This privacy policy ("Policy") explains how Adaya AI, Inc. (“Adaya”, “we”, “us” and “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) through https://www.adaya.ai (the “Site”) and the related content, platform, services, and other functionality offered on or through the Site (collectively, the “Services”). It does not address our privacy practices relating to job applicants, employees and other personnel.

Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By submitting Personal Information to us and/or by using or accessing our Services, you give your consent that all Personal Information that you submit may be processed by us in the manner and for the purposes described below. Therefore, before you provide us with any Personal Information, you should read through this Policy in its entirety and understand its terms.

Adaya collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). Adaya also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. on. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

Contact Information such as your billing address, delivery address, email address, telephone numbers, and, for business-to-business users, company name and legal entity name.

Identifiers such as your first name, last name, alias, username or similar unique personal identifier, account name, professional title, online identifier, country, and/or date of birth.

Financial Information such as credit or debit card information, payment details, bank account details, amount of transaction and category and ID of merchant, or other payment information.

Profile Data such as user name, password, employment information, data provided to customer support (e.g. subject of inbound phone calls and emails, ticket comments, ticket tags, ticket custom fields and audit events) and communication preferences.

Technical Information such as internet protocol (IP) address, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.

Transaction Data details about the products you have purchased, payments you have made, and/or other details of products and services you have purchased from us in the past, purchase or product preferences, personal interests, feedback, reviews, and survey responses.

Usage Data includes information about how you use our Services, such as statistics regarding the opening of and clicking on emails sent by Adaya and activity on the Site (e.g. pages viewed, products seen, etc.).

Marketing and Communications Information such as marketing campaign data, clickthroughs, clickstreams, referring URL, Google Analytics ID, your preferences and consent in receiving marketing from us and our third parties, email and text communications, and your communication preferences.

Inference Data including inferences drawn from the Personal Information identified above.

Where we need to collect Personal Information by law, or under the terms of a contract we have with you, 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 products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We collect Personal Information three ways: (1) directly from an individual when an individual provides us information when interacting with us in some way, (2) automatically when an individual interacts with our Services; and (3) from third-party sources, such as public data bases.

Adaya may collect Personal Information from you that to you voluntarily provide to us in various ways, including but not limited to:

Creating an account;

Booking a Strategy Session;

Completing any online forms on the Site;

Purchasing our products or services from us;

Call, e-mail, or otherwise communicate with us and/or third parties contracted by Adaya;

Respond to marketing e-mails; or

Otherwise interact with our Services or other Adaya platforms.

Automated Technologies or Interactions.  As is true of most digital platforms, we and our service providers receive and store certain types of Personal Information whenever you interact with us online. This information, depending on where you are located, can include Personal Information, such as: internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  When you access and use our website and platforms from your mobile devices, we receive data from that mobile device.  This may include your device ID, location data, IP address and device type.  You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings.  Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Cookies and Tracking Technologies. We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our website. For example, cookies gather information about how long you spend on a web pages are of interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features of the Site may not function properly.

We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Service Providers: Our service providers that perform services solely on our behalf—such as payment processors, website hosting providers, email service providers, scheduling software providers, chatbot platform providers, and marketing providers—collect Personal Information and may share some or all of this information with us.

Social Media Networks: When you interact with our Services through various social media networks, such as when you connect your account with Google, and Facebook, to our Services, “Like” us on Facebook or follow us or share our content on TikTok, Instagram, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. For example, integrate our services into your GSuite using your Google credentials, we receive your name and email address as permitted by your Google profile settings in order to authenticate you. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.


Publicly Available Sources: We collect Personal Information about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

Business Partners: When an individual interacts with our Services through or in conjunction with our business partners—such as partners who host and manage various online advertisements and ad platforms—we may receive some Personal Information about individuals that they permit our business partners to share with us. [This may be combined with website analytics data described below.]

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding visitors of our Site. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Site. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on how to opt-out from Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

[Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.]

[Third Party Cookies. We engage third-party service providers, including Google and Facebook, to serve interest based ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests.]

Third Party Cookies. We engage third-party service providers, including Google and Facebook, to serve interest based ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and

purchases in order to deliver targeted advertising based on your interests.

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

Where we need to provide products or services to you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

The European Union General Data Protection Regulation ("GDPR") and United Kingdom GDPR require us to explain the valid legal bases we rely on in order to process your Personal Information. As such, we have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

In addition, we may need additional information to fulfill your request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry, request, and/or Personal Information we require to fulfill the foregoing falls outside the scope of this Policy. In that case, such additional privacy disclosures will govern how we may process the information provided at that time.

We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners and service providers in order to provide you with our products and Services and perform any contract we enter into with them or you. We do not retain your Personal Information for a duration that is longer than reasonably necessary for the disclosed purpose. 

Information You Instruct Us to Share. You may be presented with an option on our Site to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. For example, with your consent, we may post your testimonial on our Site or service-related publications.

Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, communications services, website development services, payment processing services, accounting and audit services, customer support

services, scheduling platform services, compliance services, analytics services, and marketing services.

Internal Third Parties. We may share Personal Information with our successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Adaya who may use the Personal Information for the purposes described above.

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

[Sales of Personal Information. Like most companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our Site. This technology allows these advertising partners to receive information about your activities on our Site, which is then associated with your browser or device. These companies may use this data to serve you more relevant interest based ads as you browse the internet. Under some state laws, sharing data for online advertising may be considered a “sale” of information. Except for this sharing, Adaya does not sell any of your information. Adaya has no actual knowledge of any sales of Personal Information of minors under 16 years of age.]

The security of your Personal Information is important to us. Certain sensitive information submitted, such as credit card information, is encrypted using secure layer technology (SSL). However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

For individuals in the European Economic Area (“EEA”) or the United Kingdom, please see the Section entitled EEA and United Kingdom Privacy Rights in particular the Marketing paragraph of that Section for information relevant to them.

Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites. 

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If you are under the age of 13, you may not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, the child’s parent or guardian should contact us to request that we remove such Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.

For those in the GDPR Territories, "13" shall be replaced with "16", as applicable to such users.

Our Services may include integration with third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Policy, this Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy policies.

We do not retain your Personal Information for a duration that is longer than reasonably necessary for the disclosed purpose. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

You may opt out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by contacting us at [email protected]. If you wish to opt out, please send us an email to the address provided below and include “Opt-Out” in the email’s subject line along with your name and the email address you used to sign up for communications in the body of the email.

This opt out will not apply to operational or informational emails related to your account and purchases. You may continue to receive promotional email messages for a short period while we process your request.

Adaya wants your Personal Information to be complete and accurate. You represent and warrant that all information you provide in connection with your use of the website will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy. To confirm the completeness and accuracy of, or make changes to, your Personal Information, please contact us at [email protected]

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information, in the United States [and other countries.] By using the Services, you understand and acknowledge that your Personal Information will be transferred to and processed in the United States, which may have different data protection rules than in your country.

We will take steps reasonably designed to treat your Personal Information securely and in accordance with this Policy.

Notice to Users Located Within the European Economic Area, European Union, or United Kingdom ("GDPR Territories")

Standard Contractual Clauses; Terms. As is the case today, any transfers of personal data outside of the GDPR Territories must meet certain legal requirements. This includes where we act as processor on behalf of our customers. Transfers by our customers where we are processor are made using the Standard Contractual Clauses put in place through our GDPR Data Transfer Addendum referenced in the data processing terms or addendum applicable to the product.

Where Adaya acts as a data processor on the behalf of our European Union advertisers and business partners, we ensure that we comply with the specific requirements for data processors. We’ve updated any related terms of service to align with the GDPR. Where we appoint parties to act as data processor on our behalf, we’ve ensured that we have appropriate terms in place to comply with our requirements under the GDPR and to safeguard personal data. And where we act as a data processor on an advertiser's behalf, we rely on our advertiser's legal basis as data controller for our processing of this data.

Data Subject Rights. If you are located in one of the GDPR Territories, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed about what Personal Information we hold about you, have a copy of it, correct or otherwise rectify it, and/or if you want it to be removed from our systems, please contact us using the contact information set out below.

In certain circumstances, you have the following data protection rights:

Right to Access Personal Information. This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.

Right to Correct Personal Information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Right to Request Erasure of Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be explained to you, if applicable, at the time of your request.

Right to Object to Processing of Personal Information. You have the right to object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to Request Restricted Processing of Personal Information. This enables you to ask us to temporarily stop the processing of your Personal Information in the following scenarios: (a) if you have concerns about the accuracy of your information and want to have it rectified; (b) where you believe our use of your information may be unlawful but you do not want us to erase it; (c) where you need us to hold the information for the purposes of defending or exercising your rights with respect to a legal claim even though we may no longer need it; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to keep it.

Right to Request Transfer of Personal Information. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to Withdraw Consent. You have the right to withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA.

If you wish to exercise any of the rights set out above, please contact us using the contact details below. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure designed to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

California residents have the right to receive information that identifies any third party companies or individuals that Adaya has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at [email protected].  

We do not disclose a user’s Personal Information to any third party for such third-party's direct marketing purposes nor do we sell, rent or lease your Personal Information except as disclosed in this Policy. California, Nevada and Utah allow their residents to opt-out of the sale of their Personal Information; however, we do not sell any such information at this time. In the event of Adaya's sale of your Personal Information, you can opt-out of such sale by contacting us at [email protected].

We may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy.

When we make changes to this Policy, we will change the date at the beginning of this Policy. If we make material changes to this Policy, we will notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

For users in the EEA, the EU, the United Kingdom, or Switzerland, any changes or modifications will be effective upon your express consent, as you will be notified of any changes by virtue of a pop-up, banner, or other notification mechanism when you seek to access the Site or Services after we issue a change or modification. Upon consent, the revisions on the Site or Services shall apply to all use of the Site or Services and all acts or omissions occurring after the effective date of the revised Policy.

To the extent any provision of this Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email at [email protected].