Privacy Notice
This “Privacy Notice” describes the practices of Posh, Inc., and the rights and choices available to individuals, regarding personal data. Personal data means any information that relates to an identifiable individual.

Posh may provide separate privacy notices that apply to specific products or services that we offer, in which case thisPrivacy Notice does not apply. We may alter this Privacy Notice as needed for certain products and services and based on changes in the local laws and regulatory frameworks. This Privacy Notice does not apply to Posh’s processing of the personal data of its personnel, such as employees and contractors.

1. The personal data we collect 
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‍We may collect personal data directly from individuals and the parties with which we do business, including prospects. These may include parties that interact with us directly (such as individuals who visit our web-site or job applicants), parties to which we provide goods or services (such as clients, banks or financial institutions) (collectively, “clients”), parties that provide services to us (such as vendors) (collectively, “service providers”), end-users who will interact with our Services for the purpose of effectuating a support function by disclosing PII such as your username, password, email address or information, phone number, physical address, IP address or information, locations, transcripts of conversations with our AI rendering Services (collectively, “consumers”) and other parties with whom we offer or provide products and services (such as independent network organizations, system integrators) (collectively, “partners”).

We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, making an application for one of our products or services, interacting with us on social media, or corresponding with us. The types of information we obtain in these contexts include: 
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• Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address 
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• Profile information, such as username that an individual may establish on our website, along with any other information that an individual enters into their account profile 
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• Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory 
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• Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services 
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• Information related to the use of Posh products or services, such as account information, spending thresholds, spending activity and patterns, and information about the information we process 
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• Voice based biometric identifier and information necessary for authenticating the SaaS AI application customer

• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications 

• Other information such as job applicant data used when reviewing candidates profiles for job openings, etc.

Information that we collect about individuals who do not interact with us directly 

‍We may receive personal data about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our products or services. If you are providing us with the personal data of another individual, please ensure you have brought this Privacy Notice to their attention. In addition, due to the unique nature of our business, in many cases, we obtain personal data from other participants in a Chatbot message processing chain from its clients. The types of information we receive about third parties includes: 

• Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them 

• Information about potential job candidates, such as when a recruiter contacts us about an individual who may become a candidate for a job at Posh 

•Information about customers of our clients (referred as “consumers”) that our clients send to us or allow us to collect in the context of the services that Posh performs, such as information related to financial transactions initiated by the customer, account registrations, and in some cases information needed to verify a customer’s identity and details of products or services purchased, and as otherwise stated in an applicable specific privacy notice for a Posh product or service. Where our technology is incorporated into a client’s mobile application or website, we also may automatically collect certain information of the types described in the section below titled “Information collected via automated means.” 

Information collected via automated means 

‍When you access our Artificial Intelligence (“AI”) chatbots and related services (collectively the “Services”), we, our service providers, and our partners may automatically collect information about you, your computer or mobile device, and activity on our websites or mobile applications. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Certain products or services that we provide or which clients may incorporate into their websites or mobile applications may automatically collect additional information, as may be further described in a separate privacy notice. For clients who have opted in to voice-based biometric authentication for its customers, we will also collect voice samples transparently and pass it via API to our third-party service provider. This information is used for improving the hit ratio and positively authenticating the customers when they attempt to sign-in to the SaaS AI services. 

Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected via various mechanisms, such as via cookies, pixels, tags, web beacons, embedded scripts, through our mobile applications, and similar technologies. This type of information may also be collected when you read our HTML-enabled emails. You can choose to disable cookies or to opt out of the use of your browsing behavior for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Notice. 

Information we collect from private and publicly accessible sources 

‍We and our service providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet. We and or our third party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference and fraud prevention agencies, to the extent permitted under applicable law. 

We may also maintain pages for our company and our products and services on a variety of third-party platforms, such as LinkedIn, Facebook, Twitter, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them (e.g. for lead generation purposes), we will treat that information in accordance with this Privacy Notice. 

Sensitive personal data 

‍In case of specific clients who opt-in to perform voice based authentication for its customers, Posh integrates with third party service providers to collect and use voice-based biometric information. 

In the context of processing employment applications, we may also request sensitive information, such as racial or ethnic origin or information about disability, where required or permitted by law of the jurisdiction in which you are applying for employment. 

Outside of these contexts or otherwise as we specifically request, we ask that you not provide us with any sensitive personal data (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) and in the event provided, you are solely responsible for any sensitive information provided through our Artificial Intelligence (“AI”)chatbots, our website or otherwise to us. 

2. How we use your personal data 

‍We use your personal data for the purposes of: 

‍Providing our products and services, which includes: 

‍• Operating, evaluating, maintaining, improving, and providing the features and functionality of our products and services 

• Authenticating customers of the SaaS AI platform using a voice-based biometric information

• Fulfilling a banking transaction initiated by you (either with us or our client) 

• Managing our relationship with you or your company 

• Carrying out our obligations, and exercising our rights, under our agreement with you or your company

• Communicating with you regarding your account with us, if you have one, including by sending you service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our products or services, technical and security notices and alerts, and support and administrative messages) • Personalizing the manner in which we provide our products and services 

• Checking for fraud or money laundering and/or managing either our or our clients’ risk • Administering and protecting our business 

• Providing support and maintenance for our products and services, including responding to your service-related requests, questions, and feedback 

• We do not knowingly sell any Personal information which we collect 

For research and development 

‍We use the information we collect for our own research and development purposes, which include: 

•Developing or improving our products and services 

•Developing and creating analytics and related reporting, such as regarding Artificial Intelligence and Machine learning 

Marketing 

‍We may use your personal data to form a view on what products or services we think you may want or need, or what may be of interest to you. We may contact you with marketing communications using the personal data you have provided to us if you have actively expressed your interest in making a purchase or have made a purchase from us and, in any case, you have not opted out of receiving that marketing, to the extent permitted by applicable law. Where required by law, we will get your express opt-in consent before we disclose your personal data with any company outside of Posh for marketing purposes. 

‍Managing our recruiting and processing employment applications 

‍We process personal data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. 

‍Complying with law and regulations 

‍We use your personal data as we believe necessary or appropriate to comply with applicable laws and regulations, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. 

‍Compliance, fraud prevention and safety 

‍We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. 

‍For any other purposes with your consent 

‍In some jurisdictions, applicable law may require us to request your consent to use your personal data in certain contexts, such as when we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly. 

We will require consent and Opt-in from the customers of our clients, before requesting any voice-based biometric identifier and information. 

To create anonymous data 

‍We may create anonymous, de-identified, or aggregate data from your personal data and other individuals whose personal data we collect. We make personal data into anonymous, de-identified, or aggregate data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes. We may disclose aggregated information and information that does not identify any individual, without restriction. 

3. How we disclose your personal data 

‍Service providers 

‍We may employ third party companies and individuals to administer and provide services on our behalf (such as companies that provide customer support, companies that we engage to host, manage, maintain, and develop our website, SaaS AI applications, and IT systems). Please reference our “Data Protection Addendum” DPA for the list of the third-party service providers used and relevant to the delivery of the SaaS AI applications. 

‍Our clients 

‍When we perform services for our clients, we may disclose personal data with those entities. For example, we may collect information about a client’s customers from or on behalf of the client, such as when we process the messages posted via the Chatbot, we may provide personal data about those customers back to the client. We are not responsible for the privacy practices of our clients. 

Compliance with Laws and Law Enforcement; Protection and Safety 

‍Posh may disclose information about you to government or law enforcement officials (including tax authorities) or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our products and services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. 

‍To Other Parties with Your Permission or to Fulfill a Contract They Have With You 

‍Posh may transfer your personal data to any third party who is not otherwise covered by the other listed categories above where you have given us permission to do so, or with whom you have entered into a contract when we need to transfer your personal data to that party in order to fulfill that contract. 

‍Marketing communications 

‍You can ask us to stop sending you marketing messages at any time by clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages. 

‍Targeted online advertising 

‍Some of the business partners that collect information about users’ activities on our websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. 

‍Do Not Track Signals Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com. 

Accessing, modifying or deleting your information 

‍In some jurisdictions, applicable law may provide a right for individuals to access their personal data, correct inaccurate personal data, or delete their personal data in some circumstances. You may contact us directly at privacy@posh.tech to request access to, or modify or delete your information in accordance with the law in your jurisdiction. We may not be able to provide access to, modify, or delete your information in all circumstances. Please view the Data Protection

Addendum of this Privacy Notice for additional information on how you may exercise these rights if you live in these jurisdictions. 

‍Complaints 

‍If you have a complaint about our handling of your personal data, you may contact our data protection officer at privacy@posh.tech. We request that a complaint be made in writing. Please provide details about your concern or complaint so that our data protection officer can investigate it. We will take appropriate action in response to your complaint, which may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency. 

4. How we keep your data safe 

‍We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We ensure privacy data is encrypted at rest and also in transit with commercially reasonable industry standard encryption algorithms. You also acknowledge and agree that the transmission of information via the Internet is not completely secure. Although we have implemented commercially reasonable measures to protect your personal data, we cannot guarantee the security of such information. Any transmission of personal data is at your own risk. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

5.This Website May Link to Other Websites 

‍Posh may also link to third-party websites, mobile applications, and other content. We are not responsible for the privacy practices of any third party, and this privacy notice does not apply to such third party’s websites, mobile applications, or other content. We do not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked third-party website, mobile application, or other content. We are not responsible for any content on third-party properties to which we link. We provide links to third-party properties or content as a convenience, and visiting or using linked third-party properties or content is at your own risk. 

You acknowledge and agree that we do not control these service provider and business partner 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 service provider and business partner directly. For further information related to your right to privacy; please review our Data Processing Addendum.