Privacy Policy

CALIFORNIA PRIVACY NOTICE

1. Scope of This Notice

This California Privacy Notice (the "CA Notice") supplements the information contained in our Privacy Policy above and applies solely to individual residents of the State of California ("consumers" or "you") within the scope of the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA).

2. Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

• Internet/Network Information: such as device meta information, logs and analytics data;
• Geolocation Data: such as your approximate location based upon your IP address;
• Inferences: such as information generated from your use of the Services reflecting predictions about your interests and preferences.
• Chatbot and Conversational Data: including conversation transcripts, messages you send and receive through our Chatbot Services, contact information you provide (name, email, company, job title, industry), behavioral tracking data (pages visited, time spent, scroll depth, click events), session information, and computed intent assessments generated by our AI systems.
• Identifiers: including session IDs, conversation identifiers, and other unique identifiers associated with your chatbot interactions.

We collect this from: directly from you, from your browser or device when you use our Services, or from third parties that you permit to share information with us.

For details about how we use this information, please refer to Section 3 (How We Use Your Information) of our main Privacy Policy.

3. Disclosure of Personal Information

As described in Section 4 (How We Share and Disclose Information) of our main Privacy Policy, we do not share any personal information with third parties for their direct marketing purposes. We do not "sell" personal information as traditionally defined, but may share identifiers for cross-context behavioral advertising.

4. Your California Privacy Rights

If you are a California resident, you have the following rights under the CCPA/CPRA:

• The Right to Access/Know: Request information relating to your personal information we have collected and disclosed in the last 12 months, including the categories of personal information collected, the sources from which we collected it, the business or commercial purpose for collecting it, the categories of third parties with whom we shared it, and the specific pieces of personal information we collected about you.
• The Right to Request Deletion: Request the deletion of personal information we have collected from you, subject to certain exceptions under applicable law.
• The Right to Correct: Request correction of inaccurate personal information we maintain about you.
• The Right to Opt-Out of Sale/Sharing: Opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes.
• The Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• "Shine the Light": California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes.

5. How to Exercise Your California Privacy Rights

To exercise your rights, please submit a request by emailing us at info@genleads.com with the subject line, "California Rights Request."

Verification: We will need to verify your identity and confirm you are a resident of California. This may require the matching of sufficient information you provide us to the information we maintain about you (e.g., cookie ID, mobile ID, IP address).

Authorized Agents: You are permitted to use an authorized agent to submit requests on your behalf where we can verify the agent's authority to act on your behalf via power of attorney or signed permission.

Response Time: We will respond to your request within the timeframes required by applicable California law.

EUROPEAN PRIVACY NOTICE

This European Privacy Notice applies if you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland. This notice supplements our main Privacy Policy and provides additional information required under the General Data Protection Regulation (GDPR), UK GDPR, and applicable Swiss data protection laws.

1. Scope and Controller Information

For purposes of the GDPR, UK GDPR, and applicable Swiss data protection laws, AdChats LLC dba GenLeads.com is the data controller responsible for the processing of your personal data in connection with our Services.

2. Legal Bases for Processing

We process your personal data automatically collected (Device data, Analytics, etc.) under the following legal bases:

• Legitimate Interests (Article 6(1)(f) GDPR): To monitor and resolve issues with the Services, to improve the Services generally, and to inform our direct marketing. We have balanced our legitimate interests against your privacy rights and determined that our processing is necessary and does not override your fundamental rights and freedoms.
• Consent (Article 6(1)(a) GDPR): Where required by law, we will only use your personal data to serve you relevant and personalized advertisements to the extent you have given us consent. You may withdraw your consent at any time.

Chatbot and Conversational AI Data: We process chatbot conversation data, behavioral tracking data, and contact information you provide during chatbot interactions under the following legal bases:

• Consent (Article 6(1)(a) GDPR): When you voluntarily provide contact information or engage in conversations through our Chatbot Services, you consent to the processing of such data for the purposes of responding to your inquiries and providing follow-up communications.
• Legitimate Interests (Article 6(1)(f) GDPR): We process behavioral tracking data and use AI to personalize chatbot interactions based on our legitimate interest in providing improved user experiences and understanding user needs. We have balanced this interest against your privacy rights and determined that such processing is necessary and does not override your fundamental rights and freedoms.
• Contract Performance (Article 6(1)(b) GDPR): Where you request information, case studies, or other materials through the chatbot, we process your data to fulfill your request and perform our contractual obligations.

You have the right to object to processing based on legitimate interests at any time, and you may withdraw your consent for chatbot data processing by contacting us at info@genleads.com. Note that withdrawing consent may affect the functionality and personalization of our Chatbot Services.

3. Data Retention

We store personal data no longer than necessary for the purposes set out in this Privacy Policy, considering the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means, as well as applicable legal requirements.

4. International Data Transfers

The personal data we collect may be transferred to and stored in countries outside of your jurisdiction, including the United States. In such cases, we ensure the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses (also known as Standard Contractual Clauses or SCCs) adopted by the European Commission, or other appropriate legal mechanisms to ensure an adequate level of data protection in accordance with applicable data protection laws.

5. Your Rights Under GDPR/UK GDPR

If you are located in the EEA, UK, or Switzerland, you have the following rights regarding your personal data:

• Right of Access (Article 15 GDPR): Obtain confirmation of processing and a copy of the data held, including information about the purposes of processing, categories of personal data, recipients, retention periods, and your rights.
• Right to Rectification (Article 16 GDPR): Obtain rectification of inaccurate or incomplete data.
• Right to Erasure (Article 17 GDPR): Require us to erase your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent and there is no other legal basis for processing.
• Right to Restriction of Processing (Article 18 GDPR): Require us to limit the purposes of processing in certain circumstances.
• Right to Data Portability (Article 20 GDPR): Receive a copy of your data in a structured, machine-readable format and transmit that data to another controller where technically feasible.
• Right to Object (Article 21 GDPR): Object to processing based on our legitimate interests or for marketing activities. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: You have the right to withdraw your consent at any time where processing is based on consent. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority (supervisory authority) if you believe that our processing of your personal data violates applicable data protection laws.

To exercise these rights, contact us at info@genleads.com. We will respond to your request within one month, or within two months if the request is complex, in accordance with applicable data protection laws.

6. Children's Privacy

The Services are not directed at persons under 16 in the European regions. We do not knowingly collect personal data from any persons under the age of 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

COOKIE NOTICE

This Cookie Notice explains how we use cookies and mobile advertising IDs to manage and provide our online services. This notice supplements our Privacy Policy and provides specific information about our use of cookies and similar tracking technologies.

1. What Are Cookies and Mobile Advertising IDs

Cookies are tiny files downloaded to your computer that allow us to collect information about your interaction with our Services. We also utilize mobile advertising IDs (Google advertising ID on Android and IDFA on iPhone) to improve our advertising service.

Cookies and similar technologies help us:

• Remember your preferences and settings
• Understand how you use our Services
• Deliver relevant and personalized advertisements
• Measure the effectiveness of our advertising campaigns
• Improve our Services and user experience

2. Types of Cookies and Tracking Technologies We Use

We automatically collect log data about your device and software: IP address, operating system, browser type, date/time of visit, and analytics data helping us measure usage and activity trends. We also collect approximate location data based on IP address.

We use the following types of cookies and tracking technologies:

• Essential Cookies: These cookies are necessary for the Services to function and cannot be switched off in our systems.
• Analytics Cookies: These cookies help us understand how visitors interact with our Services by collecting and reporting information anonymously.
• Advertising Cookies: These cookies are used to deliver advertisements that are relevant to you and your interests, and to measure the effectiveness of advertising campaigns.
• Mobile Advertising IDs: We use mobile advertising identifiers (Google Advertising ID on Android devices and IDFA on iOS devices) for advertising and analytics purposes.

3. Your Choices About Cookies

If you prefer not to accept cookies via browser settings:

• Navigate to browser settings to notify you of cookies, disable existing cookies, or set browser to reject cookies.
• Note: Disabling cookies may negatively affect the functionality of the Services.

Most web browsers allow you to control cookies through their settings preferences. However, limiting the ability of websites to set cookies may worsen your overall user experience. For more information about how to manage cookies in your browser, please visit your browser's help documentation.

4. Choices About Mobile Advertising IDs

To opt out of ads personalization on mobile devices:

Please note that opting out of personalized advertising does not mean you will no longer receive advertisements. You will continue to receive advertisements, but they may be less relevant to your interests.

5. Third-Party Cookies

Some cookies are placed by third-party services that appear on our Services. We do not control the setting of these cookies, so please check the third-party websites for more information about their cookies and how to manage them.

6. Updates to This Cookie Notice

We may update this Cookie Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated notice on this page and updating the "Last Revised" date at the top of our Privacy Policy.