• the date and time you access our website
• the pages you visit on our website
• if you navigate to our website by clicking a link, the location of that link
• the technical capabilities of the computer you use to access our website
• the internet service provider you use to connect to our website
• the IP address (a number automatically assigned to your computer whenever you are surfing the internet) from which you access our website

We use this information, in the aggregate, to make our website more useful to visitors, to learn about the number of visitors to our site, the types of technology used, to detect operational problems, and to improve our website's overall security. Any Individual Information you allow us to share will be associated with a random code, not with your name. "Individual Information" means the data are related to a single person and not aggregated or combined with data from other End Users.

1. DEFINITIONS

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect your Personal Information through different means, described below:

• Visitors to our Websites. When you access our Website through automated data tracking technology.
• Merchants' Customers. We may obtain your Personal Information from Merchants when we provide Services to Merchants. We process this Personal Information on our Merchants' behalf and recommend you review your Merchant's privacy policy and contact them with any complaints, questions or requests.
• Merchants and Account Holders. When you download, register with, or use our Platform; when you decide to interact with us, either by providing us your information through the registration page, login page or demo page on the Website; by email; regular mail; or telephone; or when you authorize third parties to provide us Personal Information. Most information we collect about Merchants is business information, not Personal Information. We use any Personal Information collected to support and better understand our Merchants and provide and improve our Services.
• Employees / Contractors / Applicants. If you apply for a job with Company, we use your Personal Information to consider hiring you. If we hire you, we will use your Personal Information in connection with your employment. A separate privacy notice may apply to employees.

3. WHAT THIS PRIVACY POLICY DOES NOT COVER

• Third-Party Websites. This Privacy Policy does not apply to any third-party sites that may link to or be accessible from the Websites or the Platform.
• Non-Personal Information; Anonymized Information. In some situations, we may rely on exemptions or other permitted conduct under applicable laws, including collecting, using, disclosing or storing Personal Information. Information about your business is not typically Personal Information. Anonymized information is also not considered Personal Information for the purposes of this notice. We may anonymize any Personal Information in our custody, in which case it will cease to be Personal Information.

4. TYPES OF PERSONAL INFORMATION WE COLLECT

We collect information which may be We collect information which may be considered Personal Information when maintained in an identifiable format. The applicable Personal Information is also summarized in Annex 1 below. Below are some examples of the Personal Information we may collect through our Services, Website or the Platform:

• Identifiers of Visitors to the Website. If you are a visitor to our Website we may collect (a) certain electronic information as described in the section titled, “Cookies Notice,” below; and (b) if you request information or a demo, we may collect your name, email address, and company name and business address, personal credit score, telephone/mobile number(s). When a visitor participates in interactive features on the Website, if any, the user may provide information to us, including without limitation through submission of “contact us” forms, customer support tickets or other forms.
• Identifiers of Merchants who Use our Platform. If you are a Merchant using our Platform, we may collect your real name; alias; city, state and country or location; unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers. We may obtain Personal Information that you provide to us relating to (a) the business contacts of our Merchants, including name, company address, telephone number, email address, job title; (b) the Merchant’s data about its own customers including Personal Information (“Merchant Data”); (c) financial information which may include your personal credit history, personal credit score, business transaction history and other credit/loan products and creditors; and (d) online reviews or feedback and any other content.
• Internet or other similar network activity. We collect information about an individual's interaction with our Website and the Platform.
• Phone Calls. We collect inbound phone call metadata (Whether a call was answered; and the duration of a call).
• Geolocation data. We do not use geolocation data. But we may receive information about an individual’s approximate physical location, such as city, state, and country, when they provide such information to us or as determined based on the individual’s IP address. Also, Merchant Data that we obtain from Merchants may contain additional information including billing addresses.
• Communications. When you communicate with us (via email, phone, through the Services or Website, or otherwise), we may maintain a record of your communication, including AI chats and robot chats.
• Business contact information. We may collect or receive contact information about personnel of actual and prospective customers, vendors, contractors, business partners and other similar third parties, which may include full name, email address, phone number, company, job title, and other similar identifying information.
• Payment information. We do not collect any payment information of Merchants. The VIA Services are a conduit for credit card data, which is passed through to the charging API and not stored by the Company.
• Prospective Merchants’ Customers We collect lead information (including the name, email address and phone numbers) for our Merchants and provide that information to our Merchants. Merchants may annotate the leads with information of their choosing (for example, whether a call-back is needed, or waiting on a bid), which is not controlled by the Company but stored by Company.
• Actual and prospective employees of Company. When an individual applies for employment with Company, or becomes an employee of Company, we collect information relating to that individual’s contact details, suitability for employment, background, employment history, salary and payment details, and other similar information.
• Information collected from third parties or public sources We may receive information from third-party sources, such as business partners, marketing service providers, third-party data aggregators, or publicly available sources, in order to make our own information more accurate and useful. Such information may include an individual’s full name, email address, phone number, company, job title and other contact information.

We may link together different types of information or link information to Personal Information. If linked information directly or indirectly identifies an individual person, we treat the linked information as Personal Information. Where we need to collect Personal Information by law, or under the terms of the contract between us and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services or the Platform). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case.

5. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

• Automated technical usage data. When a user accesses the Services or the Website, we automatically generate and retain records of how the user interacts with the Services and Website through cookies, web beacons, and other similar technologies. We collect information about your online activities over time and across third-party websites or online services, allowing the third party to track your online activities over time and across different sites when you use the Websites.
• We use Google Analytics which collects information which may include your IP address, device identifiers, device information (such as operating system type or browser type), cookies, referring and exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, crash data, and other similar technical data, which they provide to Company in anonymized form. We may use technologies such as cookies and/or scripts to collect this information. Please see the “Cookies Notice” section below for further information.
• Location information. We do not use geolocation data. But we may receive information about an individual's approximate physical location, such as city, state, and country, when they provide such information to us or as determined based on the individual's IP address.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

6. COOKIES NOTICE

We use cookies and related technologies ("Cookies") to provide our Services and Platform, gather information when visitors navigate through the Website to enhance and personalize the experience, to understand usage patterns, and to improve the Services, and the Website.

Cookies are small text files containing a unique string of characters that are stored in your web browser’s memory when you visit a Website. When you return to a Website that has placed a cookie in your browser, the cookie allows a Website provider to recognize that you have visited the site before.

Cookies on our Website may fall into the following categories:

• Necessary Cookies. These cookies are necessary to provide you with the Services and the Website to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how the Services and the Website function. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on Website other than the Website.
• Functional Cookies. These cookies allow us to provide you with a better experience when you use the Services and the Website through customized settings. These cookies do not collect identifying information about you, and they do not monitor or remember any of your interaction with the Website or Platform.
• Targeting Cookies. These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other Sites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings. See CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below for further details on how you can control third-party targeting cookies.
• Google Analytics. Our Website and Platform may use Google Analytics. Google Analytics uses cookies to help us to analyze how users use the Website. It counts the number of visitors and tells us things about their behavior in the aggregate. Google Analytics does not associate your IP address with any other data held by Google. you may see how Google uses data when you use our Website and Platform at https://policies.google.com/technologies/partner-sites.

7. HOW WE PROCESS, SHARE AND DISCLOSE PERSONAL INFORMATION

Much of the Personal Information we process is necessary to provide our Services and meet our contractual obligations. In this Privacy Policy, to “process” Personal Information means to perform any operation on Personal Information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying. In most other situations, we rely on our legitimate interest (which, in some countries, would be “implied consent” or a legal exception to the consent requirement, such as where the processing is to prevent fraud). The specific purposes for which we process Personal Information include:

• To communicate with you;
• To provide our Services and Platform to you;
• To administer, manage, test and improve our Services;
• To better understand the Services, such as through reporting and analytics;
• To deliver information to third parties including Merchants;
• To market and advertise our Services;
• To fulfil any other purpose that would be reasonably apparent to the average person at the time of collection; and
• For any other purpose with your consent.

While not stated as a purpose below, we may also use any Personal Information:

• For security purposes, including to detect, prevent and investigate potential fraud; and
• Where required or permitted by law.

We may also request express consent to process your Personal Information in some circumstances, such as when you sign up to use our Platform, or when you visit our Website, and we use cookies. We may also de-personalize information, such as through anonymization or aggregation. We may use and disclose such information for any purpose, as it will no longer identify you or any other person.

We do not sell your Personal Information to third parties (as “sell” is defined in California law). A “sale” would not include a situation where someone is buying all or part of our business (as is explained further below).

We do not track your individual-level activity on the internet outside of our Websites.

We share your Personal Information with our employees, contractors, consultants and other parties such as affiliates and third-party companies that assist us in providing our Services, including marketers, customer support and hosting services. Below is a non-exhaustive list of the third parties that may have access to Personal Information under our control.

The following table outlines recipients to whom we may disclose your Personal Information, as well as the purpose of such disclosure. When we disclose your Personal Information, we cease to control it, and the recipient’s policies and procedures will apply. Where required by law, we will obtain your consent before disclosure.

8. PROCESSING PERSONAL INFORMATION OUTSIDE THE U.S.

We may disclose Personal We may disclose Personal Information to third parties both in and outside of your country, and as result, your Personal Information may be collected, used, disclosed or stored in another country, including Canada, as well as in the United States of America. Laws relating to privacy vary between countries, and your Personal Information may be processed in a country with less stringent laws than the laws in your country. Personal information may be accessible to governments, courts, or law enforcement, national security authorities or and regulatory agencies of these countries in accordance with applicable laws.

9. PAYMENT INFORMATION

We use a third-party payment provider to process payments from Merchants. We do not collect Personal Information related to credit cards or other payment information. The payment provider will collect, use and disclose that information in accordance with its own privacy policy.

10. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• How to Control Cookies. You can review your Internet browser settings, typically under the sections “Preferences,” “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you choose to block all cookies, you may not have access to our Website, our Services will not function as intended, and you will not be able to log in. If you have blocked all cookies and wish to make full use of the features and Services we offer, we recommend enabling at least first-party cookies. Rather than blocking all cookies, you can choose to block only third-party cookies. This will allow the Services to function as intended.
• To learn more about the use of Cookies by Google for analytics, please see https://policies.google.com/technologies/cookies. To exercise choice regarding those Cookies, please see the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. The opt-outs described above are device- and browser-specific and may not work on all devices.
• Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own products or services, you can opt-out by sending us an email stating your request to info@via.site. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

11. ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your You can review and change your Personal Information by logging into the Platform and visiting your account profile page. You may also send us an email at info@via.site to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

12. YOUR STATE PRIVACY RIGHTS

You may have additional rights under state consumer privacy laws of your state of residence regarding our use of your Personal Information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their Personal Information,
• Access and delete certain Personal Information,
• Correct inaccuracies in Personal Information, taking into account the processing purpose (excluding Iowa and Utah),
• Data portability, and
• Opt-out of personal data processing for targeted advertising (excluding Iowa).

We will not discriminate against you for exercising any of your rights as described above.

As a security measure, our Privacy Officer may request specific information from you in order to verify your identity prior to granting any requests. If we cannot respond to your request promptly or have to refuse the request, we will advise you of the reasons, subject to any legal restrictions. If you disagree with our determination, you may complain to us, and we will reconsider. If you are not satisfied with our ultimate determination, you may contact your local data protection authority or privacy commissioner. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

Where permitted by law, we may refuse or charge a fee for repeat, abusive or inappropriate requests.

13. RETAINING YOUR PERSONAL INFORMATION

We only store Personal Information as long as necessary to fulfill the purposes for which the Personal Information was collected, to conduct our business operations and maintain an appropriate historical record of our relationship with you, or in order to comply with applicable laws, whichever is longer, after which time the Personal Information is destroyed or erased. We may, instead of destroying or erasing your Personal Information, make it anonymous such that it cannot be associated with, or tracked back to, you.

14. DATA SECURITY FOR PERSONAL INFORMATION

We take steps to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of your Personal Information. These safeguards are intended to prevent your Personal Information from loss and unauthorized access, copying, use, modification or disclosure. 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 our Services or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Also, the Internet is not a secure environment, and no computer system is perfectly secure. As such, we cannot guarantee the security of Personal Information provided to us through electronic means; there is always a risk that your Personal Information may be accessed or used without authorization.

15. PERSONAL INFORMATION OF CHILDREN

We will not collect, use, disclose and store Personal Information of children under the age of 13 without the consent of a parent or guardian. If you believe that a child under 13 may have provided us with Personal Information without the consent of a parent or guardian, we request that you contact us immediately.

California Minors:

If you are a California resident who is under the age of 16 and you are unable to remove publicly available content that you have submitted to us, you may request removal by contacting us at the Contact Us information below. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it.

We are not required to remove any content or information that:

1. federal or state law requires us or a third party to maintain;
2. was not posted by you;
3. is anonymized so that you cannot be identified;
4. you don't follow our instructions for removing or requesting removal; or
5. you received compensation or other consideration for providing the content or information.

Removal of your content or information from the Service does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

16. UPDATES TO THIS PRIVACY POLICY

This Policy may change from time to time. Your continued use of this Website or our Services after we make changes to this Privacy Policy is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

17. CONTACT US

ANNEX 1

SMS COMMUNICATIONS

If you opt in to receive text messages from Via AI Growth LLC (Via.site), we may send you marketing and promotional messages, including updates about products, services, offers, and related information.

Message frequency may vary. Message and data rates may apply.

You may opt out at any time by replying STOP to any message you receive. After you send STOP, we will confirm your opt-out by SMS and you will no longer receive SMS messages unless you opt in again.

For assistance, reply HELP to any message or contact us at info@via.site.

Consent to receive marketing text messages is not a condition of purchase.

Text messaging originator opt in data and consent will not be shared with any third parties, excluding aggregators and providers of the text message services.