Privacy Policy

PoodleAI Corp, a Delaware corporation, does business as Replify (the “Company,” “we,” or “us”), recognizes the importance of data privacy and information security. This Privacy Policy sets forth how we collect, use, disclose, and retain personal information. This Privacy Policy describes the types of personal information we collect, the purposes for which we use it, the types of third parties with whom we share it, and the rights you may have with respect to that personal information. This Privacy Policy applies to personal information you provide when you visit any website or mobile application we own, license, maintain, or otherwise operate that links to this Privacy Policy (each, a “Site”), or when you otherwise contact or engage with us. For purposes of this Privacy Policy, the Site(s) and all services furnished by the Company through a Site are referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SITE OR SERVICES, OR BY PROVIDING US WITH PERSONAL INFORMATION, YOU CONSENT TO THIS PRIVACY POLICY AND ANY APPLICABLE TERMS OF SERVICE ON THE SITE YOU ACCESS.

Scope

This Privacy Policy applies to personal information that the Company receives during its business operations as a “data controller,” which means we determine the purpose and means of use of that personal information.

Platform role for customer end users. When a business uses the Services to contact its own leads, members, or customers, that business controls the decision to collect phone numbers, the legal basis to contact a person, the message content, and the recipient list. In that context, the business is the data controller for its end user data, and the Company acts as a service provider that handles data on the business’s behalf under its instructions. This Privacy Policy describes how the Company uses data within its own business operations and as a service provider. End users should review the privacy policy of the business that contacted them for details about that business’s data practices.

For purposes of this Privacy Policy, “personal information” means any information that, alone or with other information, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. “Personal information” does not include anonymized or de identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de identify personal information. Such data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

The Types and Categories of Personal Information We Collect

The Company collects personal information to provide our Services, comply with legal obligations, and support legitimate business interests, plus for the other reasons set forth in this Privacy Policy. When you do not provide personal information, we may not be able to provide the Services or complete a transaction you request.

Categories of personal data we collect

Personal Identifiers

Identifiers such as name, address, email address, and phone number.

Registration Data

Data you provide when you register for an account to use the Site or Services, such as user name and password.

Online Identifiers

Persistent identifiers that can recognize you or your device over time and across services, such as device identifier, Internet Protocol address, cookie IDs, pixel tags, mobile ad IDs, and similar tech.

Commercial Information and User Content

Records of the Services you order, obtain, or consider, plus other purchase or use history tied to our Services. Content you submit to the Services, such as input, prompts, file uploads, or feedback.

Promotional and Communications Data

Data about your preferences for Company updates and alerts, plus your subscription status for those updates. You may opt out from promotional email at any time via the “unsubscribe” link in an email or by contact with us as set out below.

Internet and Electronic Network Activity Data

Data about how you access or use the Site, such as browse history on the Site, queries, search history on the Site, and data about your interaction with the Site.

Feedback Data

Data you provide about our Services, such as survey responses or reviews.

General Location Data

Data about the general city, state, or region where a Site user is located.

Inferences

Inferences drawn from the categories above that help create a profile about preferences, traits, and behavior.

Communications Data for SMS, MMS, and Voice

Data tied to SMS, MMS, web chat, email, or voice calls that occur through the Services, plus related consent data where a business customer stores or provides it to us. Examples include phone number, call or text metadata, message content, reply status, opt out status, time stamps, and conversation logs.

Technical Data We Collect Automatically

When you access the Site, we collect certain data automatically by technical means. This data relates to your device, plus your experience on the Site and other websites, and may include the following.

Usage and Device Data

When you access and use the Site, we collect details of your access to and use of the Site, such as traffic data, usage logs, other communication data, and the resources you access and use on or through the Site, such as browse history and search history. We may also collect information about your device and internet connection, such as device type, IMEI, Wi Fi MAC, IP address, operating system, browser type, and mobile network information. The Site may collect diagnostic data related to your use of the Site, such as crash logs and performance data.

Cookies and Similar Tech

We use cookies and similar tools within the Site. A cookie is a small file placed on your device. It may be possible to refuse cookies by use of the applicable device or browser settings. If you refuse cookies, some parts of the Site may not function properly. The Site may also use web beacons, clear gifs, pixel tags, and single pixel gifs that allow us to analyze Site use, such as the popularity of certain content and system integrity checks. Analytics tools help us understand how users use our Services and improve user experience.

Site Monitoring

We use cookies and similar tools within the Site to monitor and record activities and communications to, from, and on the Site to protect the Site, improve the Site, and analyze Site use, plus for the other purposes listed in this Privacy Policy. You acknowledge, agree, and consent to such monitoring and recording.

Non Cookie Tech

We may use certain non cookie tools provided by our service providers to support our digital ads programs. These tools may include browser cache, locally stored objects, or a statistical identifier based on browser or device traits.

Sources of Information

First Party or Direct Collection

We collect personal information directly from you when you use our Services, such as when you register an account, make a purchase, sign up for a subscription, or contact us.

Automated Collection

As described above, we collect certain information by automated means when you use the Site.

Third Party Sources

We may receive personal data from service providers that help us provide the Services, plus from business customers that use the Services and provide their end user contact data to the Services. We may also receive data from public sources if you choose to link a social profile or if you contact us through a social platform.

How We Use Your Information and Purpose of Collection

We use personal data to provide the Services, meet legal duties, and support business operations, as permitted by this Privacy Policy.

How Your Personal Data Is Used

Provide the Services

We use personal data to provide, operate, and maintain the Site and Services.

Account access and administration

We use Registration Data to create and manage accounts, allow sign in, and support account settings.

Transactions and billing

We use personal data to complete transactions, send order confirmations, send invoices, and support payment related questions.

Customer support

We use personal data to respond to questions and requests, provide customer support, and handle support tickets.

Service notices and security

We use personal data to send technical notices, product updates, security alerts, and administrative messages related to the Services.

Communications features for SMS, MMS, and voice

If you provide a phone number, or if a business customer of the Services provides your phone number to the Services, we may use that phone number to provide communications through the Services, which may include SMS, MMS, and voice calls. Examples include replies to questions, follow up to requests, appointment or tour coordination, account notices, and billing notices. Message frequency varies by business and by your interactions. Carrier message and data rates may apply.

Promotional communications

We may use personal data to send promotional communications about our Services, such as newsletters, surveys, product announcements, offers, events, and invitations. Promotional email may be stopped at any time via the unsubscribe link in an email or by contacting us as described below. We do not use phone numbers for promotional SMS unless the recipient has provided the required consent for SMS.

No sale or promotional sharing of phone numbers

We do not sell phone numbers. We do not share mobile opt in consent data or phone numbers with third parties or affiliates for their own promotional purposes. We may disclose phone numbers to service providers as needed to provide the Services, or as required by law, carrier rules, or provider rules.

Service analytics and performance

We use personal data to analyze Site and Services use, measure performance, and improve reliability and user experience.

Fraud prevention and abuse detection

We use personal data to detect, investigate, and help prevent fraud, unauthorized access, spam, and misuse of the Services.

Legal and compliance

We use personal data to meet legal duties, protect rights and property, protect the rights and property of customers and partners, take part in legal or regulatory processes, and respond to lawful requests from authorities.

Due diligence and security obligations

We may use personal data to meet due diligence duties related to security, anti bribery, anti money laundering, sanctions, export controls, and similar compliance duties where they apply.

Model use of Content

We may use Content submitted to the Services to provide requested features, improve product quality, and test new features. We apply access controls and other safeguards intended to reduce risk. Business customers may have contract terms that limit or define this use, and those contract terms control where they apply.

Service providers for communications

We use service providers to deliver communications features such as SMS, MMS, and voice calls. These providers may include telecom and communications vendors such as Twilio. These vendors handle personal data under our direction so we can provide the Services.

Sharing Information and Third Party Disclosures

We disclose personal data as described below and as permitted by applicable law.

Service Providers. We disclose personal data to vendors that help us provide the Services, such as cloud host, payment vendor, customer support tools, analytics, fraud and abuse prevention, legal compliance services, and telecom vendors that deliver SMS, MMS, and voice calls. These vendors act as service providers that handle personal data under our direction and for the purpose of providng the Services.

Business Restructuring. Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge, or otherwise reorganize our business. We may disclose personal data to the extent reasonably necessary to proceed with a negotiation or to complete a merger, acquisition, divestiture, or sale of all or a portion of our assets.

Legal, compliance, and legitimate interests. We may disclose personal data if required by law or government order, or in response to legal process, to protect and defend rights or property, or in urgent circumstances to protect health and personal safety. We may also disclose personal data when we believe such disclosure is necessary to defend or protect legal, regulatory, or business interests.

Direction by you. If you request information from us, facilitate a transaction with us, or otherwise engage with us, and those actions require disclosure to a service provider or other third party, you consent to such disclosure and direct us to disclose your personal data to that party as needed to fulfill your request.

SMS and MMS Privacy

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.

Social Media

We may engage with you on social media platforms such as Facebook, X, LinkedIn, or Instagram. If you contact us on a social media platform for customer support or other reasons, we may contact you via that platform’s direct message tools. Those communications are governed by this Privacy Policy. Your use of a social media platform is subject to that platform’s terms and policies. Some platforms may provide us with personal data about you based on your settings and the platform’s rules.

The Site may include social media features and widgets such as a “Like” or “Share” button. These features may collect your IP address and which Site page you access and may set a cookie to enable the feature to function properly. Social media features and widgets may be hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the platform that provides them.

Links to Other Websites and Your Direct Third Party Disclosures

The Site may include links to third party websites or allow you to disclose information directly to third parties. This Privacy Policy does not apply to those third parties. You assume privacy and security risk when you provide data to third parties via the Services. For details about those third parties, refer to their privacy statements. We do not permit use of the Services with purchased, rented, scraped, or appended phone lists.

Data Retention and Localization

We retain personal data for as long as needed to provide the Services, meet legal duties, and support dispute resolution and security. Retention depends on data type and purpose. For example, we retain personal data needed to provide the Services, facilitate transactions you request, comply with legal duties such as tax and export control obligations, and defend legal or business interests. In other cases, we retain personal data for as long as needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in the United States, and the personal data we collect is retained and stored in the United States. The Company may use service providers that store personal data on our behalf in the United States and in other countries. Those locations may not provide the same level of personal data protection as your jurisdiction. When transferred to the United States or elsewhere, your personal data may be accessible to government authorities under local law. By providng personal data to us, you acknowledge and agree that your personal data will be transferred to and stored in the United States and other countries where our service providers operate.

Security

We seek to protect the security of personal data and use a variety of security tools and procedures intended to help protect personal data from unauthorized access, use, or disclosure. However, no system can be fully secure, and we cannot guarantee absolute security. We are not responsible for the security of personal data you transmit to the Site or Services over networks we do not control, such as the internet or wireless networks, and you provide personal data at your own risk. To the extent permitted by law, we are not liable for a data incident caused by a third party.

Security also depends on you. Where we have issued you, or where you have chosen, a user name and password, you are responsible for keepng those credentials confidential. You must contact us promptly, and in any event within twenty four (24) hours, if you believe your credentials have been compromised. You acknowledge and agree that we may contact you via email or other electronic communications if we are legally required to notify you of a data security incident.

No Data Collected from Children

The Site is not directed to, and is not intended for use by, children. If you are under eighteen (18), you are prohibited from access to or use of the Services, or from providng personal data to us.

Feedback

You may provide feedback about our business, our business sector, or the Services (“Feedback”). Any information you post as Feedback may be visible to other users and may be retrievable by search engines. Third parties may be able to download or share Feedback. We recommend you do not upload confidential information in Feedback. Public post of information on the Site is voluntary, and you should carefully consider what you choose to make public.

As between you and the Company, Feedback is considered our confidential and proprietary information. To allow us to use Feedback, you grant us a non exclusive, perpetual, irrevocable, worldwide, royalty free license, with the right to sublicense, to use, publish, and disclose Feedback in any manner and via any media, without reference to source.

Your Rights and Responsibilities

You agree to provide personal data to the Company only if that data is accurate, reliable, and relevant to our relationship, and only to the extent such disclosure does not violate applicable data protection law or infringe another person’s privacy rights.

IF YOU PROVIDE PERSONAL DATA, INCLUDING DATA ABOUT A THIRD PARTY, YOU REPRESENT AND WARRANT THAT YOU HAVE FULL RIGHT AND AUTHORITY TO PROVIDE THAT DATA, AND THAT OUR USE OF THAT DATA AS SET FORTH IN THIS PRIVACY POLICY WILL NOT VIOLATE ANY PERSON’S RIGHTS. YOU AGREE TO INDEMNIFY THE COMPANY FOR CLAIMS OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL DATA TO THE COMPANY.

To the extent provided by local law and subject to exceptions, individuals may have the following privacy rights.

The right to know about our use of personal data, including the specific pieces of personal data we have collected.

The right to request deletion of personal data.

The right to correct personal data.

The right to be free from discrimination for exercisng privacy rights.

We do not “sell” or “share” personal data for cross context behavioral ads, as those terms are defined under applicable local law. We also do not use sensitive personal data for the purpose of inferencng characteristics about a consumer.

Exercisng Your Rights

To the extent applicable under local law, you may exercise privacy rights described in this section by sendng a request to contact@replify.ai.

Verification

To protect personal data from unauthorized access, change, or deletion, we may require credential verification before we act on a request. If you do not have an account with us, or if we suspect fraud or misuse, we may request additional information and proof of residency for verification. If we cannot verify identity, we may be unable to act on your request.

Authorized Agents

You may submit a rights request through an authorized agent. The agent must present signed written permission to act on your behalf, and you may be required to verify identity and submit proof of residency. Agent requests may be sent to contact@replify.ai.

Appeals

Depending on where you live, you may have the right to appeal a decision we make about a rights request. To appeal, email contact@replify.ai.

Updatng Your Information

It is important that personal data you provide is accurate and reliable. In some cases, you may be able to edit your account to update personal data, such as name, phone number, address, or email. You may also request updates by contact with us as described below.

Email Marketing and Your Rights

You may opt out of promotional email. Promotonal email often includes an unsubscribe option. You may also opt out by contact with us as described below. You agree to notify the Company promptly if you no longer own, license, or use an email address you used to subscribe.

SMS Opt Out and Help

For SMS or MMS from a specific business that uses the Services, reply STOP to opt out. For help, reply HELP, or email contact@replify.ai. Opt out applies to that specific business. The business may send replies you request, plus notices required to provide its services or meet legal duties.

Do Not Track Signals

Some web browsers transmit do not track signals. Due to differences in how browsers implement this feature, it is not always clear whether users intend for these signals to be transmitted. Unless required by law, we do not take action in response to these signals.

Persons with Disabilities

We aim to ensure access to information about our Services, includng this Privacy Policy. Contact us if you would like this Privacy Policy in an alternative format.

Employment Applications and Talent Management

As part of recruitment and talent management, we collect personal data from individuals who seek work with us. This may include contact data, resume data, job preference data, plus other data permitted by law such as background check or reference data. We use this data to evaluate candidates, verify information, conduct checks permitted by law, communicate about the recruitment process, comply with legal duties, improve recruitment, accommodate candidate needs, and protect the rights and property of our business and others. We may disclose this data to service providers that assist with recruitment and checks, as described in the Sharing section.

Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will note changes by updatng the “Last Updated” section in the Privacy Policy where it appears on the Site. Your continued use of the Services after changes take effect signifies consent to the updated Privacy Policy. We may send notice of changes by email or text, but those notices do not replace your duty to review this Privacy Policy periodically.

Contact Us

If you have questions about this Privacy Policy or our use of personal data, would like more information, or would like to exercise a privacy right, contact us at contact@replify.ai. Questions about SMS, MMS, or voice privacy may be sent to contact@replify.ai.