PRIVACY NOTICE
Last updated December 27, 2021

Thank you for choosing to be part of our community at Chirpley BV ("Company," "we," "us," or "our").
We are committed to protecting your personal information and your right to privacy. If you have any
questions or concerns about this privacy notice or our practices with regard to your personal
information, please contact us at hello@chirpley.ai.
This privacy notice describes how we might use your information if you:1.
Visit our website at https://chirpley.ai
2.
Engage with us in other related ways ― including any sales, marketing, or events
In this privacy notice, if we refer to:1.
"Website," we are referring to any website of ours that references or links to this policy.
2.
"Services," we are referring to our Website, and other related services, including any sales,
marketing, or events.
The purpose of this privacy notice is to explain to you in the clearest way possible what information wecollect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy
notice that you do not agree with, please discontinue use of our Services immediately. Please read thisprivacy notice carefully, as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when you register on the Website,
express an interest in obtaining information about us or our products and Services, when you
participate in activities on the Website (such as by posting messages in our online forums or entering
competitions, contests or giveaways) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and theWebsite, the choices you make and the products and features you use. The personal information wecollect may include the following:
Personal Information Provided by You. We collect names; email addresses; usernames; passwords;
contact preferences; contact or authentication data; hobbies; work position; country; city; social-media
niches; social-media platforms; date of birth; personal interest; online identifiers; internet activity;
photos; geolocation information; physical information; cultural information; social identity; education
information; and other similar information.
Payment Data. We may collect data necessary to process your payment if you make purchases, suchas your payment instrument number (such as a credit card number), and the security code associatedwith your payment instrument. All payment data is stored by __________. You may find their privacy
notice link(s) here: __________.
Social Media Login Data. We may provide you with the option to register with us using your existingsocial media account details, like your Facebook, Twitter or other social media account. If you choose
to register in this way, we will collect the information described in the section called "HOW DO WE
HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true, complete and accurate, and you must
notify us of any changes to such personal information.

Information automatically collected
Some information, such as your Internet Protocol (IP) address and/or browser and device
characteristics, is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country, location, information
about how and when you use our Website and other technical information. This information is primarily
needed to maintain the security and operation of our Website, and for our internal analytics andreporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The
information we collect includes Log and Usage Data. Log and usage data is service-related, diagnostic,
usage and performance information our servers automatically collect when you access or use ourWebsite and which we record in log files. Depending on how you interact with us, this log data may
include your IP address, device information, browser type and settings and information about youractivity in the Website (such as the date/time stamps associated with your usage, pages and files
viewed, searches and other actions you take such as which features you use), device event information(such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

2. HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfillment of ourcontract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described
below. We process your personal information for these purposes in reliance on our legitimate businessinterests, in order to enter into or perform a contract with you, with your consent, and/or for compliancewith our legal obligations. We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the information we collect or receive: To facilitate account creation and logon process. If you
choose to link your account with us to a third-party account (such as your Google or Facebook
account), we use the information you allowed us to collect from those third parties to facilitate accountcreation and logon process for the performance of the contract. See the section below headed "HOWDO WE HANDLE YOUR SOCIAL LOGINS?" for further information.
1.

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To post testimonials. We post testimonials on our Website that may contain personal information.
Prior to posting a testimonial, we will obtain your consent to use your name and the content of thetestimonial. If you wish to update, or delete your testimonial, please contact us at hello@chirpley.ai
and be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about
your use of our Website.
To enable user-to-user communications. We may use your information in order to enableuser-to-user communications with each user's consent.
To manage user accounts. We may use your information for the purposes of managing our
account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you
product, service and new feature information and/or information about changes to our terms,
conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Website
safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal andregulatory requirements or in connection with our contract.

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To respond to legal requests and prevent harm. If we receive a subpoena or other legal request,
we may need to inspect the data we hold to determine how to respond.
Fulfill and manage your orders. We may use your information to fulfill and manage your orders,payments, returns, and exchanges made through the Website.
Administer prize draws and competitions. We may use your information to administer prize draws
and competitions when you elect to participate in our competitions.
To deliver and facilitate delivery of services to the user. We may use your information to provide
you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to
your inquiries and solve any potential issues you might have with the use of our Services.
To send you marketing and promotional communications. We and/or our third-party marketing
partners may use the personal information you send to us for our marketing purposes, if this is inaccordance with your marketing preferences. For example, when expressing an interest in
obtaining information about us or our Website, subscribing to marketing or otherwise contacting
us, we will collect personal information from you. You can opt-out of our marketing emails at any
time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
Deliver targeted advertising to you. We may use your information to develop and display
personalized content and advertising (and work with third parties who do so) tailored to yourinterests and/or location and to measure its effectiveness.
For other business purposes. We may use your information for other business purposes, such asdata analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Website, products, marketing and your experience.
We may use and store this information in aggregated and anonymized form so that it is not
associated with individual end users and does not include personal information.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, toprotect your rights, or to fulfill business obligations. We may process or share your data that we holdbased on the following legal basis:
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Consent: We may process your data if you have given us specific consent to use your personal
information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve ourlegitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process yourpersonal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so inorder to comply with applicable law, governmental requests, a judicial proceeding, court order, or
legal process, such as in response to a court order or a subpoena (including in response to publicauthorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate,
prevent, or take action regarding potential violations of our policies, suspected fraud, situations

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9.

involving potential threats to the safety of any person and illegal activities, or as evidence inlitigation in which we are involved.
More specifically, we may need to process your data or share your personal information in thefollowing situations:
Business Transfers. We may share or transfer your information in connection with, or duringnegotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data withthird-party vendors, service providers, contractors or agents who perform services for us or on
our behalf and require access to such information to do that work. Examples include: payment
processing, data analysis, email delivery, hosting services, customer service and marketing
efforts. We may allow selected third parties to use tracking technology on the Website, which will
enable them to collect data on our behalf about how you interact with our Website over time. This
information may be used to, among other things, analyze and track data, determine the popularityof certain content, pages or features, and better understand online activity. Unless described inthis notice, we do not share, sell, rent or trade any of your information with third parties for theirpromotional purposes. We have contracts in place with our data processors, which are designed
to help safeguard your personal information. This means that they cannot do anything with yourpersonal information unless we have instructed them to do it. They will also not share yourpersonal information with any organization apart from us. They also commit to protect the data
they hold on our behalf and to retain it for the period we instruct.
Other Users. When you share personal information (for example, by posting comments,
contributions or other content to the Website) or otherwise interact with public areas of theWebsite, such personal information may be viewed by all users and may be publicly madeavailable outside the Website in perpetuity. If you interact with other users of our Website andregister for our Website through a social network (such as Facebook), your contacts on the social
network will see your name, profile photo, and descriptions of your activity. Similarly, other users
will be able to view descriptions of your activity, communicate with you within our Website, andview your profile.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We only share information with the following categories of third parties. If we have processed your data
based on your consent and you wish to revoke your consent, please contact us using the contact
details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
1.
2.
3.
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6.

Ad Networks
Social Networks
Sales & Marketing Tools
Data Storage Service Providers
User Account Registration & Authentication Services
Website Hosting Service Providers

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
If you choose to register or log in to our services using a social media account, we may have access tocertain information about you.
Our Website offers you the ability to register and login using your third-party social media accountdetails (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information we receive may varydepending on the social media provider concerned, but will often include your name, email address,
friends list, profile picture as well as other information you choose to make public on such social media
platform.
We will use the information we receive only for the purposes that are described in this privacy notice orthat are otherwise made clear to you on the relevant Website. Please note that we do not control, andare not responsible for, other uses of your personal information by your third-party social media
provider. We recommend that you review their privacy notice to understand how they collect, use andshare your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice
unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in thisprivacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting
or other legal requirements). No purpose in this notice will require us keeping your personal information
for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store your personal informationand isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organizational and technical security
measures.
We have implemented appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, despite our safeguards and efforts tosecure your information, no electronic transmission over the Internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly
collect, access, steal, or modify your information. Although we will do our best to protect your personal
information, transmission of personal information to and from our Website is at your own risk. You
should only access the Website within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rightsthat allow you greater access to and control over your personal information. You may review, change, or
terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) torequest rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have the right to object to theprocessing of your personal information. To make such a request, please use the contact details
provided below. We will consider and act upon any request in accordance with applicable dataprotection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw
your consent at any time. Please note however that this will not affect the lawfulness of the processing
before its withdrawal, nor will it affect the processing of your personal information conducted in relianceon lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory authority. If
you are a resident in Switzerland, the contact details for the data protection authorities are available
here. If you have questions or comments about your privacy rights, you may email us at
hello@chirpley.aiAccount Information
If you would at any time like to review or change the information in your account or terminate youraccount, you can:1.
2.

Log in to your account settings and update your user account.
Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and informationfrom our active databases. However, we may retain some information in our files to prevent fraud,
troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply withapplicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you
choose to remove cookies or reject cookies, this could affect certain features or services of ourWebsite. To opt-out of interest-based advertising by advertisers on our Website visit
http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking
on the unsubscribe link in the emails that we send or by contacting us using the details provided below.
You will then be removed from the marketing email list — however, we may still communicate with you,for example to send you service-related emails that are necessary for the administration and use of youraccount, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out,
you may access your account settings and update your preferences.

10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to havedata about your online browsing activities monitored and collected. At this stage no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically communicates your choice
not to be tracked online. If a standard for online tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal
information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who
are California residents to request and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared personal information in theimmediately preceding calendar year. If you are a California resident and would like to make such arequest, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website,
you have the right to request removal of unwanted data that you publicly post on the Website. To
request removal of such data, please contact us using the contact information provided below, andinclude the email address associated with your account and a statement that you reside in California.
We will make sure the data is not publicly displayed on the Website, but please be aware that the data
may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:1.
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Every individual who is in the State of California for other than a temporary or transitory purpose;andEvery individual who is domiciled in the State of California who is outside the State of California
for a temporary or transitory purpose.

All other individuals are defined as "non-residents". If this definition of "resident" applies to you, wemust adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category

ExamplesCollected

A. IdentifiersContact details, such as real name, alias,
postal address, telephone or mobile contact
number, unique personal identifier, online
identifier, Internet Protocol address, email
address and account nameYes

Name, contact information, education,
employment, employment history and financial
information

Yes

B. Personal information
categories listed in the
California Customer
Records statuteC. Protected classification
characteristics under
California or federal law

Gender and date of birth

D. Commercial information

Transaction information, purchase history,financial details and payment information

E. Biometric information

Fingerprints and voiceprints

F. Internet or other similar
network activity

Browsing history, search history, online
behavior, interest data, and interactions with
our and other websites, applications, systems
and advertisements

G. Geolocation data

Device location

Yes

No

No

Yes

Yes

H. Audio, electronic, visual,thermal, olfactory, or
similar information

Images and audio, video or call recordings
created in connection with our businessactivities

I. Professional or
employment-related
information

Business contact details in order to provide you
our services at a business level, job title as well
as work history and professional qualifications
if you apply for a job with us

J. Education Information

Student records and directory information

Yes

Yes

Yes

K. Inferences drawn fromother personal information

Inferences drawn from any of the collected
personal information listed above to create aprofile or summary about, for example, anindividual’s preferences and characteristics

Yes

We may also collect other personal information outside of these categories instances where you interact
with us in-person, online, or by phone or mail in the context of:1.
2.

Receiving help through our customer support channels;
Participation in customer surveys or contests; and3.

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?
Chirpley BV collects and shares your personal information through:
1.
2.
3.

Targeting cookies/Marketing cookies
Social media cookies
Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at hello@chirpley.ai, or by referring to the contact details at the bottom of
this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if theauthorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit entity that processes theinformation on our behalf. We may use your personal information for our own business purposes, suchas for undertaking internal research for technological development and demonstration. This is notconsidered to be "selling" of your personal data.
Chirpley BV has disclosed the following categories of personal information to third parties for abusiness or commercial purpose in the preceding twelve (12) months:●

Category B: Personal information, as defined in the California Customer Records law, such as
your name, contact information, education, employment, employment history and financial
information.

The categories of third parties to whom we disclosed personal information for a business or commercial
purpose can be found under "WHO WILL YOUR INFORMATION BE SHARED WITH?".
Chirpley BV has not sold any personal information to third parties for a business or commercial purposein the preceding twelve (12) months. Chirpley BV will not sell personal information in the future
belonging to website visitors, users and other consumers.

Your rights with respect to your personal data
Right to request deletion of the data (request to delete) — You can ask for the deletion of your personal
information. If you ask us to delete your personal information, we will respect your request and delete
your personal information, subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance requirements resulting
from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed ( Request to know ) — Depending on the circumstances, you have a right to know:
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Whether we collect and use your personal information;
The categories of personal information that we collect;
The purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
The categories of personal information that we sold or disclosed for a business purpose;
The categories of third parties to whom the personal information was sold or disclosed for abusiness purpose; andThe business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer informationthat is de-identified in response to a consumer request or to re-identify individual data to verify aconsumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.

Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person
about whom we have the information in our system. These verification efforts require us to ask you toprovide information so that we can match it with information you have previously provided us. For
instance, depending on the type of request you submit, we may ask you to provide certain information
so that we can match the information you provide with the information we already have on file, or wemay contact you through a communication method (e.g. phone or email) that you have previously
provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority tomake the request. To the extent possible, we will avoid requesting additional information from you forthe purposes of verification. If, however, we cannot verify your identity from the information alreadymaintained by us, we may request that you provide additional information for the purposes of verifying
your identity, and for security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.

Other privacy rights:
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4.

5.

You may object to the processing of your personal data.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to
restrict the processing of the data.
You can designate an authorized agent to make a request under the CCPA on your behalf. We
may deny a request from an authorized agent that does not submit proof that they have beenvalidly authorized to act on your behalf in accordance with the CCPA.
You may request to opt-out from future selling of your personal information to third parties. Upon
receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but nolater than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at hello@chirpley.ai, or by referring to thecontact details at the bottom of this document. If you have a complaint about how we handle yourdata, we would like to hear from you.

12. DO WE MAKE UPDATES TO THIS NOTICE?
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an
updated "Revised" date and the updated version will be effective as soon as it is accessible. If we makematerial changes to this privacy notice, we may notify you either by prominently posting a notice ofsuch changes or by directly sending you a notification. We encourage you to review this privacy noticefrequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at hello@chirpley.ai or by postto:Chirpley B.V.
De Donge 19, 5684 PX Best, Netherlands
Best, Noord-Brabant 5684 PX,
Netherlands

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it in some circumstances. To request
to review, update, or delete your personal information, please submit a request form by clicking here.