Chorus AI Inc. Website Privacy Policy

Section 1. Purpose

Chorus AI Inc. and our affiliates and subsidiaries (collectively, “Chorus AI” or “we”) respect and protect the privacy of our users and customers. The following practices govern how we collect, use, share, and protect the information you provide to us through our websites (“Site”) and other information we might collect about you and the choices you have regarding our collection and use of your information.

Section 2: Scope

This Privacy Policy (“Policy”) explains how we process information that we collect from users of our website www.chorusai.co and on any other websites, mobile applications, or other online services that display or link to this Policy (together, the “Site”), as well as from our former, current, and prospective customers and other individuals that use our products and services or communicate with us. Please note, that this Policy only applies to us but not to any third-party websites that may process, share, or distribute your personal information or other information.

Our collection, use, and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information.

Personal Information. In this Policy, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual.

Not Covered by this Policy. This Policy does not apply to job applicants and candidates who apply for employment or to employees and non-employee workers, whose personal information is subject to different privacy notices.

Customer Data. Chorus AI provides digital experience services in the areas of creative and content ideation, development, and management; data consulting; digital marketing campaign management and consulting; access and management of third-party technology services, and other related services (our “Services”). We may receive, access, or otherwise process personal information in order to provide our Services (the “Customer Data”) to customers. In such cases, Chorus AI will only process Customer Data on behalf of and under the instructions of our customers and as set out in our customer agreements, or where otherwise required by applicable laws.

Controller or Responsible Party. With respect to Customer Data, the customer that provides a specific dataset is the controller with respect to that dataset, and we are the data processor. For other data, Chorus AI is the data controller.

Section 3. Personal Information We Collect

The types of Personal Information we might collect about you when you use our Site or otherwise interact or engage with Chorus AI or through other channels could include the following:

• Identifiers: Information that identifies you directly or could be used to identify you.
  • Examples: Full name, email address, social media account information, phone number, job title and description, company name, customer account information, IP address, and other data that identifies or could identify your online activity.
• Commercial Information: Information related to purchases that you or your company might make in connection with our services.
  • Examples: Purchase history, products considered.
• Online Activity: Limited information about your use of the internet collected via web analytics. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the Services of visit our Site.
  • Examples: Browsing and/or search history regarding sites visited before or after visiting our Site, the type of operating system used to connect to our Site, interactions with our services or our advertisements, browser type, Internet service provider, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and your preferences when you use the Site.
• Geo-IP Information: Information about where your computer or device is approximately located (at the city or state level) when you use the Site.
• Inferences: Information we can determine or estimate about you based on information we collect about you.
  • Examples: Purchase preferences, potential future purchase behavior.
• User-Generated Content: Information you post on the Site or your communications to us.
  • Examples: Comments or reviews about Service.

Section 4. How We Collect Personal Information

Depending on your relationship with Chorus AI, we may collect Personal Information from you in different ways. Some of the ways that Chorus AI may collect Personal Information include:

• When you give us Personal Information directly, including through contact forms on our Site, surveys, or by emailing us to request products, services, or information. This Personal Information would include the specific identifiers you provide directly to us.
• When you post user-generated content on our Site, we will collect the information you provide in such submissions, including identifiers you submit. User-generated content you submit to any public area of the Sites is considered “public” and will not be subject to the privacy protections in this Policy.
• We may record any calls, training sessions, webinars, or similar events that you participate in with us. We will take commercially reasonable efforts to inform you prior to the recording and provide you with the opportunity to object to the recording.
• When we collect information about your online activity automatically through our Sites through web analysis, such as your Internet protocol (IP) address, cookie identifiers, and other identifiers that are automatically assigned to your computer or devices when you access the Internet.
• When our subscriber customers (“Subscribers”) use our analytics-based, data-driven solutions in their campaigns. When acting as a service provider for our Subscribers who use our solutions, we may receive Personal Information about you based on your interactions with our Subscribers. This could include sales data, web data/Site activity data, and business contact and lead information that is governed by the Subscriber’s privacy policies (collectively, “Subscriber-Provided Information”).
• When Subscribers use our Services, Chorus AI receives data from its partners related to ads served. Some of the data received may be considered Personal Information, such as Internet protocol (IP) address, cookie identifiers, and other identifiers that are automatically assigned to your computer or devices when you access the Internet.
• From publicly available information and from third-party providers, partners, and integrators who gather data from a variety of sources including data co-ops or publicly-available sources that we use to develop professional profiles (“Business Profile Information”) that is compiled into our Business Database. Such information could include identifiers, such as name, title, department company name, company’s officers, and certain company employees, business and/or cell phone numbers, fax number, office address, email addresses, employment and education history, social media data, and similar information.
• We may collect information from third parties such as web-based and mobile networks, exchanges, aggregators, and publishers that are collected from their sites and properties, which might include identifiers such as IP address, cookies, and other unique identifiers that might be considered Personal Information. We do not reverse engineer this information to identify you personally such as your name, mailing address, or email address. Instead, we use the data to identify the company associated with the data and analyze the company’s behavior from a marketing and sales perspective for the benefit of our partners and Subscribers. The type of information collected via the identifiers might include information about online behavior, such as pages visited, time spent on a web page, session start/stop time, whether the visitor scrolled through or clicked on an ad or webpage, referring website address, and geolocation, that is then associated with the company identified.

Except as may be applicable for our employees or job applicants, for whom we have separate privacy policies, we do not knowingly directly collect sensitive Personal Information (such as medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of an individual). Sensitive personal information may be provided to us by a customer as part of Customer Data in order for us to provide Services and such information is subject to the customer’s privacy policy.

Section 5. How We Use Personal Information

We process Personal Information for a variety of purposes, but only for the reasons for which we collected it. As applicable, we only process Personal Information when we have a legal basis to do so, as explained in this Policy. We use the Personal Information we collect for the following business purposes.

• To Provide Services or Information Requested: We may use your Personal Information to fulfill requests for Services or respond to your requests for information.
• Administrative Purposes: We may use your Personal Information for administrative purposes, including to:
  • Measure interest in Chorus AI services;
  • Ensure internal quality control;
  • Communicate with you about your accounts and activities involving us and our services, including changes to our Sites or services;
  • Verify your identity or account, as necessary;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Comply with regulatory requirements;
  • Prevent potentially prohibited or illegal activities;
  • Data analysis to identify usage trends, determine the effectiveness of marketing or improve our Site or services; and
  • Enforce contracts with our Subscribers.
• Research and Development: We may perform survey research (online and offline). Sometimes we may ask third parties to conduct this research for us. You do not have to participate in these surveys. We will use the information we collect for research and reporting purposes to help us improve our Sites and Services. Similarly, if you post any user-generated content to the Sites, Chorus AI and our Subscribers may use this information to improve our products or overall customer experience.
• We use the Personal Information we collect

for the following commercial purposes.

• Marketing Chorus AI Products and Services: Individuals who provide us with Personal Information or whose Personal Information we obtain from third parties may receive periodic emails, newsletters, mailings, or phone calls from us with information about us or our business partners’ products and services or upcoming special offers/events we believe may be of interest and as permitted by applicable law. If you prefer that we not use your Personal Information for these purposes you may opt-out as described in Section 7 of this Policy. We may display personal testimonials and other endorsements on our Sites. With your consent, we may post your testimonial along with your name.
• Subscriber-Provided Information Chorus AI may use Subscriber-Provided Information to process data for our Subscribers and to provide the Services.
• Business Profile Information. We may use Business Profile Information to provide business-to-business contacts and enriched data to our Subscribers and partners for their business-to-business marketing and sales purposes and for such business purposes as permitted under our agreements. The information might include name, company, office address, job title, education, job history, and similar information.
• De-Identified and Aggregated Information. We may use Personal Information and other information you provide to us or that we collect about you to create de-identified and aggregated information that does not directly identify you. We use this information for a variety of functions, including learning more about our current services, and developing new services. De-identified or aggregated information is not Personal Information. We may share this information within Chorus AI and with third parties in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
• Other Uses. We may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, training purposes, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
• New Uses of Personal Information. Before we use Personal Information for any new purpose not originally disclosed to you, we will endeavor to provide information regarding the new purpose through updates to this Policy or other means to give you the opportunity to opt out. Where we are legally required to get your consent before processing Personal Information, we will comply with that requirement.
• Combining Personal Information. As described in Section 4 above, we may purchase information from third parties to combine with Personal Information we have already collected from you. We purchase this information for our internal marketing purposes, and also to provide to our Subscribers and partners as part of our business-to-business analytics and data-driven marketing and sales services.

Section 6. How We Share Personal Information

We may share your information as described in this Policy or with your permission.

• Service Providers. We may share your Personal Information (including Business Profile Information and Subscriber-Provided Information when permitted by our Subscribers) with third-party contractors, partners, vendors, and providers we use to perform functions on our behalf or on behalf of our Subscribers for business purposes, including hosting or enriching data, customer relationship management, tech and security support, communications, and advertising (“Service Providers”). These companies will have access to your Personal Information only to perform their functions and may not use it for any other purpose. We will only share your Personal Information with Service Providers that can provide sufficient guarantees that they will process your Personal Information securely and in accordance with data protection legislation. We obligate our Service Providers from taking any action with respect to your Personal Information unless instructed by Chorus AI. Such Service Providers are required to maintain the confidentiality of your Personal Information, and for Service Providers handling Subscriber-Provided Information, they are subject to substantially the same level of data protection as imposed on Chorus AI by its Subscribers.
• Business Partners. Chorus AI may share Personal Information with our business partners and affiliates to fulfill our contractual commitments, or to provide you with a product or service that you have requested. We also share this information for marketing or sales purposes including in connection with conferences or events where (if applicable) you have consented to sharing. Chorus AI may also provide Personal Information to business partners we work with to jointly offer products or services, or whose products or services we believe may be of interest to you.
• Subscribers. We may share Business Profile Information we collect and process for our Subscribers with our Subscribers. Our Subscribers’ privacy policies discuss how they will use this information.
• Affiliates. We may share Personal Information with any affiliated companies.
• Interest-Based Advertising and Third-Party Marketing. We may allow third-party advertising partners to set tracking tools on our Sites to collect information regarding your online activity. For more information about this, see Section 8 below. We may also use this and other Personal Information (such as demographic information or hashed email addresses) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) to provide you with more relevant advertisements when you visit websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” If you prefer that we do not share your Personal Information with third-party advertising partners for this purpose, you may opt-out as described in Section 7 of this policy.
• Disclosures for Legal or Similar Purposes. We may disclose your Personal Information if necessary to: (i) comply with legal requirements, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) to enforce Chorus AI policies or contracts or other commitments; (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, we may sell or transfer your Personal Information in connection with the transaction (unless otherwise prohibited by our Subscriber contracts or applicable law). Should such an event occur, Chorus AI will make efforts to ensure that the recipient use Personal Information consistent with this Policy.

Section 7. Jurisdiction-Specific Privacy Rights

Certain jurisdictions may provide certain rights with respect to Personal Information. This section generally addresses those rights and how you may exercise them in connection with our practices described in this Policy.

Depending upon location, you may have one or more of the following rights:

• The right to disclosure about our collection and use of your Personal Information.
• The right to correct or update your Personal Information.
• The right to request that we delete the Personal Information that we collected about you.
• The right to obtain a copy of your Personal Information.
• The right to restrict how we process your Personal Information and/or request that we do not sell or share your Personal Information about you.
• The right to withdraw your consent to the processing and/or sharing or sale of your Personal Information.
• The right to be free from discrimination for exercising any of your rights under data protection legislation.

To exercise the above rights, please send an email with your request and current contact information to privacy@chorusai.co. In order to protect your privacy, we will ask you to verify your identity before we can act on your access or deletion request. This process may require you to provide additional information, which we will only use for verification purposes.

Section 8. Cookies Pixel Tags, Web Beacons, and Analytics Information

We, as well as third parties that provide content, advertising, or other functionality on our Sites, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information. These Technologies are essentially small data files placed on your computer, and other devices, that allow us to record information whenever you visit or interact with our Sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. If you choose to delete cookies, our Sites may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about how you engage with a web page. The pixel allows us to record, for example, which web pages you’ve visited or advertisements you’ve clicked on. These pixel tags work with cookies to let us know what portions of our Sites interest you, help us provide you with tailored information from our Site, and help us enhance and develop our products and services.
• Social Media Widgets. Our Site includes social media features such as the Facebook “Like” button and Twitter and LinkedIn widgets to let you share and interact with content on social media. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing them. We cannot control how these companies use your information. By using these services you assume the risk that third parties may use the Personal Information you provide for any number of purposes.
• Analytics and Internet-Based Advertisers. We may also use Google Analytics and other vendors to collect information regarding visitor behavior and visitor demographics on some of our services and to remarket to audiences visiting the Sites and to develop Site content. The privacy policies and practices of these third-party providers will govern their use and collection of this information.
  • For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of the data your use of the

services generates by going to http://tools.google.com/dlpage/gaoptout.

We use the Technologies as follows:

• Strictly Necessary. We use Technologies that are necessary to operate our Sites, services, applications, and tools. This includes Technologies that allow you to access our Sites, services, applications, and tools that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or that allow you to use saved search or similar functions. The Sites usually only set these cookies when you make a specific action, like setting privacy preferences, or logging into the Sites. You can set your browser to block or alert you about these cookies, but some parts of the Site may then not work.
• Performance. We may use Technologies to assess and improve the performance of our Sites, applications, services, and tools, including to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, or determine whether you have viewed an item or link. All information these Technologies collect is aggregated and de-identified.
• Functional. We may use Technologies to offer you enhanced functionality when accessing or using our Site, services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites. If you do not allow these Technologies, then some or all of these services may not function properly.
• Targeting. We may use Technologies to deliver content, including ads relevant to your interests, on our Sites or on third-party sites. This includes using Technologies to understand whether the advertising you see is useful, such as whether you have clicked on an advertisement. Chorus AI and our advertising partners may set these Technologies. Our advertising partners may use these Technologies to build a profile of your interests and show you relevant advertisements on other Sites.
• Social Media. Social media services set these Technologies to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.
• Opting Out of Technologies. If you would like to opt-out of the Technologies we employ on our Sites, services, applications, or tools, you may block, delete, or disable them through your browser, as applicable. The online advertising industry also provides websites you can use to opt out of receiving targeted ads from advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy at http://www.aboutads.info/choices, http://www.youronlinechoices.eu, https://youradchoices.ca/choices, and http://www.networkadvertising.org/managing/opt_out.asp. Alternatively, for some devices, you may use your device’s platform controls to make choices about these Technologies. Please note that you must separately opt-out in each browser and on each device and that cookie-based opt-outs are not effective on mobile applications.

Section 9. Other Important Information

• Security Measures. We take steps to ensure that your Personal Information is treated securely and in accordance with this Policy. Our security program includes administrative, technical, and physical safeguards appropriate for our size and resources and the types of information that we process. We cannot guarantee that your Personal Information will be 100% secure. We do not accept liability for unintentional disclosure and you acknowledge that we are not responsible for any intercepted information sent via the internet. Should you use our Sites or provide Personal Information to us, we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Sites, where we have a legitimate interest or other lawful basis to do so. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
• Retention. Chorus AI retains the Personal Information we process on behalf of our Subscribers for as long as needed to provide services to our Subscribers or as necessary to fulfill the purpose(s) for which it was collected. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where Chorus AI is a data controller, we will retain your Personal Information in accordance with any applicable data protection legislation and for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means. In some circumstances, we may anonymize your Personal Information (so that it can no longer be associated with you).
• Data Transfers. Personal Information that Chorus AI collects may be stored or transferred outside of your state, province, country, or governmental jurisdiction where the data protection laws may differ from those in your jurisdiction, including but not limited to, in the United States, in the cloud, on our servers, or on affiliate or third-party service provider servers. Law enforcement or other authorities may access your Personal Information pursuant to a lawful request.
• Human Resources Data. With regard to Personal Information that Chorus AI receives in connection with the employment relationship, Chorus AI will use such Personal Information only for employment-related purposes. If Chorus AI intends to use this Personal Information for any other purpose, Chorus AI will notify the individual and provide an opportunity to opt out of such uses. Chorus AI’s use of Personal Information received in connection with employment-related purposes is governed by Chorus AI internal policies.
• Children’s Privacy. We do not knowingly collect, maintain, or use Personal Information from children (individuals under 13 and, in certain jurisdictions, under the age of 16) and no part of the Site is directed to children. If you learn that your child has provided us with Personal Information without your consent, you may alert us by sending an email to privacy@chorusai.co. If we learn that we have collected any Personal Information from children, we will promptly take steps to delete such information.
• Google Workspace Data. Any data obtained from Google Workspace APIs are not used to develop, improve, or train generalized/non-personalized AI and/or ML models.

Section 10. Revisions to the Policy

Chorus AI may change this Policy by posting an updated or revised Policy on our Site. Please check this Policy periodically so that you will remain up-to-date. If you continue to visit the Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.

Section 11. Contact Information – Accessing, Correcting, Updating Your Data

If you have any questions or concerns about this privacy policy or Chorus AI’s privacy practices, or you wish to change, amend, delete, or review your Personal Information, please contact us via email at privacy@chorusai.co.

If you have a disability that prevents you from accessing this Policy, please contact us at privacy@chorusai.co to access the policy in an alternative format.