This Privacy Policy applies to the processing of personal information by Textio, Inc. (“Textio,” “we,” “us,” or “our”) including on our website available at lavalier.ai and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Policy (collectively, the “Services”).

Disclosure Regarding Customer Data. This Privacy Policy does not apply to the personal information that we process on behalf of our customers pursuant to a written agreement we have entered into with such customers (“Customer Data”). Our customers’ respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

Our Services are generally designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not as individual consumers.

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1. UPDATES TO THIS PRIVACY POLICY
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE PROTECT AND USE PERSONAL INFORMATION
4. HOW WE SHARE PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR
9. CALIFORNIA PRIVACY RIGHTS
   
10. CHILDREN’S PERSONAL INFORMATION
11. CONTACT US

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1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and we may also send other communications.

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2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

• Personal Information You Provide to Us Directly. We may collect personal information that you provide to us.
  

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account.
  

• Purchases or Transactions. We may collect personal information and details associated with your purchases or transactions on the Services, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
  

• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
  

• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
  

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
  

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
  

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
  

• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and resume or CV. ‍

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, and location information.

• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.

• Cookies. Cookies are small text files stored in device browsers.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular user interface element. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

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3. HOW WE PROTECT AND USE PERSONAL INFORMATION

Security procedures are in place to protect the confidentiality of your personal information. For example, we use encryption to protect your personal information.

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

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A. Provide the Services

We use personal information to provide the Services, such as:

• Providing access to certain areas, functionalities, and features of the Services;
• Communicating with you;
• Answering requests;
• Sharing personal information with third parties as needed to provide the Services; and
• Processing your financial information and other payment methods.
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B. Operate Our Business

We use personal information to operate our business, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Carrying out analytics;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information unless doing so is permitted by, or we are required to do so to comply with, applicable laws;
• Processing applications if you apply for a job we post on our Services;
• Allowing you to register for events;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content.

D. With Your Consent or Direction

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

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4. HOW WE SHARE PERSONAL INFORMATION

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.
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A. Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

• Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be shared with service providers that help provide our chat features.

Some of the service providers we may use include:

• Vector. Vector may use cookies and related technologies to connect your activities with other personal information they or others may hold about you, such as your email or online profiles. Vector might then send you communications and marketing materials to these emails or profiles. To opt out of these communications, please email Vector at security@vector.co.

• Other Users You Share or Interact With. The Services may allow Lavalier users to share personal information or interact with other users of the Services.

• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Lavalier Customers (Authorized Users Only).] In cases where you use our Services as an employee, contractor, or other authorized user of a Lavalier customer, we may share any information associated with your use of the Services with the Lavalier customer, including, but not limited to, account information, usage information, files, and the contents of the communications associated with your account. Your personal information may also be subject to the Lavalier’s customer’s privacy policy. We are not responsible for Lavalier’s customer’s processing of your personal information.‍

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B. Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.
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C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

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5. YOUR PRIVACY CHOICES AND RIGHTS
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Your Privacy Choices. The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Policy).

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
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The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
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Please note you must separately opt out in each browser and on each device.
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Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Request Access to or Portability of Your Personal Information;

• Request Correction of Your Personal Information;

• Request Deletion of Your Personal Information;

• Request Restriction of or Object to Our Processing of Your Personal Information; and

• Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.

We will process such requests in accordance with applicable laws.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe that our processing of your personal information violates applicable law.

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6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us will be transferred, processed, and stored in the United States.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to the United States, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

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7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as long as necessary to fulfill the purpose(s) for which it was collected, or as long as necessary to pursue our business purposes.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.

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8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR applies only to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

Our processing of your personal information may be supported by one or more of the following lawful bases:

• Section 3A: Provide the Services
  ‍Lawful Basis: Performance of a Contract (i.e., to provide the Services to you);
  ‍Legitimate Interest; Consent; For Compliance with Legal Obligations
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• Section 3B: Improve the Services and Develop New Products and Services
  ‍Lawful Basis: Performance of a Contract (i.e., to provide the Services to you); Legitimate Interest; Consent; For Compliance with Legal Obligations
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• Section 3C: Operate Our Business
  ‍Lawful Basis: Performance of a Contract (i.e., to provide the Services to you); Legitimate Interest; Consent; For Compliance with Legal Obligations
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• Section 3D: Marketing
  ‍Lawful Basis: Legitimate Interest; Consent
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• Section 3E: With Your Consent or Direction
  ‍Lawful Basis: Performance of a Contract (i.e., to provide the Services to you); Legitimate Interest; Consent

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9. CALIFORNIA PRIVACY RIGHTS‍

California law permits users who are California residents to request and obtain once a year, free of charge, a list of the third parties to whom we have disclosed their PII (if any) for their direct marketing purposes in the prior calendar year, as well as the type of PII disclosed to those parties. We do not share PII with third parties for their own marketing purposes. ‍

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10. CHILDREN’S PERSONAL INFORMATION‍

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.‍

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11. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at privacy@lavalier.ai or write to:

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Lavalier Privacy Team

600 1^st Ave, Suite 330, PMB 72670

Seattle, WA 98104