PRIVACY POLICY

Last updated: January 18, 2024

Thank you for choosing to be part of our community. Your privacy is important to us. This privacy policy (“Privacy Policy”) describes how Pairgap, Inc., together with our affiliates and subsidiaries (collectively, “Pairgap,” “we,” “us,” or “our”), collect, use, disclose, and process your information. It also explains the rights and choices available to you with respect to your information.

This Privacy Policy applies to information we collect and process when you interact with us and our products and services, such as when you access or use our websites, and other Pairgap online services that link to this Privacy Policy (each a “Service” and collectively, the “Services”); contact our support staff; engage with our social media features and pages; or otherwise interact with us. We hope you take some time to read this Privacy Policy carefully. You can click on the links below to go directly to the corresponding section of this Privacy Policy.

CONTENTS
1. INFORMATION WE COLLECT
2. HOW WE USE INFORMATION
3. HOW WE SHARE INFORMATION
4. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
5. YOUR CHOICES
6. HOW WE PROTECT INFORMATION
7. DATA TRANSFERS
8. CHILDREN’S PRIVACY
9. THIRD-PARTY LINKS
10. INFORMATION FOR CALIFORNIA RESIDENTS
11. INFORMATION FOR NEVADA RESIDENTS
12. CHANGES TO THIS PRIVACY POLICY
13. CONTACT DETAILS
14. ACCESSIBILITY

1. INFORMATION WE COLLECT

We collect different types of information depending on the context of your interactions with us and our Services. Some of the information we collect includes personal information. We use the term “personal information” generally in this Privacy Policy to refer to information that can be used to identify you, either alone or in combination with other information.

1. Information you provide directly to us

• Account and Profile Data. We collect any information or content you provide to us when you sign up for an account, or create a user profile, which may include your name, date of birth, contact information (e.g., email and phone number), password, profile pictures, home address, employment details, gender, race, relationship status, educational details, interests/hobbies, and financial information (e.g., credit card or debit card). Emergency contact information is collected, but known medical conditions are not. You may choose to provide additional information about yourself to create a profile, which may include, interests and hobbies, employment details, locations, gender, and race.
• After you create your user profile, anytime you log in, we may collect additional information and add it to your profile.
• Communications Data. We collect information when you communicate with us (e.g., by email, text message, or chat sessions) or others on our Services, such as when you request additional information about products or services, or sign up to receive our e-mail newsletters, notification, or marketing messages. We collect logs of communications conducted through additional methods, including video conferencing platforms such as Zoom. We also log the intent of communications, such as requests for product information, interactions with customer support, and marketing sign-ups. We also collect information when you interact with us on social media, such as by tagging us and/or our products or permitting us to follow your social media profile. Examples of such information include your contact information (e.g., email address, phone number, or mailing address), the date and time of your communications, online identifiers, social media profile, and the content of your communications.
• Customer Relationship Data. We collect information relating to our customer relationships, which may include customer name, employer, job title or role, contact details (e.g., email and phone number), and information contained in communications between us and our customers.
• Demographic Data. We may collect specific or general demographic data when you fill out forms or surveys on our Services or sign up for and participate in promotions, and special programs that we provide. Examples of such information include age, gender, zip code, state, and country.
• Transaction Data. We collect information relating to transactions, including purchases of services, that you enter into with us and/or through our Services. Examples of such information include the type of services requested or purchased, order details, amount charged, payment method and payment information (e.g., debit or credit card number), billing information, and information about any services you exchanged with us.
• Sensitive Data. Some of the information you provide or generate when using the Services may relate to your preferred language and may fall under a special category for which certain data protection laws require enhanced protection (“Sensitive Data”). To the extent that information we collect is Sensitive Data, we ask for your explicit consent to process the data.

2. Information provided by third parties

• Social media features and widgets. Our Services may include social media features, such as links to Instagram, Facebook, YouTube, and X, formerly known as, Twitter, that allow you to share information (e.g., via widgets, plugins, or other tools), such as, the “Like” or “Share” button (“Features”). 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. They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the third-party social media service. Features are either hosted by a third party or hosted directly on our Services. Your interactions with these Features are governed by the privacy statements of the third-party companies providing them. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.
• Third-party sign in. If you access our Services through a third-party application, such as the Apple App Store or Google Play App Store (together with any similar applications, “App Stores”) or a social media or other third-party account, such as Airtable, Hubspot, or Google, we may collect information about you from that third-party application that you have made public via your privacy settings. Depending on your privacy settings on the third-party account, information we collect through App Stores or third- party accounts may include your email address, name, username, user identification number, location, gender, birth date, profile picture and your social media network contacts. If you choose to access our Services using a third-party account, you authorize us to collect your information from that third-party service and process it in accordance with this Privacy Policy. Please note that we do not control the third party’s information practices, so please review the third party’s privacy statement and your settings on the third party’s site carefully.

3. Information collected through tracking technology

We collect certain information automatically when you access and use our Services or visit our retail locations. The types of information we collect may include:

• Device and Network Data. We collect certain information about the device you use to access our Services. Examples of such information include your device’s browser type.
• Location Data. Based on your interaction with the Services, the type of device you use to access the Services, and your device’s connectivity, we may collect location-based information including your IP address, GPS location, longitude/latitude, city, county, zip code and region. We may use this type of information to enhance your user experience, to better understand your interaction with our products and services in our retail locations. Unless you provide us with your consent to do otherwise, this information will only be used by us and our third-party service providers to provide you with the Services you request or in an aggregated and anonymized format that does not identify you. If you no longer wish to have this location information collected and used by us, you may opt-out by disabling the location and Bluetooth features in the operating system of your device.
• Usage Data. We collect information about your activity on our Services via log files, cookies, and other similar tracking technologies. Examples of such information include your access times, pages viewed, and other system activity, your use of any hyperlinks available within our Services, and identifiers associated with browser cookies, log files, cookies, and similar technologies we deploy on our Services. We may use third-party service providers, such as Google Analytics, to collect this usage data. Learn more about how Google collects and uses data here. To opt-out of Google Analytics please use this link.

For more information about our and our third-party partners’ use of cookies and similar tacking technologies to collect information automatically, and any choices you may have in relation to its collection, please read our Cookie Policy.

4. Other types of information

• Inferences and Derived Data. We may derive information or draw inferences about you based on the
  other types of personal information we collect. For example, we may infer your location based on your
  IP address, or your purchasing habits based on your browsing behavior on our Services.

3. HOW WE USE INFORMATION

We use personal information for a variety of purposes as described in more detail below.

1. To Provide and Maintain our Products and Services. We use the information we collect to operate and maintain our Services and to provide our products and the features and functionality of our Services.

These activities may include, among other things, using information to:

• administer your account and provide you access to the Services and features you request;
• debug, identify and repair errors that impair existing intended functionality of our Services
• complete transactions you request, including to process payments and to fulfill and manage your orders;
• contact you about your account, transactions, and/or use of the Services (e.g., account management,
  customer service, product updates, policy changes, security updates, or system maintenance);
• enforce our terms, conditions, policies and other agreements;
• respond to or follow-up on your questions, comments, reviews, and other requests, including to provide customer service; and
• verify individual identity.

2. To Improve, Personalize, and Develop Our Products and Services. We use the information we collect to improve and personalize our Services, product offerings, marketing and promotional efforts, and to develop new ones. These activities may include, among other things, using information to:

• enable and enhance your use of our Services, including to identify your product and services preferences, provide personalized information, and assist with your usage trends; and
• perform research and development activities, which may include, for example, conducting data analysis in order to develop new or improve existing products and services, and performing quality control activities.

We use cookies and similar tacking technologies for the purposes described above. For more information, please read our Cookie Policy.

4. To Conduct Feedback Surveys and Obtain Testimonials. From time to time we (or third parties acting on our behalf) may contact you to participate in feedback surveys or to provide reviews and testimonials. We use such information to improve our products, our Services, and in any manner consistent with this Privacy Policy. If you decide to participate, you may be asked to provide certain information, which may include personal information. You are in control of the information you would like to share with us. Prior to posting a testimonial, we will obtain your permission to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at info@Pairgap.com in the United States and Canada and be sure to include your name, testimonial location, and contact information.

5. To Send You Marketing and Promotional Communications. By creating an Pairgap account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, or promotions. You may also opt-in to receiving similar notifications on the Services. We may provide you with these materials by phone, postal mail, text or email, as permitted by applicable law. Such uses include:

• To develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location; and
• To notify you about offers, products and services that may be of interest to you or about which you have previously expressed an interest.

You can opt-out of receiving our marketing communications at any time as further described in the “YOUR CHOICES” section.

6. To Comply with Legal or Regulatory Obligations or In Connection with a Legal Process. This may include using information as we believe to be necessary or appropriate to: (i) comply with judicial proceedings, court orders or legal processes or to respond to proper governmental request or investigation; (ii) detect, prevent, or otherwise address fraud, security or technical issues; (iii) protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate
our policies, procedures, and terms and conditions; and (iv) to protect yours, ours or others’ rights, property or safety;

7. With Your Consent. We may process your information for a purpose not otherwise described in this Privacy Policy in accordance with your consent or instructions.

8. Other Reasonable Business Purposes. As permitted by applicable law, we may use information to carry out other reasonable purposes related to our business or your ongoing relationship with us. This may include using information to obtain or maintain insurance coverage, manage risk, obtain professional advice, and perform other internal functions such as accounting and auditing.

3. HOW WE SHARE INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, we share information in the following situations:

1. Service Providers. We share information with third-party suppliers, vendors, service providers, contractors or agents who perform services for us or on our behalf, including order fulfillment and shipping, payment processing, customer support, administering our marketing and reviews platform, hosting, information technology and security, fraud prevention, mail and email distribution, events, contests, and promotion administration, marketing, advertising, and analytics services. This excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

2. Where Required or Permitted by Law or Legal Process. We may disclose information where we believe disclosure is necessary or required (i) to comply with applicable law, regulation, or legal process, or in response to requests by law enforcement authorities, government or public agencies or officials, or regulators; (ii) to exercise, establish or defend our legal rights or to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

4. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We use cookies and similar tracking technologies to automatically collect information, including your email address, through our Services. We also work with third-party partners who provide analytics and advertising services or other functionality on our Services. These third parties may also use cookies and similar tracking technologies to collect information about you when using our Services (for instance through a browser) and may combine the information with other information they have access to such as your mailing address so that we may serve relevant marketing offers to you via email or direct mail. Where required by law, we base the use of cookies and similar tracking technologies upon consent. If you wish to change your cookies and similar tracking technologies settings, please visit the cookie banner on our homepage. For more information about how we use such technologies and how you can refuse certain cookies, please read our Cookie Policy.

5. YOUR CHOICES

1. Access to your account
You may access, correct or update most of your account and profile information on your own through the Services within your Profile Settings of the website:
https://pairgap.com/dashboard/login/

Simply login to the website, navigate to the My Account section to update your email, password, phone number and address or to manage your email and privacy setting and delete your account.

Marketing Communications

• Email. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at info@Pairgap.com in the United States. If you opt-out of receiving promotional communications from us, we may still send you non-promotional communications, such as those about your account, your orders, or our ongoing business relations.
• Text Messages. To opt-out of receiving text messages, follow the opt-out instructions in the text messages that you receive from us.

3. Device Permissions

Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Depending on the manner in which you make changes to your settings, certain Services may lose partial or full functionality.

5. Managing Cookies
For more information about how you can refuse certain cookies, please read our Cookie Policy.

6. “Do Not Track” Features

Some web browsers incorporate a Do Not Track (“DNT”) or a similar feature. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6. HOW WE PROTECT INFORMATION

We have implemented reasonable and appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that no method of transmission over the Internet, or method of electronic storage, is fully secure. Although we will do our best to protect your personal information, we cannot guarantee its absolute security. In the event we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by phone, if permitted to do so by law.

If you create an account as part of using our Services, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, selecting a strong password and constructing a unique password. You are also responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. Please notify us of any unauthorized use of your password or account.

7. DATA TRANSFERS

For the reasons and purposes described in this Privacy Policy, the information we collect may be transferred to, stored, and otherwise processed in the United States and other countries. Wherever possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By accessing and/or using the Services or otherwise providing your personal information, you are agreeing to the transfer of your information to the United States.

8. CHILDREN’S PRIVACY

Our Services are intended for general audiences over the age of 18 years old. We do not knowingly collect information from children under the age of 18 years old. If you are not over 18 years old, then DO NOT DOWNLOAD OR USE THE SERVICES. We also do not knowingly sell the personal information of individuals under the age of 16.

9. THIRD-PARTY LINKS

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or shared.

As part of the functionality of our Services, we may integrate with certain third-party services. If you choose to link your account with such applications, you can decide to share the health information we collect about you while you use the Services. You may opt-out of tracking at any time by configuring your privacy settings on such applications. Your interactions with third-party services or other health applications are governed by the privacy policy of the company providing the service.

10. INFORMATION NEVADA RESIDENTS

Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain personal information a business has collected or will collect about you. We do not sell your personal information as defined under Nevada law. For more information about how we handle and share your personal information or your rights under Nevada law, please contact us at info@Pairgap.com.

11. INFORMATION FOR CALIFORNIA RESIDENTS
California law requires us to disclose the following information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy.

1. Categories of Personal Information We Collect, Use, and Disclose

The table below identifies the categories of personal information we have collected in the past twelve (12) months and which we continue to collect. It also lists the categories of third parties to whom we disclose personal information for a business purpose. For more information, including the sources from which we obtain personal information, please see the “INFORMATION WE COLLECT” section of this Privacy Policy.