Privacy Policy

Introduction

Your privacy is important to us, and we are committed to fair practices that protect your information. This “Privacy Policy” applies to www.villagers.co (the “Site”) and our retail consumer analytics and communications and marketing platform (the “Software,” and together with the Site, the “Platform”), which are owned and operated by Villagers IRL, Inc. (“we,” “us,” or “our”). This Privacy Policy explains how we collect, use, and disclose personally identifying information (“Personal Information”) gathered through the Site and Platform.

Definitions

For clarity, this policy uses the following definitions:

• “Visitors”: Individuals who browse our website without creating an account
• “Merchants”: Retail businesses (i.e., our customers) that registered to use our Platform
• “Users”: Our Merchants' personnel who use our Platform
• “End Customers”: The customers of our Merchants, whose data we process through the Platform

Information We Collect and Process

Visitor Information

We collect and process:

• Device Information: IP address, browser type, device type, and information uploaded to the Site by you
• Contact Information: Data you provide through contact forms

End Customer Information Collected from Merchants

We may collect (or receive) from Merchants and process on Merchants' behalf:

• Platform Usage: How End Customers use our tools and features
• Transaction Records: Information that may contain End Customers' invoices, orders, service agreements, and message history
• Contact Information: End Customers' name, contact information, and communication preferences

Uses of Personal Information

We may use End Customer and Visitor information to:

• Provide, market, and improve our products and services
• Evaluate business opportunities
• Respond to requests or inquiries from Merchants, End Customers, and Visitors and/or as required to meet our legal obligations
• Analyze an End Customer's interactions with the Platform

Additionally, we may share information:

• With third parties for marketing, advertising, research or other reasonable business purposes
• As required to respond to legal processes
• In order to protect our rights
• With third parties in the event of a corporate transaction
• With third party vendors that provide services to us and/or our Visitors and Merchants in connection with the Platform

Merchant to End Customer Communications Through the Platform

If and to the extent authorized by an End Customer in connection with its agreement with a Merchant, such Merchant can deliver email and text messages to such End Customer via the Platform.

Service-Related Messages

Merchants may send individual service-related messages to their End Customers such as:

• Specific orders, repairs, or services
• Appointment scheduling and confirmations
• Personal invitations for services
• Responses to End Customer inquiries
• Account or service updates

Promotional Messages

Merchants may send promotional messages through the Platform such as:

• Broadcast messages to multiple End Customers
• General promotional content
• Sales announcements or offers
• Group event invitations
• Newsletter-style updates

For purposes of the Platform, Merchants are required to warrant that each End Customer:

• Opted in to receive text and email messages through the Platform
• Permits us to collect and store their contact information
• Understands that data about such End Customer's use of text and email messaging will be shared with the SMS and email provider(s) for purposes of providing the Platform

Each End Customer's agreement with its Merchant is specific to such individual End Customer's relationship with the Merchant. If an End Customer does not believe it authorized a Merchant to provide us with any of the foregoing authorization, such End Customer should contact us using the contact information set forth below. If an End Customer desires to update its permissions with one of our Merchants, such End Customer should contact such Merchant directly (as each Merchant is responsible for this data and these permissions). Please note we will be unable to process most of your requests immediately but will endeavor to do so as promptly as commercially practicable.

Aggregated and Blinded Uses of Personal Information

Our Software uses or may in the future use artificial intelligence and machine learning modules to analyze Personal Information in aggregate, anonymized, and blinded formats. Using artificial intelligence and machine learning modules or other tools, we may aggregate, anonymize, and/or de-identify Personal Information for the purposes of:

• Analyzing the effectiveness of our Platform
• Improving and adding features to our Platform
• Conducting research and performing analytics with respect to our Platform

We will not make any attempts to reidentify information that has been anonymized and/or de-identified. Data generated by the Software is owned by us.

Third Party Data Sharing

Third Party Vendors

We may use third party vendors to:

• Collect personally identifiable information
• Process messages through SMS, social media, and email delivery
• Integrate with point of sale systems to import Merchant data
• Process payments for Merchant billing
• Analyze the performance of the Platform
• Provide customer service or support

We are not responsible for the information practices of third parties. Any access to use of third party links on the Site or in the Platform are governed by such third party's privacy policy and we are not responsible for any acts or omissions of such third party. Except to the extent set forth herein, these third parties are prohibited from using your Personal Information and we exercise commercially reasonable efforts to ensure they contractually agree to treat your Personal Information as confidential.

Cookie Use and Tracking

We collect information through our servers and filtering systems when you visit our website. Cookies are small text files placed on your computer that collect standard internet log information and track website activities.

We may use cookies to:

• Keep Merchants and Users signed in
• Enable website features
• Understand how Merchants and Users use our Platform
• Improve Platform performance
• Store Visitor and Users preferences
• Track email engagement

Information we collect:

• Browser type and operating system
• Language preference
• Referring web pages
• Visit dates and times
• Search information
• Page visit paths
• Website usage patterns

Cookie Management: You control cookie settings through your browser. Not accepting cookies impacts some Platform features. Learn more at www.allaboutcookies.org.

Web Beacons

Web beacons are tiny graphics, similar in function to cookies, that track the online movements of users. They are not stored on your computer and may not be disabled or controlled through your browser.

Compliance with Certain Laws

California Privacy Rights and Laws

Under California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and related privacy laws, California residents have specific rights regarding Personal Information. We comply with these laws by:

• Not selling Personal Information
• Retaining Personal Information for no more than 84 months
• Providing rights to access, delete, opt out of data sharing, correct Personal Information, and request information about data sharing practices

Under California's “Shine the Light” law (California Civil Code Section 1798.3), you can request a summary of our annual disclosures to third parties of your Personal Information for direct marketing purposes. To obtain this information, please email us at irl@villagers.co and place “Shine the Light Request” in the subject line. Please be aware that not all information sharing is covered by “Shine the Light” requirements and only information on covered sharing will be provided.

Per California Civil Code Section 1789.3, California residents can contact the Complaint Assistance Unit of the Division of Consumer Services, California Department of Consumer Affairs:

• Mail: 1625 North Market Blvd., Sacramento, CA 95834
• Phone: (800) 952-5210

To exercise your rights, email us at irl@villagers.co. We will respond within 45 days, verify your identity before processing requests, and provide certain information (to the extent available) for the previous 12-month period.

Children's Privacy (COPPA)

The Children's Online Privacy Protection Act (COPPA) and COPPA Rule, enforced by the Federal Trade Commission, protect children's online privacy. Our Platform:

• Is not intended for individuals under 18
• Does not knowingly collect information from children under 13
• Deletes any discovered information from children under 13 immediately
• Does not permit users under 18 to create accounts or submit Personal Information

International Visitors and End Customers

Under the General Data Protection Regulation (GDPR), European Economic Area (“EEA”) Visitors and End Customers are “Data Subjects” with specific rights. We process personal data under these legal bases: consent, contractual necessity, legitimate business interests, and legal obligations.

If you are located in the EEA and have questions or concerns about our data processing practices and procedures, please contact us at irl@villagers.co.

Changes to This Policy

We update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. Changes to this Privacy Policy will be effective upon publication to the Site.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

• Email: irl@villagers.co
• Address: Villagers IRL, 353 West Main St., Durham, NC 27701