Last Updated: [3/05/2024]

Flairr Inc, doing business as Brilo AI ("Brilo AI," "we," "us," "our"), values your privacy. This Privacy Policy outlines our approach to collecting, using, disclosing, and safeguarding your Personal Information, along with detailing your rights related to this information. It encompasses the data collected through our website and mobile website (collectively known as the "Site"), as well as information received directly from you or via third parties to provide our services or carry out business activities (collectively referred to as "Services").

This Privacy Policy is exclusively relevant to information gathered by Brilo AI via the Site and Services and does not extend to our handling of data processed on behalf of our Clients. For details on how our Clients, or we acting on behalf of our Clients, collect, use, and share your information, please consult the privacy policy of the respective Client.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using out Site and/or Services. By Accessing or using our Site and/or Services you agree to our use of your information consistent with the Terms of Use and this Privacy Policy.

1. CHANGES TO THIS PRIVACY POLICY

We occasionally update this Privacy Policy to reflect changes in our products and services and customer feedback, or if required by applicable US law. When we post changes, we revise the “last updated” date at the top of this statement. Your use of the Site is subject to the then effective Privacy Policy.

2. CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS

When local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

3. INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

· Identifiers such as name, mailing address, service address, email addresses, phone numbers, social security number, and Brilo AI account login information;

· Commercial information such as payment card or bank account information, and the type(s) of service subscribed to.

· Internet or other electronic network activity information such as browsing/search history, IP address, data collected by cookies and similar technologies, device information such as device IDs, specifications, and operating system;

· Geolocation data such as non-precise geographic location indicators from mobile devices, websites, and service addresses;

· Audio, electronic, visual, thermal, olfactory or similar information such as call recordings, chat transcripts, and email correspondence.

· Professional/employment information such as employer, and occupation;

· Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including credit reports and scores; and

· Personal information as described in Cal. Civ. Code § 1798.80(e)to the extent collected under another category of Personal Information above.

Some of the Personal Information listed above may be considered Sensitive Personal Information under relevant privacy laws. This includes Brilo AI account login credentials. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.

The type of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on our Site (“Usage Data”). For example, each time you use our Site, we may collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Site. Among other things, this data helps us estimate our audience size and usage patterns, recognize you when you return to our Site, store information about your preferences, customize our Site according to your interests, and speed up your searches. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the categories of Identifiers or Internet or other electronic network information, as appropriate. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages, chat transcripts, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

4. HOW WE COLLECT INFORMATION From You

We collect information from you when you use the Site with or without registration, upon registration, and when you use our Services. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction. You are responsible for ensuring the accuracy of the information you submit to Brilo AI in connection with your use of the Site. You are also responsible for the use of your password and its use by anyone to whom you disclose it or who obtains from you.

Third-Party Personal Information

We may gather Personal Information from external sources, including the clients we serve. Brilo AI utilizes third-party advertising and analytics services, along with cookies and automated tools, to analyze your usage of the site. Brilo AI and these services use "cookies," which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. Some of the information generated by the cookies about your use of the website (including IP address) is transmitted to service providers and used to evaluate your use of the Site and to compile statistical reports on website activity and audience data for Brilo AI. Furthermore, these services provide insights into how your ad views, usage of ad services, and engagement with these ads correlate with visits to our website. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.

You have the option to either accept or reject cookies. While most web browsers are set to accept cookies by default, you can adjust your browser settings to refuse cookies. Please note, however, that declining cookies through your browser settings might limit certain features on our Website.

When you sign up and utilize the Services, you agree to receive communications and promotional content from Brilo AI regarding services or products offered to you, or those you might find interesting, including offerings from our partners or external entities. You will be given the chance to unsubscribe from marketing messages by adhering to the opt-out instructions included in the communication.

5. HOW WE USE AND DISCLOSE YOUR INFORMATION Generally

We may use Personal Information for business purposes, such as to:

· Provide you with the Site and Services;

· Service consumer accounts;

· Communicate with you;

· Market products and services to you;

· Evaluate, develop, and improve business operations;

· Perform marketing and other types of research and analytics;

· Develop new or modified products and services;

· Operate information security and anti-fraud programs;

· Comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others;

· Perform day-to-day business operations such as accounting and general management; and

· Respond to governmental and other legal requests.

We use Sensitive Personal Information as follows:

· Brilo AI account login information – to permit access to customers’ online accounts, and in connection with our security and anti-fraud programs.

Additionally, we may employ Personal Information and/or Sensitive Personal Information as outlined at the time of collection, with your approval, or in accordance with legal requirements or permissions.

Service Providers

We may disclose your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:

· Fulfillment and account servicing vendors, which help us provide products, services and information to you, and service your account or benefits;

· Payment processors, which help us to accept and process the payments for our products/services to you;

· Marketing and communications vendors, which help us market our products/services to you, and conduct outreach campaigns;

· Research and development vendors, which help us develop and improve our products and services;

· Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);

· IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;

· Professional service firms, which provide accounting, legal, auditing, and other professional services; and

· General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure.

We disclose the following categories of personal information for a business purpose: Identifiers/Contact Information, Commercial information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.

Third Party Selling and Sharing

We do not sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Information to other companies who do not provide services to us.

Other Third-Party Disclosures

We may occasionally disclose your Personal Information to Third Parties, for purposes such as:

· To comply with the law;

· To respond to legal requests (including court orders, investigative demands and subpoenas) if, in our discretion, we believe it is necessary or appropriate;

· To prevent or stop any illegal, unethical, or legally actionable activity;

· To protect the safety, property, or rights of ourselves, consumers, or any other third party;

· If we are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of our assets and the disclosure is necessary to complete the transaction;

· To businesses controlling, controlled by, or under common control with us; and

· For additional purposes with your consent where such consent is required by law.

Links to Other Sites

The Site contains links to other third-party websites. Brilo AI is not responsible for the privacy practices of such third-party websites. We strongly recommend that you review the privacy policy of each website that you access prior to providing any personal information to make sure you understand what data is collected and how such data is used by third parties.

6. SECURITY

We understand the critical need to protect Personal Information against loss, misuse, or modification. To this end, we implement appropriate administrative, technical, and physical measures to secure Personal Information from unauthorized access, exposure, and misuse. However, it's important to acknowledge that no method of transmitting data over the Internet or any other network can guarantee absolute security. Therefore, despite our efforts to safeguard your information through our Site or Services, any information you transmit is at your own risk.

7. ADDITIONAL US STATE PRIVACY RIGHTS

If you are a resident of a state with an applicable privacy law, you may have additional rights to access and control your Personal Information. Exemptions may apply. Consumer privacy rights for residents of these states include:

Right to Access

You have the right to request twice per 12-month period that we provide you:

· the categories or specific pieces of Personal Information we collected about you;

· the categories of sources from which we collected your Personal Information;

· the business or commercial purpose for which we collected your Personal Information; and

· the categories of Third Parties with whom we sold, shared, or disclosed your Personal Information, including the categories of Personal Information sold, shared, or disclosed to each and the purposes for doing so.

Right to Deletion

You have the right to request that Brilo AI delete any of your Personal Information we have collected from or about you. We may not delete your Personal Information if Brilo AI:

· Needs to retain the personal information to comply with applicable law, exercise our rights, detect and protect against fraudulent and illegal activity, or comply with other legal obligations;

· Uses the personal information internally in a manner that you have authorized or is reasonably within your expectations as a consumer, such as if we need to complete a transaction for you.

Right to Correct

You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions for you to provide us with optional documentation to support your request and we will consider it. We may decline to correct your Personal Information if we determine that your request is fraudulent or abusive or if we determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Information instead of correcting it.

If you only wish to update your contact information or other Personal Information rather than disputing its accuracy, please make the changes directly in your account or email us at support@brilo.ai

Right to Appeal

You have the right to appeal our decision to deny, in full or in part, one or more of your privacy requests. We will process appeal requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision.

Right to Opt-Out from the Sale or Sharing of Personal Information

You have the right to direct us not to sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Information to Third Parties. We

will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.

How to Exercise Your Rights

If you are a California resident and would like to exercise your rights, you may submit a request by emailing us at support@brilo.ai . If you submit your request via email, please include at least your name, mailing address, email address, and a description of your request. We will confirm receipt of your request within 10 business days.

Following the submission of your request, we might reach out to request further details needed to confirm your identity. This could involve asking you to confirm information we already have on file or to provide a signed statement under penalty of perjury to attest to your identity. Your request cannot be processed until your identity has been verified, so we urge you to reply quickly. Should you fail to respond to our information requests in a timely manner, we reserve the right to reject your request.

Upon receiving a verified request for Right to Know, Deletion, or Correction, we commit to processing it within 45 days, taking into account any legal exemptions or extensions that could extend this period up to 90 days. If you maintain an online account with us, our response to your request will be delivered through that account. If not, we will offer you the choice of receiving our response either by mail or electronically.

Authorized Agent

Should you be acting as an authorized representative making a request for a California resident, it is required that you submit either a legal power of attorney or a written authorization signed by the consumer, in addition to verifying your identity. You may provide this documentation via email to support@brilo.ai after submitting the request. We may contact you and/or the consumer on whose behalf you claim to act to verify your authorization.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.

8. CONTACT US

For inquiries or feedback regarding this Privacy Policy and our practices related to privacy, please reach out to us at support@brilo.ai