Privacy Policy

Privacy Statement

Last Updated: November 25, 2024

Causify.AI Incorporated (“Causify.AI”) owns and operates an online website and platform that provides users with AI based products and services to analyze data, predict outcomes and guide decision making. In this Statement, we refer to these as our “Services”.

The information that you and others entrust us with enhances our ability to provide more relevant and helpful Services. We take your trust in us seriously and are committed to providing you with information, products and services based on the information you have shared with us. We are committed to respecting your privacy when you visit our website or use our Services and being transparent about how we use the information you have entrusted to us.

This Statement describes how we obtain, use, and process your information. It informs you of the rights you have, how you can exercise them and how you can contact us. Please review this Statement carefully to learn about our practices with respect to information and privacy. By visiting our websites, related mobile applications and use our Services, you acknowledge and confirm that you have read this Statement.

We offer our Services to users in a number of countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices. In addition, this Statement provides specific information relevant to users residing in certain regions or countries.

1. Information Collected and Processed

When you access or use our Services, we collect and process information from and about you to provide the Services in a more personalized and relevant way. Some information we collect passively (for example, with our servers, cookies or other similar tracking technologies). Some information we collect directly from different sources, including from you, affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a third-party website or when you visit third-party websites via our Services, those third-party websites may also share information with us about your use of their service. Any information that we receive from third-party websites may be combined with the information provided by you and processed as detailed in this Statement.

Information processed may include the following:

(a) Contact information, including name, phone number, and postal and email addresses (both hashed and unhashed)

(b) Billing and other payment information (such as your bank account information, credit card number, cardholder name, expiration date, authentication code and billing address)

(d) Details relating to your registration or subscription with Causify.AI

(e) Device information, such as when you accessed our Services and information about the device used (for example, IP address, software or internet browser used, preferred languages, unique device identifiers, and advertising identifiers)

(f) Online activity, including pages you have visited, content reviewed, and apps reviewed

(g) Other information about yourself that you have voluntarily disclosed

(h) Communications with us, such as when you contact our customer service team, including inbound and outbound calls

(i) Information that you have provided to other third-party companies, for example, for the purposes of logging in to social media. This includes publicly available information, such as name, age range as well as email addresses.

2. Information Uses and Purposes

To the extent possible, we want to provide you with relevant content when you use our Services, and we may use information about you to do that in various ways, including to:

(a) Facilitate registration, subscription, and other contracts with us

(b) Manage your account, including to allow you access to and use of our Services

(d) Improve our Services, including but not limited to analytics, quality assurance, product and service development and improvement

(e) Provide you with a tailored/optimized experience by grouping users based on, for example, usage, interests and demographics

(f) Communicate with you or facilitate communication between you and our partners and/or affiliates

(g) Respond to your questions and comments

(h) Resolve disputes or troubleshoot problems

(i) Prevent fraud and other potentially prohibited or unlawful activities

(j) Comply with relevant laws, respond to legal requests, prevent harm, and protect your or our rights

(k) Provide payment services, including to detect and prevent money laundering, fraud and security incidents

(l) Enforce any applicable terms of service

3. Information Sharing

In order to provide some of our Services and processing activities, we use third-party service providers, including web developers and software developers, and share information with these service providers and certain other third parties, as set forth in more detail below. Please note, that while we seek to ensure that your private data’s confidentiality and privacy are protected by such third parties, we do not control such third parties and are not responsible for their behavior.

(a) Hosts, Suppliers and Business Partners. We may share information with certain suppliers used to facilitate our Services, including to develop and provide technical support to our Services. We may also share information about you, your devices and your use of our Services with our trusted business partners. For example, we may share information so that we can facilitate payment for products or services you may purchase on the websites of our partners.

(b) Fraud Detection Companies. Third parties may assist us by providing us with their fraud detection technologies.

(c) Other third parties, such as advertisers and referring websites. Third parties may also assist us in collecting information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. Other third parties may also provide us with their content and contract generation, management, and hosting tools. Third parties may only collect or access information as needed to perform their permitted functions. If and to the extent these third parties only assist us to perform our processing operations, we have bound them contractually to only act on our behalf as so-called data processors.

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

(a) To comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.

(b) To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Causify.AI, our customers, or others; and in connection with our Terms of Service and other agreements.

(c) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

4. Information Choices

You have options with respect to the processing and use of your information by us. You are able to access, update, change preferences regarding, or close your account, but please note that limiting information you share with us may affect the functionality of and your experience with the Services. Regarding your information preferences, you may have the opportunity do the following:

(a) Choose the way in which and whether we communicate with you.

(b) Choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites or Services.

(c) Prevent the collection of certain geolocation information (e.g. by switching off location services for our app in the settings of your phone), but note that turning off location sharing may affect certain features of our Services.

(d) Close your account. Note that if you close your account, we have the right to deactivate your account and remove your profile information from active view. We may retain some information associated with your account for purposes including backups, fraud prevention, dispute resolution, investigations, our own legitimate business interests, and legal compliance for the period necessary to fulfil the purposes outlined in this Statement.

(e) Modify your marketing subscriptions, including email subscription choices, via account settings.

(f) Unsubscribe from promotional messages, including from emails via any such email we send.

5. Third party accounts.

If you choose to log in to your account using a third party log-in (such as "log in with Google"), we may obtain personal information about you from such third party's authentication and social networking services ("SNS") to link your account with your third party account ("Third Party Account") by us either: (i) receiving your Third Party Account login information through the Services; or (ii) being allowed access to your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. We may receive from such third parties the following types of Personal Information:

• Google: Google ID, name, profile URL, email address.

We may also receive any other information you authorize us to access by authorizing the SNS to provide such information.

6. Links to Other Websites.

Our website and platform contains links to other websites. If you choose to click on a third party link, you will be directed to that third party's website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

7. Information on Children

Our Services are not intended for children, which we consider to be: (i) individuals that are 13 years of age or under, or the age of privacy consent in your jurisdiction; or (ii) when processing data on the basis of a contract, the age of legal capacity to enter into the agreement.

We do not knowingly collect any information at all from children. If you learn that a child has provided us with personal information in violation of this Privacy Statement, then you may alert us at [email protected].

8. Information Transfers

We offer our Services to users located in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

9. Information Security

We have implemented appropriate administrative, technical, and physical security procedures to help protect your information. We only authorize specific personnel to access personal information and they may do so only for permitted business functions. To the extent possible, we use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We may also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.

10. Information Deletion and Retention

We will retain copies of your information for as long as you maintain your account or subscription or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.

11. Information on Statement Changes

We may update this Statement in the future. If we believe any changes are material, we will strive to let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.

12. Contact

If you have a data privacy request, such as a request to delete or access your data, please contact [email protected]. For general data privacy inquiries or questions concerning our Privacy Statement, please contact [email protected].

13. Territory

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF AMERICA OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT THE LAW OF THE UNITED STATES OF AMERICA GOVERNS ANY SUCH COLLECTION AND PROCESSING.

If you are an individual and reside in the United Kingdom, the European Union, Switzerland, or elsewhere in the European Economic Area (collectively, and for the purposes of this Privacy Statement, the “EEA”), then the General Data Protection Regulation ("GDPR") shall apply to our practices regarding your “Personal Data” and you are considered a “Data Subject” as those terms are defined by the GDPR. For the purposes of the GDPR, we may act as both a data “Controller” and a data “Processor.” Similarly, if you are an individual and reside in California, the California Consumer Privacy Act (“CCPA”) shall apply to our practice regarding your “personal information”, and you are a “consumer”, with certain rights in your personal information and we are a “third party”, as those terms are defined in the CCPA. Personal Data, together with personal information, and all similar information shall be “Personal Information” for the purposes of this Privacy Statement. We will take commercially reasonable steps to maintain compliance with GDPR (including, without limitation, ensuring that all data processing agreements to which we are a party as subject to the appropriate Standard Contractual Clauses) and CCPA requirements.

14. ‘European Union’ Privacy Rights

A. If you currently reside in the EEA, the GDPR applies to your personal information. The GDPR requires that we have a legal basis to process your information and we will process such information under one or more of the following legal bases:

• To perform the contract that we are about to enter with you (e.g. our Terms of Service);

• Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

• To comply with a legal obligation; and/or

• If we have your consent to do so, which you may revoke at any time.

B. Under the GDPR, as a Data Subject you have certain rights. They are:

• The right to be informed. This is your right to be informed about what personal information we or our authorized vendors are processing, why, and who else the data may be passed to.

• The right of access. This is your right to see what personal data about you is held by us.

• The right to rectification. This is the right to have your personal data corrected or amended if what is held is incorrected in some way.

• The right to erasure. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.

• The right to restrict processing. This is the right to ask for a temporary halt to the processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.

• The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.

• The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.

• Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The service does not engage in automated decision making and profiling.

You can find instructions for enforcing some of these rights elsewhere in this Statement. Otherwise, if you wish to find out more about these rights, please contact us at [email protected].

15. California Privacy Rights

To the extent that the California Consumer Privacy Act (“CCPA “) applies to our practices with respect to personal information and you currently reside in California, the CCPA provides California consumers with certain rights.

A. Consumers Rights Under the CCPA

• California consumers have the right under the CCPA to request that we disclose personal information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information. In the previous 12 months, we have collected the following categories of personal information about consumers:

o Identifiers. “Identifiers” can be your name, unique personal identifiers (device identifier, IP Address, cookies, beacons, pixel tags, mobile ad identifiers), email, phone number, and similar information;

o Personal Information Under the California Customer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”), which is similar in nature to Identifiers;

o Commercial Information. Commercial information includes records of personal property, products or services purchased, obtained or considered, or other purchased or consuming histories or tendencies;

o Characteristics of Protected Classifications. This category includes race, national origin, age, and gender;

o Internet/Network Activity. Internet Activity Information includes browsing history, cookies, search history and a consumer’s interaction with a website; and

o Inferences drawn from any other category of personal information.

We collect personal information in the above categories only from you for the purposes described in this Statement, and as required to comply with applicable law.

As a California consumer, you also have the right to request that we tell you which of your personal information we have disclosed for a business purpose, or sold, in the previous 12 months. With respect to personal information being disclosed for a business purpose, the consumer shall receive the categories of information disclosed and the types of entities they have been disclosed to. This right may not be exercised more than twice in a 12-month period. For personal information being sold, this includes the categories of information being sold and the categories of third parties to whom it is being sold. In the past 12 months, we have disclosed personal information falling under the following categories of personal information:

• Identifiers;

• CCRLPI:

• Characteristics of Protected Classifications;

• Commercial Information; and

• Inferences drawn.

We disclose personal information in the preceding categories to the consumers themselves, to third parties as the consumer may direct, service providers, third parties that we have a business relationship with, potential/actual successors in interest, and government/law enforcement agencies for either the purpose it was provided/provision of Services, to comply with applicable law, or as otherwise described above in this Statement.

IN THE PAST 12 MONTHS WE HAVE NOT SOLD, AND DURING THE PERIOD OF TIME WHICH THIS STATEMENT IS POSTED WE SHALL NOT SELL, THE PERSONAL INFORMATION OF ANY CONSUMER, INCLUDING MINORS UNDER THE AGE OF 16.

Under the CCPA, California consumers have the following rights:

(a) The right to opt out of the processing, selling and sharing of information;

(b) The right to opt in (for minors)

(d) The right to non-discrimination in connection with your exercise of rights under CCPA;

(e) The right to stop us from disclosing your personal data to third parties;

(f) The right to know what personal data has been collected and is being held;

(g) The right to access personal data we have collected and stored;

(h) The right to correct errors in your personal data;

(i) The right to opt out of automated decision-making with respect to your personal data

(j) The right to limit the use of sensitive personal information; and

(k) The right to request deletion of personal data.

The full scope of these rights is set forth under the CCPA and court decisions and regulations interpreting them and may be limited in certain circumstances. For example, the right to deletion may be limited in situations where, for example, only, the data for which deletion is requested is necessary to be maintained for us to comply with applicable laws.

B. How Do you Exercise your rights under the CCPA?

Because we offer the Services exclusively online, you may submit your requests to exercise your rights under the CCPA by emailing us at [email protected] with “CCPA Request” in the subject line. When submitting a request via email, please indicate which CCPA right you wish to exercise and provide sufficient information to allow us to locate your file.

We will acknowledge receipt of your request within 10 business days of receiving it and will use commercially reasonable efforts to respond within 45 calendar days of receipt of your request, and in no event will our response come more than 90 days after receiving your request. If we are unable to provide our response within the first 45-day window, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.

Before we respond to any CCPA based requests relating to your personal information, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent. We do this to avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way. To do this, we will ask the Requestor to confirm at least two pieces of information that we have in our files. As the sensitivity of the information being requested goes up, we will ask the Requestor to confirm more pieces of information. For requests to delete information, after verification, we will confirm your desire to delete one final time before actually deleting the information. If the identity of the Requestor cannot be reasonably verified, then in order to protect you, we shall not disclose the personal information requested.

16. Florida Law

We endeavor to comply with the Florida Telemarketing Act and the Florida Do Not Call Act as applicable to Florida residents. For purposes of compliance, you agree that we may assume that you are a Florida resident if, at the time you sign up for an account, (a) your billing address, as provided is located in Florida or (b) the area code for the phone number used create an account is a Florida area code. You agree that the requirements of the Florida Telemarketing Act and the Florida Do Not Call Act do not apply to you, and you shall not assert that you are a Florida resident, if you do not meet either of these criteria or, in the alternative, do not affirmatively advise us in writing that you are a Florida resident by sending written notice to us. Insofar as you are a Florida resident, you agree that mobile messages sent by us in direct response to mobile messages or requests from you shall not constitute a “telephonic sales call” or “commercial telephone solicitation phone call” for purposes of Florida Statutes Section 501 (including but not limited to sections 501.059 and 501.616), to the extent the law is otherwise relevant and applicable.

17. Washington State Law

To the extent the law is relevant and applicable to the Services, we endeavor to comply with the commercial telephone solicitation requirements pursuant to the Revised Code of Washington (RCW) (including but not limited to sections 80.36.390, 19.158.040, 19.158.110 and 19.158) as applicable to State of Washington residents. For purposes of compliance, you agree that we may assume that you are a State of Washington resident if, at the time you create an account with us, the area code for the phone number used to create an account on our Site is a State of Washington area code.

18. Multi-State Privacy Statement for Virginia, Connecticut and Colorado

This Multi-State Privacy Statement is provided pursuant to applicable state laws and applies to Virginia, Connecticut, and Colorado residents, and supplements our overall Statement with additional disclosures and rights.

If you are a resident of Virginia, Connecticut, or Colorado you may take advantage of the following rights in accordance with applicable law:

(a) You can request to confirm whether we process your personal information. Subject to certain exceptions, you can also request a copy of your personal information you provided to us.

(b) You can request that we delete personal information we have about you.

(d) You can request to opt out of the sale of your personal information to a third party.

(e) We may display advertisements to you where the ad was selected based on personal information obtained from (or in some instances inferred) from your activities over time and across unaffiliated websites or online applications to predict your preferences or interests. To the extent permitted by law, you can request that we stop using your personal information for such targeted advertising by contacting [email protected].

To take advantage of any of these rights, please contact us here [email protected]. Note that Connecticut and Colorado residents may designate an authorized agent to request on their behalf that we stop selling or processing their personal information for targeted advertising purposes. We will take reasonable steps to authenticate your identity prior to responding to your requests. The authentication process will vary depending on the sensitivity of the personal information and whether you have an account with us. We will use commercially reasonable efforts to authenticate the identity of authorized agents and their authority to submit requests on your behalf.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.

If you have any questions about this Statement or any other applicable terms, policies or agreements related thereto, please contact us at [email protected].