Privacy Policy

Alecci Media LLC ("we", "us", or "our") is committed to protecting your privacy. We offer subscribers access to the Alecci Media Bots (the "Bot"), which are made available across multiple platforms and have strategic marketing and sales information and capabilities (the "Services"), as well as other information and services we may provide. We have prepared this Privacy Policy ("Privacy Policy") to describe to you our practices regarding the information that we collect from subscribers and the Services we offer.

We are committed to complying with the Children's Online Protection Act of 1998 ("COPPA"). COPPA requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge children to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their children restrictions regarding the online release of personal information to anyone they do not know.

By using our Bot and/or Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Alecci Media Terms of Service (the "Terms"), which are incorporated herein.

Information Collected

Information You Provide to Us

When you utilize our Bot or Services, you may be prompted to provide personal information.

We retain information on your behalf, including the content of the message and the recipient data, using your information. We will not use the raw text of conversations for training unless explicit consent is obtained.

We may use anonymized, aggregated analytics data to improve the Bot.

We may also collect personal information at other points in our Services that state that personal information is being collected.

Information Collected from Third-Party Companies

We may receive information about you from other sources. We may add this information to the information we have already collected from you via our Services in order to improve the Services.

Information Collected Automatically

Generally

When you use our Services, some information is automatically collected. For example, when you use our Services, your geographic location, how you use the Services, information about the type of device you use, your mobile network information, your Open Device Identification Number ("ODIN"), date/time stamps for your visit, your unique device identifier ("UDID"), your browser type, operating system, Internet Protocol (IP) address, and domain name are all collected. We use this information to help us deliver the most relevant information to you and administer and improve the Services.

Log Files

We gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to maintain and improve the performance of the Services.

Cookies

We use cookies to collect information. "Cookies" are small pieces of information that a website or application sends to your computer's or mobile device's hard drive while you are viewing the Site or affiliated websites. We, and some third parties, may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our Services. You may set your device settings to refuse cookies or to remove cookies from your hard drive, but our Site does not recognize "Do Not Track" signals. You can also learn more about Cookies by visiting www.allaboutcookies.org which includes additional useful information on Cookies and how to block them using different browsers. By blocking or deleting Cookies used on our Site, you may not be able to take full advantage of our Services.

Marketing Companies

We may work with a number of companies for assistance in marketing our Services to you on third-party websites. These companies may collect information about online activities conducted on a particular computer, browser, or device over time and across third-party websites or online services for the purpose of delivering advertising that is likely to be of greater interest to you on our Site and those of third parties.

Analytics Companies

We may work with a number of third-party analytics companies that collect information anonymously and report trends without identifying individual visitors. These services allow us to view a variety of reports about how visitors interact with the Services so we can improve our Site and understand how people find and navigate it.

Use of Your Personal Information

General Use

In general, personal information you submit to us is used either to respond to requests that you make, aid us in serving you better, or market our Services. We use your personal information in the following ways:

• Respond to comments, requests, and questions and provide customer service
• Identify you as a user in our system
• Provide, process, and deliver the Services you request
• Improve the quality of experience when you interact with our Services
• Send you administrative e-mail notifications
• Resolve disputes and/or troubleshoot problems
• Develop, improve, and deliver marketing and advertising for the Services
• Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes

Creation of Anonymous Data

We may create anonymous data records from personal information by excluding information that is personally identifiable to you, such as your name. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

User Feedback

We may post user feedback on the Services from time to time. If you make any comments on a blog, social networking website, or forum associated with the Services, you should be aware that any information you submit there can be read, collected, or used by other users of these forums and could be used to send you unsolicited messages. We are not responsible for the information you choose to submit in these blogs and forums.

Disclosure of Your Personal Information

Third Parties Designated by You

When you use the Services, the personal information you provide will be shared with the third parties that you authorize to receive such information.

Third Party Service Providers

We may share your personal information with third-party service providers to provide you with the Services, provide updates and technical support, and market the Services.

Other Disclosures

Regardless of any choices you make regarding your personal information (as described below), we may disclose personal information if we believe in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on us; (iii) to protect or defend the rights or property of Alecci Media LLC, our subsidiaries, divisions, and affiliates or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms.

Your Rights Under the General Data Protection Regulation (GDPR)

• Right to Access – the right to be provided with a copy of your personal information
• Right to Rectification – the right to require us to correct any mistakes in your personal information
• Right to be Forgotten – the right to require us to delete your personal information—in certain situations
• Right to Restriction of Processing – the right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
• Right to Data Portability – the right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
• Right to Object – the right to object at any time to your personal information being processed for direct marketing (including profiling) and in certain other situations to our continued processing of your personal information
• Right Not to be Subjected to Automated Individual Decision-Making – the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the California Consumer Privacy Act (CCPA)

You have the right under the CCPA of 2018 and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information is collected
• Our business or commercial purpose for collecting or selling personal information
• The categories of third parties with whom we share personal information, if any
• The specific pieces of personal information we have collected about you

Right to Deletion

Subject to certain exceptions, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records
• Direct any service providers to delete your personal information from their records

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

Children's Online Privacy Protection Act (COPPA)

We understand the importance of protecting children's privacy and are fully compliant with COPPA. We do not knowingly collect personal information from children under the age of thirteen (13). Any information we need regarding children under thirteen (13) must be provided by his or her parent or guardian. If you are under thirteen (13), you are not permitted to use the Services and should not send any information about yourself to us through the Site.

In the event we become aware that we have collected personal information from anyone under the age of thirteen (13), we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at alexandria@aleccimedia.com.

Third-Party Websites

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another website, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and are not responsible for these outside websites or their content. Please understand that the terms of this Privacy Policy do not apply to any outside websites, content, or any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website that you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

Choice/Opt-Out

We want to communicate with you only if you want to hear from us. You may choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails, updating your communications preferences on our Site, or contacting us directly. Please note, however, that as a user of the Services, you cannot opt-out of some administrative communications that are reasonably necessary to the Services, such as billing notifications.

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, an updating, or the correction of inaccuracies in other personal information in our custody or control by contacting us directly.

Parents or legal guardians can review any personal information collected about their minor child, have this information deleted, request that there be no further collection or use of their child's personal information, and/or allow for our collection and use of their child's personal information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child's parent or legal guardian.

We reserve the right to retain any personal information, unless requested to be deleted by a parent or legal guardian of a minor child, reasonably necessary to appropriately document our business activities and record retention purposes. We will store personal information for as long as reasonably necessary for the purposes described in this Privacy Policy. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request where required by law, but please note that we may be required to keep such information and not delete it or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements.

California Residents

If you are a California resident and have an established business relationship with us, you may request a notice disclosing the categories of personal information we have shared with third parties, for the third parties' direct marketing purposes, during the preceding calendar year. To request a notice, please contact us directly.

Targeted Advertising

We may work with third parties, such as network advertisers and ad exchanges, that use tracking technologies on our Site in order to provide tailored advertisements on our behalf and/or on behalf of other advertisers across. We may use third-party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third-party websites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities (including past visits to our Site) and mobile media ("Targeted Advertising").

Targeted Advertising uses information collected on an individual's web browsing behavior on one website (such as the pages they have visited or the searches they have made) in order to target advertising to that individual on another website. Targeting called Cross Device Tracking can also take place across devices such as tablets, smartphones, laptops, and smart televisions. Third parties collect this information by placing or accessing cookies or other tracking technologies in your browser when you visit this or other websites.

You may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative ("NAI") members and your choices regarding having this information used by these companies, including the "opt-out" procedures of NAI members. You may also opt-out of receiving Targeted Advertising on participating websites and services by visiting the Digital Advertising Alliance ("DAA") website at http://www.aboutads.info/choices/.

Users Outside of the United States

The Site is maintained in the United States of America. By using the Site, you freely and specifically give us your consent to export your personal information to the United States and to store and use it in the United States as specified in this Privacy Policy. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time, and if we make any material changes in the way we use your personal information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on the Services and updating the "Last Updated" date below. If we make any changes to this Privacy Policy, they will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on the Services. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. Continued use of our Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.