   Registration Information. In order to use our Services, you will be required to register and provide us with the following identifiers directly: your name, email address, birth date, gender, address, employer/engaging company, position, role,  and phone number. If you use the Services by logging in through a third-party login/account registration service (such as Meta, Google, Microsoft),we also receive certain identifiers about you indirectly as provided by such third-party service, as determined by such third party's policies and your preferences.

1.2.   PaymentInformation. We may collect your bank information upon registration or other information that would allow us to transfer payments to you. Additionally, you may be directed to a third-partypayment processor in order to make payments to us, in which case, we receive certain identifiers from such payment processor, such as the last four digits of your credit card number.

1.3.   Contact Information. If you contact us, we collect certain identifiers directly from you, such as your name, email address, and the content of your message.

1.4.   Device/NetworkInformation. When you use the Site or Services, we will collect information about your device automatically, including non-PersonalInformation such as your operating system and browser type, identifiers such as your IP address or device ID, and internet and other electronic network activity such as your browsing history and usage data.

1.5.   Product/UsageInformation. We collect commercial information regarding Performances that you have booked, including the pricing for such Performances. We collect this information automatically.

2.    How We Share Your PersonalInformation

2.1.   Sharing for Business Purposes. In the past 12 months, we may have disclosed the following categories of Personal Information for the following business or purpose in the preceding 12 months: we may have shared your personal identifiers and internet or other electronic network activity with data analytics providers, operating systems, and other third parties that assist us in providing you with the Services, including providing us with IT and system administration services, data backup, security, and storage services, and providing data analytics services, and to help us serve advertisements and provide other marketing services, as well as with our affiliates as necessary to provide you with services.

2.2.   AdditionalSharing Activities. 

2.2.1.   Affiliates. We share information, including your PersonalInformation, with our affiliated company, Pelles.AI Ltd. ,where this is necessary to provide you with the Site and Services, and for the purpose of management of our business.

2.2.2.   Business Transfers: YourPersonal Information may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such a case, your Personal Information shall continue being subject to the provisions of this CA Supplement.

2.2.3.   Law Enforcement Related Disclosure:We may share your Personal Information with third parties: (i) if we believe in good faith that such disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms, thePrivacy Notice, and this CA Supplement); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.                                                                                  

2.2.4.   Other Uses or Transfer of Your Personal Information:If you use our Services together with or through a third-party service, site and/or mobile application, we may receive information (including PersonalInformation) about you from those third parties.Please note that when you use third parties outside of our Site or Services, their own terms and privacy policies will govern your use of those services.

 

3.    Your Rights -How to Access and Limit Our Use of Certain Personal Information

Subject to certain exemptions, you have certain rights in relation to the PersonalInformation that we have collected about you, as detailed below. In accordance with applicable law, we may ask for reasonable evidence to verify your identity before we comply with certain of your requests, as detailed below.

3.1.   YourRights

3.1.1.   Right to Know and Access. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:

-       The specific Personal Information we have collected about you.

-       The categories of Personal Information we have collected about you.

-       The categories of sources from which we collected the Personal Information about you.

-       The categories of third parties to whom we disclose Personal Information about you.

-       The categories of Personal Information about you we have sold and the categories of third parties to whom we have sold such Personal Information.

-       The categories of Personal Information about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed suchPersonal Information.

-       Our business or commercial purpose(s) for collecting or selling your PersonalInformation.

3.1.2.    Right to Delete. Subject to certain exceptions, you have the right to request that we and any of our service providers delete your Personal Information.

3.1.3.   Right to Correct. If you find that any of the information we've collected about you is inaccurate, you have the right to correct such information.

3.1.4.   Right to Opt-Out of the Sale of Personal Information.If you are 16 years of age or older or have opted-in to the sale of yourPersonal Information, you have the right to direct us to not sell your PersonalInformation at any time. You may change your mind and opt back into the sale of your Personal Information at any time by contacting us at the address above. We may deny any request to opt-out of the sale of Personal Information that we deem in our good-faith, reasonable and documented belief is fraudulent. 

3.1.5.    Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates. 

3.1.6.   Right to Limit our Use of Your Personal Information.To the extent we collect any sensitive Personal Information about you, you have the right to instruct us to limit our use of such Personal Information only to for the purpose of providing you with our services and certain business operation purposes.  

3.2.   How to Exercise your California Privacy Rights

3.2.1.   ContactInformation. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at info@pelles.ai .You may only request to exercise your right of access twice within a 12-month period.

3.2.2.   Submitting a Verifiable Request: In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Information or an authorized agent of such person, which may include details relating to your account. Any requests made through your password protected account will be verified through our existing authentication procedures for such account.

3.2.3.    SubmittingRequests through an Authorized Agent:An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your Personal Information through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law.

 

4.    Retention

4.1.   We retain your Personal Information as long as necessary to fulfill each of thepurposes we described above. Once we're done with your data, we delete it.

4.2.   When deciding how long to store Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized access, the purposes for which the Personal Information was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business's retention policy.

 

5.    Children

We do not knowingly sell the Personal Information of California residents under 16 years of age.

 

6.    How to Contact Us

If you have any comments or questions about this CA Supplement or our privacy practices, or if you wish to exercise any of your legal rights as set out herein, please contact us at info@pelles.ai.