This Privacy Policy describes Chati LLC (“Chati”) practices for collecting, using, maintaining, protecting, and disclosing (“processing”) your personal information when you use our services (“Services”), such as when you:
This Privacy Policy also applies to personal information we collect from third parties about you. This Privacy Policy does not apply to websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.
Our privacy practices are subject to the applicable laws of the places in which we do business, so we have added region-specific terms that only apply to customers located in certain geographic regions, or as required by applicable laws.
“Personal information” (sometimes called “personal data”) is a broadly defined term whose legal definition varies across jurisdictions. When used in this Privacy Policy, “personal information” includes information that is reasonably capable of identifying a particular individual (including through their device) either alone or when combined with information from other sources.
The personal information we collect about you depends on the nature and context of your interaction with our Company and Services. It may also depend on various choices you make about how to use the Services we offer, the functionality and features you choose or enable, your location, the devices you us to interact with our services, and applicable law. The following describes the personal information we collect about you and the way we collect it.
We collect the following categories personal information you provide to us, including the following:
Sensitive Personal Information Some jurisdictions have defined certain categories of personal information as “special” or “sensitive.” We collect the following categories of sensitive personal information when you provide it to us or allow us to collect it based on your interaction with us.
We and our third-party partners use cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively, “tracking technologies”) to gather information when you interact with our websites, mobile apps, and email communications. We use some of these tracking technologies help us optimize and maintain the security of our websites and your account. We also use them for compatible purposes like save your preferences, fixing errors, and ensuring consistent service of our websites and mobile apps.
We permit third parties to use tracking technologies on our websites for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, and provide metrics on advertising effectiveness. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites.
The information we collect using these technologies includes:
We may collect information about you from third parties (such as companies we partner with or that provide services to us) and public sources. For example:
We mostly collect personal information directly from you or based on your interaction with our Website. However, we also may collect personal information from third-party sources. These include Sponsors, our Business Services Providers, Marketing and Advertising Providers, government entities, our company affiliates, security services providers, other individuals, social media platforms, and other users of our Services.
Even if you aren’t a registered user of our Services, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. User may also post or comment with personal information about other users.
We may use your personal information for a variety of reasons. Depending on how you interact with our Services, these include using personal information:
When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations.
We may share your personal information with the following:
If we have obtained your personal information from a Sponsor or other content provider, or if you have attended content provided by them, we may share personal information related to your interaction with their content with them, typically for purposes of reporting attendance, sending follow up emails, or otherwise interacting with them. In some cases, Chati LLC is the joint-controller of the personal information we collect on behalf of Sponsors and/other content providers.
These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers.
Our affiliates include our parent company, subsidiaries, joint venturers, or other companies that we control or that are under common control with us.
Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
To any party when authorized by the individual to whom it pertains to share it.
We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information.
Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at Privacy@Chati.com.
You can control the collection and use of personal information for some of our processing activities. This includes:
Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:
Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.
Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:
Chati LLC will honor the privacy rights afforded to individuals in accordance with applicable law.
You may make a request at any time to exercise your privacy rights listed above by emailing us at Privacy@Chati.com. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.
We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere our requirements and applicable privacy laws.
We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
If you have questions or comments about this Privacy Policy or complaints and our privacy practices, please contact us at:
You may make a request at any time to exercise your privacy rights under Virginia law by contacting us using the contact methods described above. We will respond to your request withing 45 days of receipt (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within 90 days from the date of our receipt of your properly submitted request. If we decline to act regarding your request, we will inform you of our decision and the reason for it, along with instructions on how you may appeal our decision.
We do not sell your personal information to third parties (as “sell” is defined under Virginia law). If you decide you want to opt out of sharing your personal information for targeted advertising purposes, you can opt out. Please note, opting out of targeted advertising does not mean that you will no longer receive ads from us—it just means that such ads will not be specifically tailored to you.
This section applies to residents of the State of California in addition to all other applicable rights and information contained in this Policy.
California law requires that we describe the personal information we collect, disclose, and sale/share based on certain defined categories. To be clear, this chart overlaps with the description of our processing practices described above. This chart below describes our practices covering the past 12 months.
| Categories of Personal Information | Categories of Sources from which the Information was Collected | Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | Types of Third Parties with Whom this Category of Personal Information Is Shared/Sold |
|---|---|---|---|
| Identifiers (e.g., name, signature, address, telephone email, IP address) |
|
| Marketing and Advertising Providers |
| Customer Records (as defined in Cal. Civ. Code § 1798.80(e)) |
|
| We do not sell or share |
| Protected Classifications (e.g., Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status) |
|
| We do not sell or share |
| Commercial Information (e.g., your purchasing or consuming histories or tendencies) |
|
| Marketing and Advertising Providers |
| Internet/Network Activity (your your browsing history, search history) |
|
| Marketing and Advertising Providers |
| Geolocation Data | We may gather your geolocation based on your address, IP address, or other data associated with a particular location. If you are using company-equipment that collects geolocation, we may associate that geolocation with you. |
| Marketing and Advertising Providers |
| Sensory Data (e.g., Audio, electronic, visual, thermal, olfactory, or similar information) | We may collect your image, voice, electronic activity, or other sensory data through recording devices such as a security camera, call recording device, or thermal image scanner. |
| We do not sell or share |
| Professional or employment-related information (e.g., Current or past job history or performance evaluations). | We do not collect from consumers generally. Candidates for employment may be provided supplemental notices regarding collection of this information. | N/A | N/A |
| Education Information | We do not collect from consumers generally. Candidates for employment may be provided supplemental notices regarding collection of this information. | N/A | N/A |
| Inferences drawn from other personal information | We may make inferences about your preferences, likes, and interests based on personal information you provide to us. |
| Marketing and Advertising Providers |
| Sensitive Personal Information |
|
| We do not sell or share |
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
To make an access, deletion, correction, or limitation request, please use our email us at Privacy@Chati.com.
After we receive your request, to ensure the security of the information we store and consumers’ privacy, we will verify that you are appropriately affiliated with the subject of the request, either as the consumer or as an authorized agent or guardian of the consumer. We may ask you to provide a few pieces of information to confirm your identity in our records.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf. You must provide the authorized agent written permission to exercise your rights under the CPRA on your behalf and we may deny a request from an agent on your behalf if we cannot verify that they have been authorized by you to act on your behalf. Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided a power of attorney under the California Probate Code.
Our use of tracking technologies may be considered a “sale” and/or “sharing” under California law. You can opt-out of being tracked by third parties by clicking “Your Privacy Choices” link at the bottom of our website and selecting your preferences or by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any offline information because we do not make a connection between your browser and offline information. If you would like us to process an opt-out request for offline information we “sell” or “share” we recommend you submitting the Do Not Sell or Share Personal Information form that is in Your Privacy Choices.
We offer our or provide loyalty programs, promotional programs, sweepstakes, contests, or similar incentive programs that provides certain perks, such as rewards and exclusive offers (collectively, “Promotions”). When you sign up for one of these Promotions, we typically ask you to provide your personal information. Because our Promotions involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Promotion, less the expense related to offering those products, services, and benefits to Promotion participants. You may withdraw from participating in a Promotion at any time by contacting us using the designated method set forth in the applicable terms and/or rules.
California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to Privacy@Chati.com with the subject “Shine the Light Request.”
Legitimate Interests. We may process your information where it is necessary for the purposes of Chati LLC’s or a third party’s legitimate interests, such as those of registered users, our Sponsors, or partners. We process your information in furtherance of the following legitimate interests:
You are not required to pay any charge for exercising your rights. We have one month to respond to you.
If you have an EU resident and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Chati LLC’s lead supervisory authority.
Similarly, if you have a UK resident, you have the right to lodge a complaint with the UK Information Commissioner’s Office.
If you live in Australia, Canada, or Europe, we may transfer your personal data to other jurisdictions where we have facilities or service providers, including the United States, where data protection laws may not provide the same protections as the laws of your home country.
For residents of Europe, the United States is not subject to an adequacy decision, i.e., the European Commission has not determined, under Article 45 of Regulation (EU) 2016/679 (GDPR), that the United States ensures an adequate level of protection for personal data under its laws. (An explanation of adequacy decisions and list of recognized jurisdictions can be found here.) When we transfer personal data of data subjects in Europe to a third country that is not subject to an adequacy decision, we will do so in accordance with all applicable data protection laws.
If you have questions about these international transfers of personal data, or to request a copy of the relevant standard contractual clauses, please email us at Privacy@Chati.com, or contact us as provided in the “How Can You Contact Us?” section, above.
Canadian laws provide specific rights to Canadians. If you are a Canadian resident, this section applies in addition to all other applicable rights and information contained in the Privacy Policy.
We are committed to openness and accountability with respect to how we handle your personal information pursuant to Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:
Consent. In most cases, we rely on implied consent to collect, use, or disclose your personal information. In some circumstances, including those involving sensitive personal information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your personal information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by contacting us at Privacy@Chati.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Use of Your Personal Information. We will not collect, use, or disclose personal information except for the identified purposes identified above (See Disclosures of Your Personal Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the personal information we provide to them, we ensure that an agreement is place the ensure compliance with applicable Canadian Privacy Law.
Canadian Access and Challenge Rights Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your personal information and be provided access to that information. You may also challenge the accuracy and completeness of your personal information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.
Exercising Your Canadian Privacy Rights. If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your personal information, you may submit a request by emailing Privacy@Chati.com. When submitting a request, we may require that you take additional steps to validate your identity or legal authority. We will begin processing your request once you have completed the verification process.
We have put procedures in place to receive and respond to inquiries about our policies and practices relating to the handling of personal information. We will provide a response to any personal information request within the timeframe required by law. If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.
Additional information about how to exercise your rights under Canadian Privacy Law can be found here:
We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You consent to us processing your personal information in accordance with this Privacy Policy.
You may access or request correction of the personal information that we maintain about you by emailing us at Privacy@Chati.com. There are some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
If you have complaints about our privacy practices, please contact us using the contact methods provided. We will evaluate any complaints and determine if further action is necessary and keep you informed of our investigation and decisions. If you remain dissatisfied with our handling of a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
