Privacy Policy

Last modified: January 17th, 2025

1. Introduction

Please read this Privacy Policy (“Privacy Policy”) before using our Service including the Website, Widget andAPI (as defined below), referred to collectively as the “Service”. This PrivacyPolicy governs the types of information and data we collect and how we use and share this information. Your access to and use of the Service are available for your use only on the condition that you agree to the Terms of Service available under the following address: https://www.quickchat.ai/terms (“Terms of Service”) which include the terms of the Privacy Policy set forth below. Incentivai Inc. (“Company”) operates the Service. The address of the Corporation's registered office is 251 Little Falls Drive, Wilmington, New Castle, DE 19808, United States. We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service. For more information about our compliance with the Data Privacy Framework (DPF), please visit the DPF website (https://www.dataprivacyframework.gov), DPF list (https://www.dataprivacyframework.gov/list), and our alternative dispute resolution provider (https://www.jamsadr.com/).

2. Definitions

API means Quickchat application programming interface to be integrated with the User’s software.

CCPA means California Consumer Privacy Act.

Cookies are small files stored on yourDevice.

Device means a computer or a mobile device.

Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the DataController. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject is any living individual who is the subject of Personal Data.

Personal Data means data about a living individual who can be identified from those data (or from those and otherinformation either in our possession or likely to come into our possession).

Service means together the Website, Widget and/or the API (depending on the scope dedicated to a given User).

Usage Data is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

User is the individual using our Service.User corresponds to the Data Subject, who is the subject of Personal Data.

Website means web pages located at quickchat.ai.

Widget means a Quickchat widget that maybe implemented to the User’s website.

Special Categories of Personal Data means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data Privacy Framework (DPF) refers to the framework that provides guidelines for protecting personal data transferred from the European Union andSwitzerland to the United States, ensuring compliance with privacy principles.

Data Privacy Framework List refers to the list of organizations that have self-certified to the DPF principles, available on the DPF website.

Alternative Dispute Resolution (ADR) Provider refers to the independent recourse mechanism available to address complaints and resolve disputes under the DPF principles.

3. The Data Controller

The controller of your Personal Datails: Incentivai Inc. 251 Little Falls Drive, Wilmington, New Castle, DE 19808,United States.

Incentivai Inc. determines the purposes and means of processing your Personal Data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Data Privacy Framework (DPF). As the Data Controller, Incentivai Inc.ensures that your personal data is processed lawfully, fairly, and transparently.

Incentivai Inc. cooperates with OpenAI OpCoLLC to develop and improve our products. In this context, personal data may beprocessed by OpenAI as a data processor on behalf of Incentivai Inc., ensuring compliance with all relevant data protection laws and frameworks, including the DPF. For more information, please refer to: https://openai.com/policies/row-privacy-policy/

For more information about our compliance with the Data Privacy Framework, please visit the DPF website (https://www.dataprivacyframework.gov), DPF list (https://www.dataprivacyframework.gov/list), and our alternative dispute resolution provider (https://www.jamsadr.com/).

4. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

5. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”), including:

  1. email address,
  2. first name and last name,
  3. Cookies and Usage Data.

Special Categories of Personal Data:

We may also process special categories of personal data, including data concerning health, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, and data concerning a natural person's sex life or sexual orientation. This data will only be processed with your explicit consent or under another valid legal basis as required by applicable law.

This data will only be processed with your explicit consent or under another valid legal basis as required by applicable law.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a Device (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique Device identifiers and other diagnostic data. When you access Service with a Device, this UsageData may include information such as the type of Device you use, your Device unique ID, the IP address of your Device, your operating system, the type ofInternet browser you use, unique Device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include anonymous unique identifier. Cookies are sent to your browser from a website and stored on your Device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:

  1. Session Cookies: We use Session Cookies to operate our Service,
  2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings,
  3. Security Cookies: We use Security Cookies for security purposes,
  4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Cooperation with OpenAI

We cooperate with OpenAI to develop and improve our products. This cooperation involves using OpenAI's API to enhance our services while ensuring compliance with all relevant data protection laws and frameworks, including the Data Privacy Framework (DPF).

6. Use of Data

Incentivai Inc. uses the collected Personal Data for various purposes:

  1. to provide and maintain our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  2. to notify you about changes to our Service; type of Personal Data: email address, first name and last     name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  3. to allow you to participate in interactive features of our Service when you choose to do so; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  4. to provide customer support; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  5. to gather analysis or valuable information so that we can improve our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
  6. to monitor the usage of our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
  7. to detect, prevent and address technical issues; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
  8. to fulfill any other purpose for which you provide it; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
  11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; type of Personal Data: email address, first name and last name, Cookies and Usage Data; upon your consent;
  12. to process special categories of personal data (if applicable): some text
    1. Types of Personal Data: Data concerning health, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning a natural person's sex life or sexual orientation;
    2. Legal Basis: Explicit consent or other valid legal basis as required by applicable law;
  13.  
  14. in any other way we may describe when you provide the information; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
7. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

Personal Data

We will retain your Personal Data for the duration of your use of the Service and as necessary to fulfill the purposes described in this Privacy Policy. This may include retaining yourPersonal Data to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Special Categories of Personal Data

Special categories of personal data will be retained only as long as necessary for the specific purpose for which the data was collected and processed and will be securely deleted once the purpose has been fulfilled or upon withdrawal of consent, unless a longer retention period is required or permitted by law.

Usage Data

We will retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.  

Data Retained Upon Consent

Personal Data processed upon your consent will be stored until the relevant consent is withdrawn and for any period thereafter as required by applicable law or necessary for the establishment, exercise, or defense of legal claims.

Legal and Regulatory Obligations

We may retain your Personal Data for longer periods where we are required to do so to comply with legal or regulatory obligations, including but not limited to tax, accounting, and anti-money laundering regulations.  

Data Related to Disputes andEnforcement

We will retain your Personal Data for as long as necessary to resolve disputes and enforce our agreements and policies.

8. Transfer of Data

Your information, including PersonalData, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. The Company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. When we transfer your Personal Data to other countries, we will protect that Personal Data as described in this PrivacyPolicy and in accordance with applicable law. We use contractual protections for the transfer of Personal Data among various jurisdictions (the EuropeanCommission’s standard contractual clauses referred to in Article 46. 2 c) of the GDPR). Personal Data transferred to third parties will be restricted to the purposes explicitly stated in this Privacy Policy, such as providing and improving our services or ensuring compliance with legal obligations. Any onward transfer will require equivalent levels of protection, and Personal Data will not be shared with third parties unless necessary for fulfilling these purposes.

Adequate Controls and Safeguards

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Legal Basis for Transfer

When we transfer your Personal Data to other countries, we will protect that Personal Data as described in thisPrivacy Policy and in accordance with applicable law. The legal basis for international transfers of Personal Data includes, but is not limited to:

·     StandardContractual Clauses (SCCs): We use the European Commission’s standard contractual clauses referred to inArticle 46(2)(c) of the GDPR for transfers of Personal Data outside theEuropean Economic Area (EEA).

·     DataPrivacy Framework (DPF): We comply with the Data Privacy Framework principles for data transferred from the EEA and Switzerland to the United States. For more information about our compliance, please visit the DPF website (https://www.dataprivacyframework.gov), DPF list (https://www.dataprivacyframework.gov/list), and our alternative dispute resolution provider (https://www.jamsadr.com/).

Onward Transfer Restrictions

Personal Data transferred to third parties will be restricted to the purposes explicitly stated, such as providing and improving our services and ensuring compliance with legal obligations. Any onward transfer will require equivalent levels of protection as provided by us under this policy.

9. Disclosure of Data

We may disclose Personal Data you provide:

  1. under certain     circumstances, if required to do so by law or in response to valid     requests by public authorities;
  2. if we or our subsidiaries     are involved in a merger, acquisition or asset sale;
  3. to our subsidiaries,     affiliates, employees;
  4. to contractors, service     providers, and other third parties we use to support our business;
  5. to fulfill the purpose for     which you provide it;
  6. for the purpose of     including your company’s logo on our Website;
  7. with your consent in any     other cases.

We do not sell or otherwise share yourPersonal Data, except as described in this Privacy Policy.

10. Security of Data

The security of your data is ofparamount importance to us. We implement a variety of security measures tomaintain the safety of your Personal Data. These measures include, but are notlimited to, the following:

Technical Measures:

·      Data Encryption: We use strongencryption protocols (e.g., SSL/TLS) to protect Personal Data duringtransmission and storage.

·      Access Controls: Access to PersonalData is restricted to authorized personnel only, and such access is controlledthrough secure authentication mechanisms.

·     NetworkSecurity: Our systems are protected by firewalls and other network securitytechnologies to prevent unauthorized access.

Administrative Measures:

·      Policy Enforcement: We have strictinternal policies and procedures in place to ensure that Personal Data ishandled securely and in compliance with applicable laws and regulations.

·      Training: Regular training sessions areconducted for employees to ensure they are aware of data protection policiesand best practices.

·     Monitoringand Auditing: We conduct regular audits and monitoring to detect and respond toany potential security incidents promptly.

Physical Measures:

·      Secure Facilities: Personal Data isstored in secure facilities with controlled access.

·     Backupand Recovery: We maintain regular backups and have disaster recovery plans toprotect against data loss or disruption.

Third-Party Security:

·      Vendor Assessments: We perform duediligence and assessments of third-party service providers to ensure they meetour security standards.

·     DataProcessing Agreements: Third parties that process Personal Data on our behalfare required to implement appropriate security measures and comply with ourdata protection policies.

Ongoing Security Practices:

·      Incident Response: We have an incidentresponse plan in place to manage and mitigate the impact of any data breaches.

·     RegularUpdates: Our security measures are reviewed and updated regularly to addressemerging threats and vulnerabilities.

Cooperation with OpenAI

We cooperate with OpenAI to develop andimprove our products. This cooperation involves using OpenAI's API to enhanceour services while ensuring compliance with all relevant data protection lawsand frameworks, including the Data Privacy Framework (DPF). OpenAI implementsrobust security measures to protect Personal Data processed on our behalf.Please note that while we strive to use commercially acceptable means toprotect your Personal Data, no method of transmission over the Internet ormethod of electronic storage is 100% secure. Therefore, we cannot guarantee itsabsolute security.

11. Your Data Protection Rights Under GeneralData Protection Regulation (GDPR)

If you are a resident of the EuropeanUnion (EU) or the European Economic Area (EEA), you have certain dataprotection rights covered by the General Data Protection Regulation (GDPR). Weaim to take reasonable steps to allow you to exercise these rights regardingyour Personal Data. Your rights under GDPR include:

·     Rightto Access: You have the right to access and receive a copy of your PersonalData that we hold about you, and to obtain information about how we process it.

·     Rightto Rectification: You have the right to request the correction of inaccuratePersonal Data and to have incomplete Personal Data completed.

·     Rightto Erasure ("Right to be Forgotten"): You have the right torequest the erasure of your Personal Data, subject to certain conditions andexceptions provided by law.

·     Rightto Restriction of Processing: You have the right to request the restriction ofprocessing of your Personal Data under certain circumstances, such as when youcontest the accuracy of the data or object to our processing.

·     Rightto Data Portability: You have the right to receive your Personal Data in astructured, commonly used, and machine-readable format, and to request thetransfer of this data to another controller where technically feasible.

·     Rightto Object: You have the right to object to the processing of your Personal Databased on legitimate interests, including profiling, and to direct marketing.

·     Rightto Withdraw Consent: If we process your Personal Data based on your consent,you have the right to withdraw your consent at any time. Withdrawal of consentdoes not affect the lawfulness of processing based on consent before itswithdrawal.

·     Rightto Lodge a Complaint: You have the right to lodge a complaint with asupervisory authority, particularly in the EU Member State of your habitualresidence, place of work, or place of the alleged infringement, if you considerthat the processing of your Personal Data infringes GDPR.

If you wish to execute any of theabove-mentioned rights, please email us at contact@quickchat.ai. Please notethat we may ask you to verify your identity before responding to such requests.Please note, we may not able to provide Service without some necessary data.

12. Your Data Protection Rights under theCalifornia Consumer Privacy Act

Definitions

Consumer (user) for the purposes of theCCPA means a natural person who is a resident of California.

Personal Data for the purposes of the CCPA means anyinformation that identifies, relates to, describes or is capable of beingassociated with, or could reasonably be associated, directly or indirectly,with the Consumer.

Sale for the purposes of the CCPA meansselling, renting, releasing, disclosing, disseminating, making available,transferring, or otherwise communicating orally, in writing, or by electronicor other means, Consumer’s Personal Data to another business or a third partyfor monetary or other valuable consideration.

You have the following data protectionrights under the CCPA:

  1. The right to notice. You have the right to     be notified of the categories of Personal Data collected and the purposes     for which the Personal Data is used.
  2. The right to request. You have the right to     request that we provide you with information about our collection, use,     sale, disclosure for business purposes and share of Personal Data.
  3. The right to say no to the     sale of Personal Data (opt-out). You have the right to opt-out of the sale of     your Personal Data. Once we receive and acknowledge a verifiable Consumer     request from you, we will stop selling your Personal Information.
  4. The right not to be     discriminated against. You     have the right not to be discriminated against for exercising any of your     Consumer's rights.
  5. The right to delete     Personal Data. You     have the right to request the deletion of your Personal Data, subject to     certain exceptions. Once we receive and confirm your request, we will     delete (and instruct our Service Providers to delete) your personal     information from our records, unless an exception applies.

To exercise any of your rights underthe CCPA, and if you are a California resident, you may contact us at: contact@quickchat.ai. Only you, or a person registered withthe California Secretary of State whom you authorize to act on your behalf, maymake a verifiable request regarding your Personal Data.

Collection and disclosure of PersonalData under the CCPA

We may collect, and may have collected,the following categories of Personal Data from California residents within thelast twelve (12) months:

·      Identifiers such as name, emailaddress, and IP address.

·      Personal information categories listedin the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) suchas name and contact information.

·      Commercial information such as recordsof products or services purchased.

·     Internetor other similar network activity such as browsing history and interactionswith our website.

We may use or disclose, and may haveused or disclosed within the last twelve (12) months the categories of PersonalData previously identified in this Privacy Policy.

13. Service Providers

We may employ third party companies andindividuals to facilitate our Service (“Service Providers”), provide Service onour behalf, perform Service-related services or assist us in analysing how ourService is used. These third parties have access to your Personal Data only toperform these tasks on our behalf and are obligated not to disclose or use itfor any other purpose.

14. Analytics

We may use third-party ServiceProviders to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analyticsservice offered by Google that tracks and reports website traffic. Google usesthe data collected to track and monitor the use of our Service. This data isshared with other Google services. Google may use the collected data tocontextualise and personalise the ads of its own advertising network. For moreinformation on the privacy practices of Google, please visit the Google PrivacyTerms web page: https://policies.google.com/privacy?hl=en. We also encourage you to review theGoogle's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Mixpanel

Mixpanel is provided by Mixpanel Inc.You can prevent Mixpanel from using your information for analytics purposes byopting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/. For more information on what type ofinformation Mixpanel collects, please visit the Terms of Use page ofMixpanel: https://mixpanel.com/terms/.

Datadog

Datadog is a monitoring and securityplatform for cloud applications provided by Datadog Inc. Datadog uses the dataand logs collected to make our application and infrastructure more secure andreliable. For more information on the privacy practices of Datadog, pleasevisit the Datadog Privacy we page: https://www.datadoghq.com/privacy/ and review Datadog's PrivacyPolicy: https://www.datadoghq.com/legal/privacy/.

BigQuery

BigQuery is a fully managed enterprisedata warehouse provided by Google Cloud Platform that helps us manage andanalyze our application data. For more information on the data security andgovernance practices of BigQuery, please visit the BigQuery page: https://cloud.google.com/bigquery/docs/data-governance and review Google CloudPlatform's Privacy Policy plage: https://cloud.google.com/terms/cloud-privacy-notice.

15. Payments

We may provide paid products and/orservices within Service. In that case, we use third-party services for paymentprocessing (e.g. payment processors). We will not store or collect your paymentcard details. That information is provided directly to our third-party paymentprocessors whose use of your personal information is governed by their PrivacyPolicy. These payment processors adhere to the standards set by PCI-DSS asmanaged by the PCI Security Standards Council, which is a joint effort ofbrands like Visa, Mastercard, American Express and Discover. PCI-DSSrequirements help ensure the secure handling of payment information. Thepayment processors we work with are:

  1. Stripe - Privacy Policy of Stripe Inc. can be viewed at: https://stripe.com/us/privacy.
16. Links to Other Sites

Our Service may contain links to othersites that are not operated by us. If you click a third party link, you will bedirected to that third party's site. We strongly advise you to review thePrivacy Policy of every site you visit. We have no control over and assume noresponsibility for the content, privacy policies or practices of any thirdparty sites or services.

17. Children's Privacy

Our Service does not address anyoneunder the age of 16 (“Children”). We do not knowingly collect personallyidentifiable information from anyone under the age of 16. If you are a parentor guardian and you are aware that your Child has provided us with PersonalData, please contact us. If we become aware that we have collected PersonalData from children without verification of parental consent, we take steps toremove that information from our servers.

18. Changes to This Privacy Policy

We may update our Privacy Policy fromtime to time. We will notify you of any changes by posting the new PrivacyPolicy on this page and updating “effective date” at the top of this page,unless another type of notice is required by the applicable law. You areadvised to review this Privacy Policy periodically for any changes. Changes tothis Privacy Policy are effective when they are posted on this page. Bycontinuing to use our Service or providing us with Personal Data after we haveposted an updated Privacy Policy, or notified you if applicable, you consent tothe revised Privacy Policy and practices described in it.

19. Contact Us

If you have any questions about thisPrivacy Policy, please contact us at contact@quickchat.ai.

20. Privacy Policy Addendum

Addendum to Privacy Policy for Canada

Personal Data maintained and processedby our affiliates and third-party service providers in the U.S. and otherforeign jurisdictions may be subject to disclosure pursuant to a lawful accessrequest by U.S. or foreign courts or government authorities. We will notprovide your information to third parties for marketing purposes without yourprior consent. For more information about our privacy practices; to access,update or correct inaccuracies in your personal information; or if you have aquestion or complaint about the manner in which we or our service providerstreat your personal information, please contact us on data indicated in section“Contact us” above.

Addendum to Privacy Policy for Mexico

To the extent Mexican privacy laws orregulations apply, the following additional Mexico-specific provisions applyand shall prevail over conflicting provisions in the Privacy Policy.

How We Use the Information We Obtain

In addition, we may use your PersonalData for the other purposes listed in the “Use of Data” section of the PrivacyPolicy, which may be considered secondary purposes under Mexican law. We do notuse or share personal payment or financial information except in connectionwith the processing of payments or where there is another legal basis. You maywithdraw your consent to our processing of your Personal Data by contacting usas indicated in the “How to Contact Us” section of the Privacy Policy. If youwithdraw your consent for us to process your Personal Data for one of theprimary purposes indicated above, then in some situations we may not be able toprovide the service, though we may still engage in certain processingauthorized by law. The Company may also use data and related data analysis inother Company products and services.

Information We Share

We may share your Personal Data asprovided in the Privacy Policy, but to the extent permitted by law, you maywithdraw your consent to this sharing by contacting us as indicated in the “Howto Contact Us” section of the Privacy Policy. We also share the relatedinformation we obtain with our customers, partners, affiliates, and jointmarketing partners. These entities, which collectively are referred to here asthe “Business Partners” may use the information for the purposes described inthis Privacy Policy. We may also share the information with our BusinessPartners and other third parties for warranty, troubleshooting or maintenancepurposes, or for improving the design and performance of their products andservices.

Requests for Access, Correction,Cancellation, Objection or Consent Withdrawal

In addition to any rights granted inthe Privacy Policy, you may ask us to cancel your Personal Data to the extentpermitted by law by contacting us as indicated in the “How to Contact Us”section of the Privacy Policy. Following a valid cancellation request, we mayhold the Personal Data for the duration and purposes permitted by law beforedeleting it. We will answer your requests to access, correct or cancel yourPersonal Data or to object or withdraw your consent to our processing of yourPersonal Data within 20 business days from the date we receive your completerequest or as provided by law. To be considered complete, your request mustinclude your full name and contact address, and a clear and detaileddescription of your request.

Addendum to Privacy Policy for Japan

The Company complies with Japanese lawsand regulations, including the Act on the Protection of Personal Information.The Company is primarily responsible for the management of the Personal Datathat is jointly used with our affiliates or third parties. We will not provideyour information to third parties for marketing purposes without your priorconsent.

Addendum to Privacy Policy for Republic ofKorea

Except as otherwise required by law,consumer Personal Data is securely disposed of without delay when (i) theconsumer revokes his or her consent for our use of the information, (ii) thepurpose of our collection and use of the Personal Data has been accomplished or(iii) the legal retention period has expired. If applicable law requires thepreservation of Personal Data that otherwise would be disposed of, the PersonalData is transferred to a separate database and then disposed of after theperiod determined by the applicable law. Personal Data is disposed of using amethod that is reasonably likely to prevent the Personal Data from beingrestored or reused. We will not provide your Personal Data to third parties inviolation of law (such as without your consent, where consent is required). Forthe purposes stated in the Privacy Policy, Company or our affiliates areresponsible for the handling of Personal Data with respect to services providedin Republic of Korea.