LEVEL AI PRIVACY POLICY

Effective Date: January 19, 2024

Last Updated/Reviewed on: January 19, 2024

1. Introduction.

Ujwal Inc. dba Level AI (“Company” or “We”) respects your privacy and is committed to protecting it through this policy.

This policy describes the personal data collected or processed when you interact with the Company, including through our websites, our desktop applications, online or offline events, or one of our other products or services, all of which are part of the Company’s Platform (“Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

1. This policy does not apply to information collected by:

• Any third party (including our clients), including through any application or content (including advertising) that may link to or be accessible from or through the Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this element of the Platform, you agree to this privacy policy.

2. Children Under the Age of 16.

Our Platform are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Platform. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

3. Information We Collect.

Our Platform collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information that is excluded under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), such as the examples listed below:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or the California Confidentiality of Medical Information Act, clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, or the Driver’s Privacy Protection Act of 1994.

In particular, our Platform has collected the following categories of personal information and/or sensitive personal information from consumers within the last twelve (12) months:

4. How the Platform Collects Information.

Our Platform obtains the categories of personal information listed above from the following general categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Platform.
• From third parties, for example, our business partners.

1. Information You Provide to Us.

In particular, the information we collect on or through our Platform, that you provide to us, may include:

• Information you provide by filling in forms on our Platform. This may include such things as information provided at the time of registering to use our Platform or creating an account, subscribing to a service, posting material, or requesting further services or information. We may also ask you for information in connection with a promotion or when you report a problem with our Platform.
• Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Platform.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete or other forms of feedback you may provide.
• Your search queries on the Platform.

2. Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with the electronic elements of our Platform, such as our website and desktop application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• If you use or your employer installs our desktop screen recording application, we may record all of the contents of your computer screen, associated audio, and certain actions you take on your computer that may be associated with triggering or ending screen recording.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Platform according to your individual interests.
• Speed up your searches.
• Provide analytics to your employer regarding your work and your interactions with your employer’s customers.
• Recognize you when you return to our Platform.

1. The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
• Screen Recording. A screen recorder is a desktop application that monitors certain applications on your computer and records video and/or images of the contents of your computer screen and/or audio associated with the contents of your computer screen.

2. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Platform are served by third-parties, including analytics providers, advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. Use of Personal Information.

We do not “sell” personal information under that common meaning of that word. However, we may disclose non-sensitive personal information to certain third parties, such as Google Ads, as set forth above, which access may or may not be considered a sale, according to the CCPA’s definition of “sale,”

We may use, share, sell (as defined under the CCPA), or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Platform, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Platform and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Platform users/consumers is among the assets transferred.
• If you are an agent or a customer interacting with one of our business partners, to provide analytics and services to such business partner.
• For any other purpose with your consent.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

1. Business Purpose Disclosures of Personal Information.

We may disclose your information to certain outside persons or organizations (“Outside Person”), including but not limited to service providers, for a business purpose. We only make these business purpose disclosures under written contracts that, among other things: (i) describe the business purposes; (ii) require the Outside Person to comply with the CCPA, including providing the same level of privacy protection as the CCPA requires; (iii) require the Outside Person to notify Us if the Outside Person can no longer meet its obligations under the CCPA and prohibit the Outside Person; and (iv) prohibit using the disclosed information for any purpose except performing such contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

For more on your personal information sale rights, see Personal Information Sales and Sharing Opt-Out and Limit the Use of Sensitive Personal Information. Our “Business Partners” means the companies that hire us to provide analytics and artificial intelligence services regarding their customer service agents and interactions between customers and their customer service agents.

2. Reselling Personal Information.

The CCPA prohibits an Outside Person from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales, and the CPRA expands that resale restriction to include personal information about a consumer shared with a third-party for cross-context behavioral advertising purposes.

6. Your Rights and Choices.

The CCPA and CPRA provide certain consumers with specific rights regarding their personal information. To the extent you are a California consumer and the CCPA applies, this section describes your rights and explains how to exercise those rights.

1. Right to Know and Data Portability.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Rectify), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

2. Right to Delete.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Rectify), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

3. Right to Rectify.

You have the right to request that we rectify certain inaccurate personal information about you (the “right to rectify”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Rectify), we will review your request.

4. Exercising Your Rights to Know, Delete, or Rectify.

To exercise your rights to know, delete, or rectify as described above, please submit a request by either:

• Emailing us at [email protected].
• Visiting: https://thelevel.ai/correct-personal-information/

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or rectify related to your personal information. You may also make a request to know, delete, or rectify on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know, delete, or rectify must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Your first and last name.
  • Your physical address.
  • The email address that is used for your account on the Platform, or if you do not have an account, the email address you used to communicate with us or that you may have otherwise provided to us such as during a phone call with any of our personnel or representatives.
  • The phone number that is used for your account on the Platform, or if you do not have an account, the phone number you may have otherwise provided to us such as during a phone call with any of our personnel or representatives.
  • If you are a parent or guardian of a minor from whom you believe we have collected personal information, please provide the information required above to the extent possible for the minor along with your first and last name, physical address, and relationship to the minor.
  • If you are an authorized representative of an individual from whom you believe we have collected personal information, we may require that you provide proof that the individual gave you signed permission to submit the request and may also require that the individual verify their own identity directly with us or directly confirm with us that they provided you with permission, unless you have a power of attorney from the individual that you can provide to us.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know, delete, or rectify.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale or sharing opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

5. Response Timing and Format.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6. Personal Information Sales and Sharing Opt-Out and Limiting the Use of Sensitive Personal Information.

If you are age 16 or older, you have the right to direct us to not sell your personal information, to not share (as defined in the CCPA) your personal information, and to limit the processing of your sensitive information (collectively, the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales, sharing, or expanded use of sensitive personal information may opt-out of the foregoing at any time. Because we do not use sensitive personal information other than for purposes that would be permitted under the CCPA, even after a request by a consumer to opt-out of expanded use of sensitive personal information, we do not provide an option to limit the processing of your sensitive information.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

• Do Not Sell or Share My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales, personal information sharing, and expanded use of sensitive personal information. However, you may change your mind and opt back in at any time by submitting a request, as set forth above, with respect to Exercising Your Right to Know, Delete, or Rectify.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

7. Additional Choices About How We Use and Disclose Your Information.

We strive to provide you with choices regarding the personal information you provide to us. In addition to the opt-out rights provided above in the Personal Information Sales and Sharing Opt-Out and Limiting the Use of Sensitive Personal Information section of this policy, we have additional mechanisms listed below to provide you with more choices on how we use your information.

• If we have sent you a promotional email, you may be able to unsubscribe from future emails by clicking on the link provided in the email.

We do not control third parties’ collection or use of your information. However, some third parties may provide you with ways to choose not to have your information collected or used in certain ways. For example, the Network Advertising Initiative provides certain opt-out rights on its website.

Residents of certain states may have additional personal information rights and choices.

8. Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA and the CPRA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA or the CPRA that can result in different prices, rates, or quality levels. Any such permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

9. Data Security.

We have implemented measures designed to protect your information. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform. The information you share in public areas may be viewed by any user of the Platform.

Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to protect your information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

10. Automated Decision-Making Technology.

We do not use automated decision-making technology as defined in the CCPA.

11. Data Retention.

We may retain your personal information for the longest of: (i) as long as necessary for the purposes set forth in this policy or otherwise communicated to you, including providing our services to you; or (ii) as long as your account is active. We also retain your personal information to the extent necessary to comply with our legal obligations.

12. “Do Not Track” Policy.

Our Platform does not respond to Do Not Track signals.

13. Your State Privacy Rights.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. If such laws apply to us and to you, we will honor their provisions

14. Changes to Our Policy.

We reserve the right to amend this policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on applicable elements of our Platform and update the notice’s effective date. Your continued use of such elements of our Platform following the posting of changes constitutes your acceptance of such changes.

15. Application of Policy.

Given that the Internet allows users from around the world to view certain electronic elements of our Platform, not all provisions of this policy may apply to every visitor or user of the Platform. The applicability of certain provisions may depend on a variety of factors including, but not limited to, in which country or state the visitor resides and which laws and regulations apply to the Company. Accordingly, the Company reserves the right to disclaim the applicability of any provisions in this policy if the Company is not actually subject to and required to comply with the particular law which the provision is meant to address.

16. Contact Information.

If you have any questions or comments about this notice, the ways in which Level AI collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

• [email protected]

If you need to access this policy in an alternative format due to having a disability, please contact us using the above contact information.

17. Digital tracking addendum.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout .