California Privacy Notice

We collect 'Personal Information', data that identifies, relates to, or could reasonably be linked with a particular consumer or device. The following list details the categories of data collected over the last 12 months:

The categories and examples below are defined by the CCPA/CPRA. We list them to be transparent about what we *may* collect, but inclusion does not mean we collect every example listed.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA / CPRA, Personal Information excludes publicly available government records, deidentified or aggregated consumer information, and data covered by sector-specific laws (e.g., HIPAA, CMIA, FRCA, GLBA, FIPA, DPPA).

We collect Personal Information directly from you (e.g., forms, purchases), indirectly (e.g., activity observations), automatically (e.g., cookies), and from Service Providers (e.g., payment processors).

We retain Personal Information only as long as necessary to fulfill collection purposes and satisfy legal, accounting, or reporting requirements, based on data amount, nature, sensitivity, and risk.

We use and disclose your Personal Information for the following business and commercial purposes:

• To maintain our platform and deliver the Services you have requested.
• To offer customer assistance, address your questions, resolve issues, and enhance our Service offerings.
• To achieve the purpose for which the data was shared. For instance, contact details provided for inquiries will be used to respond, and payment information will be used to process transactions and fulfill orders.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of your Personal Information" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were disclosed, but it reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been disclosed.

Disclosures for business or commercial purposes are governed by written agreements. These contracts specify the intended purpose and mandate that the recipient maintains confidentiality and uses the information solely for contract fulfillment.

We may share, and have shared in the last twelve (12) months, your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors and/or websites to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, such as payment processing

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell your personal information for monetary consideration. However, we may use third-party cookies or tracking technologies for cross-context behavioral advertising, which may be considered 'sharing' or a 'sale' of personal information under the CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were sold, but it reflects our good faith belief to the best of our knowledge, that some of that information from the applicable category may be and may have been shared for value in return.

Our platform is not designed for individuals under 16, and we do not knowingly harvest their Personal Information. Linked third-party sites operate independently; we advise parents to supervise their children's online activities.

We do not sell the personal information of Consumers we actually know are less than 16 years of age unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

California residents have specific rights regarding their Personal Information under the CCPA and CPRA, including:

• The right to notice. you have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• Right to Access and Know. You are entitled to request details regarding the specific pieces and categories of Personal Information we have collected, the sources of such data, the purposes for collection or sale, and the third parties with whom it is shared. 
• The right to opt-out of the sale or sharing of Personal Information. You have the right to direct us to not sell or share your personal information for cross-context behavioral advertising. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact us.
• The right to correct Personal Information. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Information. you have the right to request to limit the use or disclosure of certain sensitive personal information we collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us.
• Right to Erasure. You may ask us to delete your Personal Information, subject to certain legal exceptions. Requests may be declined if data retention is required for transaction completion, security, legal compliance, or internal uses compatible with the original context.
• The right not to be discriminated against. you have the right not to be discriminated against for exercising any of your consumer's rights, including by: Denying goods or services to You; Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; Providing a different level or quality of goods or services to You; Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us at privacy@counselai.com or 223 Moffett Blvd, Mountain View, CA 94043

Only You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Verifiable Requests: You must provide sufficient information to verify your identity and describe your request in enough detail for us to understand and respond. We cannot respond if we cannot verify your identity or authority.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will cover the 12-month period preceding the verifiable request's receipt. You may request information collected on or after January 1, 2022 beyond this 12-month period, unless doing so proves impossible or would involve a disproportionate effort.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

To exercise your right to opt-out of the sale or sharing of your personal information, please contact us. 

If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how we use your personal information, please see the "Use of your Personal Information" section or contact us.

The Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. you can enable or disable DNT by visiting the preferences or settings page of your web browser.

California's 'Shine the Light' law (Civ. Code § 1798.83) allows residents to request information regarding our disclosure of Personal Information to third parties for direct marketing purposes.