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PRIVACY

Effective: May 9, 2022

1. INTRODUCTION

People.ai is committed to respecting and protecting your privacy. This privacy
policy (“Privacy Policy”) is intended to help you understand what data we
collect, what we do with it, how we protect it, and what choices you have with
regard to our collection and processing of your data through your use of our
services (the “Services”) through the People.ai website https://people.ai (the
“Website”), and the People.ai application https://app.people.ai (the “App”)
(collectively referred to as the “Sites”). By using the Services, visiting the
Website, or using the App, you consent to the collection, transfer, processing,
storage, disclosure, and other uses described in this Privacy Policy.

2. TYPES OF INDIVIDUALS

This Privacy Policy details our commitment to the privacy of individuals who
are:

 1. Site Visitors – those who visit the Sites or individuals who request us to
    contact them via our online web forms or email;
 2. Registered Users – those who are users of the Services via their employer’s
    (our customer) subscription to the Services or visit the App;
 3. Identifiable Individuals – those whose information is collected for the
    purpose of providing our data management services to our customers, which is
    described further, below; and,
 4. Attendees – those who attend or register to attend events sponsored by
    People.ai or in which People.ai participates. 

Collectively, we refer to the individuals, above, as collectively as “Users.” An
individual may fall into more than one category of individual. For example, an
individual may attend one of our sponsored events and be classified as an
Attendee, and then a Site Visitor when visiting the Sites. 

The terms “People.ai,” “we,” “us,” and “our” refer to People.ai, Inc. 

3. SCOPE

This Privacy Policy applies to the Website, the App, and all subpages and
successor pages found within their respective domains. The Privacy Policy
applies to data that relates to the Personal Information (defined below) of the
Users and the Customer Activity Data (defined below) of our Customers. The data
may be collected through use of the Services; visiting the Sites; or
communicating with People.ai through email, chat, or other channel. 

The Privacy Policy does not apply to de-identified or aggregated Personal
Information or data lawfully made available from federal, state, or local
records. De-identified or aggregated data is data that does not personally
identify you. An example would be, how many users have a certain postal code.
The Privacy Policy does not apply to any third party website, which may be
linked to from the Sites. The information collected through these third party
websites are governed by the privacy policies of the respective third party
websites. Please refer to your individual contracts for specifics on our data
retention and deletion policy.

4. WHAT DATA WE COLLECT

4.1. Information you provide to us

When you visit our Sites or contact us, we might collect Personal Information
that you voluntarily submit to us, such as through a web form, in an email, in a
chat message, or other form of electronic communication. Personal Information
collected in this way includes identifiers, such as your name, business address,
email address, similar identifiers, commercial information, and professional or
employment-related information relevant to you as an agent of your business. 

4.2. Information from web technologies

When Site Visitors and Registered Users visit our Sites or use our Services
various web technologies may collect information in relation to your use of the
Sites. For example, we may collect browser information, device data, logs, IP
addresses, the page of the Sites you request, the date and time of the request,
and the time spent on the Sites or page. 

The Additional Information Link

Some of the pages on the Sites may contain “cookies.” A cookie is a small data
file that may be sent to your web browser and stored on your computer. This
allows our server to recognize a computer when it revisits the Sites. The
cookies also help People.ai analyze trends, track user movement in the site, and
gather demographic information about our users as a whole. 

Most web browsers can be configured to not accept cookies, or to notify you if a
cookie is sent to you. You may also consider visiting aboutcookies.org, which
provides helpful information about cookies. You can choose to disable cookies
for the Sites but, blocking cookies may prevent or reduce the extent to which
the Sites or Services can be used or customized by you. Please note that opting
out of receiving cookies may not exercise your other data rights. 

Some pages of the Sites (and our e-mails) may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit us, for example, to count users that visited
those pages or opened an email and for other related website statistics (for
example, recording the popularity of certain website content and verifying
system and server integrity).

These web technologies may identify a device (e.g., your computer) without
identifying you individually. In many instances it is not possible for us to tie
together information collected about Site Visitors to an Identifiable
Individual, Attendee, or Registered User. Accordingly, adjusting your browser
settings to refuse cookies may not exercise your opt-out or other rights (to the
extent they apply to your jurisdiction) with respect to the information we
collect about you as an Identifiable Individual. Exercising your rights as an
Identifiable Individual, Attendee, or Registered User you may be required to
provide additional information, as described below. 

4.3. Information from Services

People.ai collects information and data for the purpose of creating our graph
database and providing the Services. We collect information and data to help us
compile, organize, and verify this information. The collected information can
include:

 1. Customer Activity Data – activity data (e.g., email, calendar, and phone
    data, address book data, customer relationship management (“CRM”) data,
    etc.) of Customer activity collected through access to the Customer’s third
    party services on behalf of the Customer. People.ai never receives or stores
    user credentials (i.e., passwords) for these third party services. People.ai
    relies on federated authentication protocols and tokens. 
 2. Personal Information (“PI”) – any information which can reasonably be used
    to identify an individual, and may include, but is not limited to, name,
    email address, telephone number, postal or other physical address, title, or
    occupation. It may also include IP addresses or other telemetry data
    necessary to run the Website or App. Customer Activity Data may include
    Personal Information of Identifiable Individuals, Registered Users, and
    Attendees. We endeavor to limit our requests for and collection of Personal
    Information to information we believe is reasonably necessary to achieve our
    purposes, or is necessary for the providing the Services.
 3. Publicly Available PI – we may collect, directly or indirectly, Personal
    Information from publicly accessible online sources. Publically Available PI
    may be collected by a third party and then provided to People.ai.
 4. Licensed PI – we may collect Personal Information through licensing
    agreements directly with data brokers or other Companies, pursuant to their
    privacy policies and terms and conditions.

5. HOW WE USE YOUR INFORMATION

5.1. General use of your information

We may use the information we collect about you to perform our obligations under
our End User Service Agreement (“EUSA”) with our Customers on the basis of our
legitimate interest including to provide, operate, maintain, improve, and
promote the Sites and the Services. We also use the collected information to
provide you with information that you may request from us, to notify you about
updates to the Privacy Policy, or for any other purpose described when you
provide the information. 

6. DATA SHARING & DISCLOSURE

We may disclose Customer Activity Data, which may include Personal Information,
to other companies or third parties under any of the following circumstances:

6.1. Customers and Partners

We use Personal Information to provide the Services to our customers and
partners.

6.2. Sub-processors (Third-Party Service Providers)

We may transfer information, including Personal Information, to our
sub-processors, which we use to provide our services. These sub-processors may
have access to or process your Personal Information for the purpose of providing
these services for us (and in turn, you). We prohibit our sub-processors to use
any Personal Information for their marketing purposes or for any other purpose
than in connection with the services they provide to us.

6.3. As Required by Law

In certain situations, we may be required to disclose Personal Information in
response to lawful requests by public authorities, including to meet national
security or law enforcement requirements. We may disclose Personal Information
to respond to subpoenas, court orders, or legal process, or to establish or
exercise our legal rights or defend against legal claims. We may also share such
information if we believe it is necessary to investigate, prevent, or take
action regarding illegal activities, suspected fraud, situations involving
potential threats to the physical safety of any person, violations of our
Service Agreement, or as otherwise required by law. To enforce the terms of an
EUSA, prevent fraud or abuse of People.ai or its users, or to protect
People.ai’s rights.

6.4. To Market Our Services:

We may share information, including Personal Information, with our channel
partners, solely for the purpose of enabling our channel partners to notify you
about our Services. People.ai requires its channel partners to provide an
opt-out option within its communications to you. By opting out, you are opting
out of receiving future communication from our channel partner.

7. INTERNATIONAL TRANSFERS

Personal Information collected on the Sites will be stored and processed in the
United States, or in other countries if specifically agreed upon in an
applicable EUSA, and by using the Sites, you consent to any such transfer of
information outside of your country. Please note, we may transfer the Customer
Data we collect about you to countries other than the country where we
originally collected it for the purposes processing the data and operating the
Services. If we transfer your information to outside of the country of
collection, we will protect that information as described in this Privacy Policy
and take steps, where necessary, to ensure that international transfers comply
with applicable laws.

8. CHILDREN’S PERSONAL INFORMATION

Our Services are not intended for or directed to persons under the age of 13.
Accordingly, we do not knowingly collect Personal Information from children
under the age of 13. If you are under the age of 13, do not submit any Personal
Information to us via email, the Sites, through our Services, or through other
channels. Any person who provides information to us through registration or in
any other manner on the Sites or through the Services represents to People.ai
that they are 13 years of age or older. If you believe that we have mistakenly
collected such information, please notify us at security@people.ai so that we
may immediately delete the information.

9. ADDITIONAL INFORMATION PER USER TYPE

9.1. Site Visitors

We may collect data on how you use the Sites, to improve the Sites and the
Services. This may include the ability to reproduce your actions on the Sites,
your IP address, your browser and device characteristics, and other such data,
for the purpose of Sites and Service improvement. 

We may collect Personal Information from you if you choose to contact us through
the Sites.

9.2. Registered Users

Our Services are intended for use by enterprise companies. Where our Services
are made available to you, a Registered User, through a Customer of ours, that
enterprise is the data controller of your personal information. Your data
privacy questions and requests should initially be submitted to the Customer in
its capacity as your data controller. People.ai is not responsible for our
Customers’ privacy or security practices which may be different than this
Privacy Policy.

Where we are the data controller of Personal Information (for example, for Site
Visitors and Attendees), then we retain the Personal Information we collect
where we have an ongoing legitimate business need or purpose to do so. (For
example, providing you with our Services, to enable your participation in an
event, and to comply with applicable legal, tax or accounting requirements, is a
legitimate purpose.)

9.3. Attendees

We ask for and may collect personal information such as your name, address,
phone number, commercial information, and email address when you register for or
attend a sponsored event or other events at which any member of the People.ai
participates. We collect this information to facilitate your registration or
attendance of the event and to send you related or followup communications. 

10. YOUR DATA RIGHTS

10.1. Cookies and Similar Technologies. 

Your browser or device can allow you to opt-out of data collection from cookies
or similar technologies by setting your browser to refuse all or some of the web
technologies (e.g., cookies) employed on the Sites. Please note that your
experience using the Sites or the Services might be degraded, or certain
functionalities may not work, if you opt-out to such collection.

10.2. Marketing Communications

If you wish to opt-out of our use of your contact information for our direct
marketing purposes, you can click the “Unsubscribe” button located within the
most recent marketing email you received from us, or contact us at
privacy@people.ai. You may also use the DO NOT SELL MY INFO button on the bottom
of each page.

10.3. Opt-Out Rights

Depending on where you are located, you may have additional rights to opt-out of
certain uses of Personal Information, know what Personal Information we’ve
collected, or request that we delete your Personal Information. Please review
the JURISDICTION SPECIFIC NOTICES, below, to determine if these rights apply to
you. 

11. JURISDICTION SPECIFIC NOTICES

People.ai is based in the United States. The Sites and Services are controlled
and operated by us from the United States and are not intended to subject us to
the laws or jurisdiction of any state, country or territory other than that of
the United States. Your Personal Information may be collected, transferred to,
stored and otherwise processed in any country where we have facilities or in
which we engage service providers, and by using the Sites and/or Services you
consent to the transfer of information to countries outside of your country of
residence, including the United States, which may have data protection rules
that are different from those of your country.

You may be entitled to additional privacy notices depending on where you are
located. Please see the appropriate subsection below that may apply to you.

11.1. California

The California Consumer Privacy Act (“CCPA”), which is effective as of January
1, 2020, regulates how we handle personal information of California residents
and gives California residents certain rights with respect to their personal
information.

Under the CCPA, People.ai is both a “business” and a “service provider.” This
subsection applies to information we collect in our role as a business. When we
act as a service provider for our Customers (for example, by providing our
services to another company that you interact with), we follow the processing
instructions of our Customer with respect to how we process your personal
information. 

11.1.1. Information We May Collect

Identifiers Identifiers such as a real name, alias, postal address, unique
personal identifier, online identifier, internet protocol address, email
address, account name, or other similar identifiers. California Customer Record
Information Identifiers such as name, address, telephone number, employment,
employment history. Internet or other electronic network activity information
Internet or other electronic network activity information, information regarding
a consumer’s interaction with an internet website, application, or
advertisement. Geolocation data City, state, country, time zone, or the city in
which an employer’s company is located. Professional or employment-related
information Job title, employer name, role, or industry. Inferences Inferences
drawn from any of the information identified in this subdivision to create a
profile about a consumer.

Please note that under the CCPA, Personal Information does not include:

 1. publicly available information; 
 2. deidentified or aggregated consumer information; or 
 3. information otherwise excluded from the scope of the CCPA.

For each of the categories of information, above, we collect the information
from a variety of sources, including directly from you, from your devices, from
your social media profiles, from our Customers, and/or from third party
providers. 

11.1.2. Use of Personal Information

We collect this Personal Information to provide the Services; to protect the
rights, privacy, and safety of the Users and Services; and to improve the
Services. For example, in the last 12 months, People.ai used Personal
Information for one or more of the following purposes:

 * To provide our Services to our Customers; 
 * To build and maintain your network of contacts;
 * To improve or modify the Services or develop new products;
 * To send you administrative information about your account, such as upgrade
   notifications, billing notices, etc.;
 * To communicate with you and provide you with any relevant customer service;
 * To present products and offers, which we believe you would enhance your use
   of the Sites. (You may unsubscribe from these types of communications at any
   time;)
 * To conduct research about People.ai or our products and services;
 * For billing and account services;
 * For data analysis such as audits and fraud prevention;
 * As required by applicable law;
 * To enforce our terms and conditions;
 * To protect the rights, privacy, or safety of People.ai or others; or
 * To otherwise operate and support the Sites.

11.1.2. Disclosure for a Business Purpose

People.ai may disclose your personal information to a third party for a business
purpose. When we disclose Personal Information for a business purpose to a third
party, the third party must keep the Personal Information confidential and not
use the Personal Information for any other purpose except the purpose for which
we provided the Personal information to the third party. 

In the 12 months prior to this Privacy Policy’s last update we’ve provided the
following categories of Personal Information: identifiers, internet or other
electronic network activity information, and geolocation data to our service
providers. Our service providers provide services such as web hosting, backend
infrastructure, log analysis, customer service, email and web services, security
and other auditing, advertising or marketing, and similar services.

11.1.3. Disclosure for a Commercial Purpose

The CCPA broadly defines selling Personal Information as “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.” In light of
this broad definition, many types of data transfers are considered a “sale”
under the CCPA. In the past 12 months, we’ve disclosed Personal Information from
the following categories in a manner that may be considered a sale under the
CCPA: identifiers; record information; internet or other electronic network
activity information; geolocation data; professional or employment-related
information; and inferences. As described below, you can opt-out of our “sale”
of your Personal Information. 

11.1.4. Your Rights Under the CCPA

The CCPA provides individual California consumers with several individual rights
with respect to Personal Information. Under the CCPA, a California consumer has
the right to request:

 * The disclosure of the categories of personal information we collected about
   you.
 * The disclosure of the categories of sources for the personal information we
   collected about you.
 * The disclosure of the specific pieces of personal information we collected
   about you. 
 * The disclosure of the personal information categories that each category of
   recipient received for valuable consideration; 
 * The disclosure of the personal information categories that each category of
   recipient obtained for a business purpose;
 * The deletion of your Personal Information, subject to certain limitations
   under the CCPA; and
 * The right not to be discriminated against for exercising certain rights under
   California law.

11.1.5. Right to Opt-Out of Sales of Personal Information

You have the right to direct us not to sell your Personal Information on a
going-forward basis. Please click the DO NOT SELL MY INFO link, which can also
be found in the footer of our homepage.

11.1.6. Exercising your rights

To exercise these rights, please submit a request to one of our contact options:

 * Calling us at +1 (888) 997-3675‬; 
 * Filing out the request webform; or, 
 * Emailing privacy@people.ai

Please be as specific as possible in relation to which right you would like to
exercise. The requests can only be granted for a  verifiable customer request.
Please provide sufficient information about yourself so we can confirm that your
request is a verifiable customer request, including at a minimum your name and
email address. Once we receive your request, we will review it, determine
whether we can verify your identity, and process the request accordingly. We
will respond to your request within 45 days of receipt, or notify you if we
require additional time. We will not respond to requests that do not include at
least your name and email address. We will provide you with the Personal
Information in a usable format that allows you to transmit the Personal
Information to another entity.

You may also designate an authorized agent to make a request on your behalf. In
order for us to process a request from your authorized agent, we must (i)
confirm that the agent is a natural person or business entity registered with
the Secretary of State that you have authorized to act on your behalf, (ii)
receive from you a copy of the written authorization that provides the
authorized agent to act on your behalf, and (iii) verify your identity by asking
you to provide us sufficient information in order to do so.

You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. Any disclosures we provide will only cover the
12-month period preceding the verifiable consumer request’s receipt. 

We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.

11.1.7. Non-Discrimination for exercising your rights

You have the right not to receive discriminatory treatment for the exercise of
your rights under the CCPA, subject to certain limitations. Please note that we
reserve the right to offer you certain financial incentives as permitted by the
CCPA that may result in different prices, rates, or quality levels. Any
CCPA-permitted financial incentive we offer will reasonably relate to your
personal information’s value and contain written terms that describe the
program’s material aspects. Participation in a financial incentive program
requires your prior opt-in consent, which you may revoke at any time by
contacting us.

12. DATA SECURITY

To ensure appropriate levels of security People.ai applies technical,
administrative and organizational security measures to prevent against
accidental or unlawful destruction and loss, alteration, unauthorized disclosure
or access, in particular where the processing involves the transmission of data
over a network, and against other unlawful forms of processing. People.ai has
undergone a Service Organization Control 2 (“SOC”) audit, and a copy of
People.ai’s most recent report is available to Customers upon request from
security@people.ai. As of the date of this Privacy Policy, the environment which
hosts People.ai’s Services maintains multiple certifications for its data
centers, including SOC reports, PCI Certification, and ISO 27001 compliance.
Please visit the AWS Compliance website at https://aws.amazon.com/compliance/
for further information.

13. CHANGES TO THIS PRIVACY NOTICE

Changes to this Privacy Policy may be made from time to time and will be posted
on this page as legal, regulatory, or operational requirements change. If we
make material changes to People.ai’s Privacy Policy, we will provide notice on
the Sites or via email. However, we encourage you to periodically review this
page for the latest information on our privacy practices. If you continue to use
the Services, after those changes are in effect, you agree to the revised
Privacy Policy.

14. GOOGLE API COMPLIANCE

People.ai’s use and transfer to any other app of information received from
Google APIs will adhere to Google API Services User Data Policy, including the
Limited Use requirements.

15. CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy
practices, please don’t hesitate to contact support@people.ai, or subscribe
below for updates.

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Email: Mail: privacy@people.ai People.ai, Inc. 548 Market St,
# 58279
San Francisco,
CA- 94104-5401

Last Updated Date: May 9, 2022

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