Privacy Policy

Last updated: August 31, 2026

Smoke Studio, Inc. (“we,” “us,” “ours” or “Smoke”) respects your privacy. This privacy policy (“Privacy Policy”) explains how we collect, process, store and share personal information in connection with our services, our websites and applications, including smoke.ai (collectively, the “Platform”) and our business operations. “You” or “your” includes our customers, users of the Platform (“Users”), and other persons about whom we collect or process personal information. If you are an individual, this Privacy Policy also provides you with important information about your personal information rights with respect to personal information that we control and how to exercise them. The Platform includes artificial intelligence and machine learning technologies (collectively, “AI Technologies”).

This Privacy Policy does not apply to personal information that we collect from employees of or job applicants to Smoke in connection with their employment or potential employment with us.

By accessing or using our Platform, or by providing personal information to us, you acknowledge that you accept our privacy practices and policies outlined below, and you consent that we may collect, process, store and share personal information as described in this Privacy Policy.

1. Notice at Collection of Personal Information

Definition of Personal Information

We collect, process, store and share information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from personal information).

Categories of Personal Information We Collect

The categories of personal information we collect from or about you depends on your relationship with us. For example, we collect certain categories of personal information directly from Users in order to provide the Platform.

We collect the following categories of personal information from all of the various sources of information:

  • Contact information, such as full name, email address and phone number

  • Demographic and biographic information, such as your profession, employer and job title

  • Internet and device identifiers, activity and analytics, such as information we automatically collect through cookies and similar technologies used on our Platform, including user activity on our Platform, browser, operating system, and device information, and IP addresses

  • Precise geolocation when you are using our Platform

  • Preference information, including preferences related to marketing, privacy, and communications

  • Inferences drawn from any of the personal information we collect; for example, to create a profile of an individual’s preferences and characteristics

  • Customer Relationship Management Systems (“CRM”): Our Users may provide us with personal information from their CRM systems and email inboxes.

  • Other information you choose to provide to us

Sensitive Categories of Personal Information Collected

  • Account access information, such as account log-in credentials

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide access to the Platform, verify your identity, or process transactions, we may be unable to offer access to the Platform, or otherwise conduct business with you.

Our Business Purposes for Collecting and Sharing Personal Information

We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests and the legitimate interests of third parties to:

  • Provide the Platform, including to provide the Platform, maintain the Platform, enable Users to access and use the Platform (including AI Technologies), to customize content, to provide recommendations, to enhance the quality and your overall experience with the Platform, including by retaining your user preferences or presenting content in the most effective manner for the browser or device you use to access the Platform, to manage our relationship with our Users, to process transactions and to otherwise assist and respond to our Users

  • Support our business operations, including to administer and protect our Platform, and systems, verify the identity of Users, and use hosting, technology and communication providers and other vendors that support our business operations

  • Market the Platform, for example, we process and share limited categories of personal information (contact information, internet and device information (including approximate geolocation), preference information and inferences) to send you marketing communications

  • Improve the Platform, for example, we process and share limited categories of personal information (contact information, internet and device information (including approximate geolocation), preference information and inferences) for our internal research and development purposes and to troubleshoot, test and conduct data analysis, to update and otherwise improve the Platform’s functionality, to make informed business decisions and to improve user experience; this includes using the above-listed limited categories of personal information to improve the features and functions of the Platform

  • Market and advertise our and third-party products and services to you, including through targeted advertising. We collect, use and share personal information (except for identification information, account credentials and payment information) to market and advertise to you, including:

    • delivering “targeted advertising” (also known as cross-context behavioral advertising), which means advertising based on your interests based on your activities over time on the Platform and online services operated by third parties, as well as information from other sources, including information collected offline; for more information, see the below section called, Our Participation in Targeted Advertising

    • recommending features, content, products, and services that might be of interest to you

  • Deidentify personal information, including aggregating and anonymizing personal information so that it is no longer personal information

  • Meet legal and compliance requirements, including to perform audits, monitoring and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of our Users, you, us, or a third party; respond to legal process (including subpoenas) and governmental, court or law enforcement requests, investigations or orders; and comply with and enforce applicable laws, regulations, policies, procedures and agreements

  • Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, bankruptcy or other transaction in which a third party invests in or acquires control of our business or assets (in whole or in part)

Although we engage in profiling for marketing and targeted advertising purposes, we do not share your personal information for the purposes of making automated decisions that produce legal or similarly significant effects concerning you.

We only use sensitive personal information (account credentials) as necessary to provide the Platform.

Under the laws of some jurisdictions, we must be able to describe the legal bases on which we rely to process personal information. We primarily rely on the legitimate interests, described above, to process personal information when not overridden by an individual’s data protection interests or fundamental rights and freedoms. Other legal bases for our processing of personal information include when the processing is necessary to perform a contract with you, we have a legal obligation to process the personal information or we have your consent to process the personal information.

Categories of Parties Whom We Share Your Personal Information

We share personal information with the categories of parties listed in this section.

Third Parties

  • Our affiliates (“Affiliates”) for purposes consistent with this Privacy Policy, including to support marketing, sale and delivery of our Platform

  • Our vendors (“Vendors”) who provide us with services and products that help us provide the Platform or operate our business but only to the extent needed to enable them to provide such services or products.

  • Social Media Platforms and Advertising- and Marketing-Related Service Providers and Partners (“Advertising Providers”), including:

    • social media platforms, including if you interact with social media widgets, share content using social media share buttons, or access features of the Platform that contain content or features provided by social media platforms, the relevant social media platforms may collect information

  • Parties you access, authorize or authenticate (“Authorized Parties”), including third parties you access through the Platform, such as payment processors; information provided to such third parties are subject to such third parties’ privacy policies; please consult the applicable third party’s privacy policy for more information on how the third party uses your personal information

  • Parties for legal purposes (“Legal Parties”), including governmental authorities, law enforcement, courts or other third parties in connection with any of the activities set forth in the bullet beginning with “Meet legal and compliance requirements” in the section above called, Our Business Purposes for Collecting and Sharing Personal Information

  • Parties for business changes (“Transaction Parties”), for example, personal information that we collect may be shared with or transferred to a third party if we consider or undergo a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part), or any similar corporate event to any of the foregoing

Notice of Right to Opt-Out of Sale/Sharing

We use your personal information to deliver the Platform to you and customize your experience. We may share the personal information that we collect for cross-context behavioral advertising or targeted advertising (except for identification information, account credentials and payment information). Depending on laws that may be applicable to you, when we share your personal information, it may constitute a “sale” of your personal information (for example, when we share your personal information in exchange for money or other valuable consideration).

You may choose to opt-out of our sale of your personal information and sharing of your personal information for cross-contextual behavioral advertising and targeted advertising by emailing:

legal@smoke.ai

Retention of Personal information

We retain personal information for as long as we deem to be necessary or advisable for our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal information (such as providing the Platform). This may include keeping your personal information after you have stopped using our Platform; for example, we may retain your personal information to market the Platform to you (unless you opt-out), comply with legal obligations, or resolve disputes. We may retain your personal information longer pursuant to a specific legal reason or requirement. When our retention period ends, we may either delete your personal information or retain it in a form such that it does not identify you personally.

2. Applicability of this Privacy Policy

This Privacy Policy covers how we treat personal information that we collect from you, or in connection with our Platform provided to you, or in connection with our other business or interactions with you. This Privacy Policy does not apply to personal information that we collect in connection with your employment or application for employment with us. This Privacy Policy does not cover, and we are not responsible for, the policies or practices of Users or third parties that you may access or be connected with through the Platform or otherwise through us.

Sources of Personal Information

We collect personal information from the following categories of sources:

  • Directly from you, such as when you register on our websites, sign up to receive information or contact us via our websites, or when you otherwise communicate or interact with us in any way, including via mail, email, phone, chat, browser form, online request form, QR code or social media

  • Indirectly from you, for example, we collect cookie data and other information from your device, browser or activity in our Platform

  • From third parties or public sources, for example, from Advertising Providers, including analytics providers and social media platforms

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide certain services, verify your identity or process transactions, we may be unable to offer certain services or otherwise conduct business with you.

Third-Party Links

Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not endorse or control these third-party websites or applications and are not responsible for their privacy practices or any information on their websites or in their applications. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal Information of Others You Share with Us

You may not disclose the personal information of someone other than yourself to us unless you have the other individual’s prior written consent or are otherwise authorized under applicable law to share their information with us. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including:

  • providing all applicable notices

  • receiving the proper authority or consent to allow us to collect, store, process and share such personal information

  • responding to data subject requests

Aggregated Data

We may anonymize, deidentify and/or aggregate data so that it no longer constitutes personal information. Anonymized or deidentified data is not personal information and restrictions on our use of personal information contained in this Privacy Policy do not apply to such anonymized or deidentified data even if such data was created or derived from personal information. We may share anonymized, deidentified and/or aggregated data that does not identify you personally with third parties, including our Affiliates, Vendors and Advertising Providers. We may also disclose aggregated user statistics in order to describe our Platform to current and prospective business partners and to other third parties for other lawful purposes. We may disclose non-personal information to any third party for any reason in our sole discretion.

Personal information of Children

We do not collect any personal information directly from children under 18 years of age. If you are a child under the age of 18, please do not attempt to use our Platform or send us any personal information. If we learn we have collected personal information directly from a child under 18 years of age, we will delete that data as quickly as possible.

To our knowledge, we do not sell or share for cross-contextual behavioral advertising or targeted advertising purposes, the personal information of children under the age of 18.

3. Your Privacy Rights and Choices

Notice of Your Personal Information Rights

With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to:

  1. Know or access – request that we disclose certain information to you about our collection and use of your personal information:

  • Whether or not we are processing your personal information

  • The categories of your personal information we have collected

  • The categories of sources for your personal information we have collected

  • Our business purposes for collecting or sharing that personal information

  • The categories of third parties with whom we shared your personal information, identifying the personal information categories that each category of recipient obtained and the purposes for sharing your personal information

  • The specific pieces of personal information we collected about you and access to that personal information

  1. Data portability – request a copy of the personal information you provided to us in a portable, and, if feasible, readily usable format to be transferred to you or a third party

  2. Deletion – request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law

  3. Correction – request that we correct inaccurate or incomplete personal information

  4. Limit use of sensitive information – request that we limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law

  • We do not use or disclose sensitive personal information (for example, account access information, racial or ethnic origin, religious or philosophical beliefs, union membership, content of mail, email, and text messages not directed at us, genetic data, or health, sex life, or sexual orientation information) for purposes other than purposes that would continue to be allowable after the receipt of a limitation request, including to provide the Platform

  1. Sale opt out – direct us to not sell your personal information at any time

  2. Sharing for behavioral advertising opt out – direct us to not share your personal information for cross-context behavioral advertising or targeted advertising

  3. Third-party marketing opt out – direct us to not share your personal information with third parties for third parties’ direct marketing purposes

  4. Object to processing – object to our processing of your personal information based on legitimate interests or for direct marketing purposes

  5. Restriction of processing – request that we restrict or suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

  6. Withdraw your consent to the processing of your personal information if our processing is based on your consent (without affecting the lawfulness of any processing prior to your withdrawal of consent)

  7. Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law

How to Exercise Your Personal Information Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via the method described below) that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may ask for information to verify your identity, such as name, phone number, email, and address. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request promptly within the timeframes required by applicable privacy law (usually between 15 to 45 days depending on the type of Valid Request, with the right for us to extend the response time as necessary). We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following method:

You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

In some instances, we may not be able to honor your request. For example, we may not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. We may not honor your request if we are not the controller of your personal information. We may not honor your request if it is technically infeasible for us to do so. For example, if you ask us to correct personal information that we store in an unalterable format, we may be unable to honor your request or we may offer to delete the personal information instead of correcting it. Additionally, we may not honor your request where not required to do so under applicable privacy laws. For example, we may deny a deletion request if the information is necessary for us to provide our Platform or comply with our legal obligations. We may deny certain right to know requests made more than twice in a 12-month period or for information collected and disclosed more than 12 months ago. We will advise you in our response if we are not able to honor your request.

You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.” Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

The Right to Lodge a Complaint with a Supervisory Authority

Subject to applicable privacy law, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with your local data protection authority and/or competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the European Economic Area, you may find the contact details for your appropriate data protection authority on this website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office here: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/.

If you are a resident of Texas, you may lodge a complaint online at this website https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/.

4. Our Use of Cookies

Our Use of Cookies and Other Tracking Technology

Our Platform uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “cookies”). Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Platform. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices.

Do Not Track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our Platform is not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.

Global Privacy Control. We recognize and respond to the Global Privacy Control (“GPC”) signal. If you enable the GPC signal in your browser or browser extension, we will treat it as a valid request to opt out of the sale and sharing of your personal information for cross-context behavioral advertising and targeted advertising purposes, as required under applicable law. For more information about GPC, visit https://globalprivacycontrol.org.

Disable or Delete Cookies and Tracking Technology; Third-Party Cookies

Disable or Delete Cookies from Your Browser or Device

You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” “options” or “help” section of your browser's menu.

You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Platform and some of the functionalities of our Platform may not work.

Third-Party Cookies and Resources to Opt-Out of Cookies and Targeted Advertising

We allow third parties to set and collect cookies through our Platform. Please review such third parties’ privacy policies and other terms for information on their privacy practices and uses of personal information, including whether they use cookies to provide targeted and cross-contextual behavioral advertising and your options to opt-out.

We use the following third-party cookies (and may use others):

  • Google for Google Analytics

  • RB2B (operated by Retention.com) for website visitor identification

    • With your consent, RB2B may use cookies, device identifiers, IP addresses and similar technologies to connect activity on our public website with business contact information or online profiles held by its data partners. We or service providers acting on our behalf may use those associations to send relevant marketing communications. You can opt out through the Retention.com opt-out page at https://app.retention.com/optout.

  • Meta (Facebook) for the Facebook Pixel (retargeting and conversion tracking)

    • The Facebook Pixel is a tracking technology that collects information about your activity on our Platform and combines it with data Meta (formerly Facebook) has collected about you separately. This combination constitutes cross-context behavioral advertising (i.e., a “share” of your personal information under the CCPA/CPRA). Please see Meta’s privacy policy here: https://www.facebook.com/privacy/policy/. To opt out of Meta’s use of your data for targeted advertising, visit Meta’s Ad Preferences at https://www.facebook.com/adpreferences/.

  • LinkedIn for the LinkedIn Insight Tag (retargeting and conversion tracking)

    • The LinkedIn Insight Tag is a tracking technology that collects information about your activity on our Platform and combines it with data LinkedIn has collected about you separately. This combination constitutes cross-context behavioral advertising (i.e., a “share” of your personal information under the CCPA/CPRA). Please see LinkedIn’s privacy policy here: https://www.linkedin.com/legal/privacy-policy. To opt out of LinkedIn’s use of your data for targeted advertising, visit LinkedIn’s Ad Settings at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

To make choices about targeted advertisements from participating third parties, including to opt-out of receiving targeted advertisements from participating third parties, please visit the Network Advertising Initiative at https://www.networkadvertising.org/choices/ or the Digital Advertising Alliance at www.aboutads.info/choices.

To find out more information about cookies, including information about how to manage and delete cookies, please visit https://www.allaboutcookies.org/.

5. Our Participation in Targeted Advertising

Targeted Advertising by Us and Third Parties

Targeted advertising (also known as cross-context behavioral advertising) is advertising based on your interests in topics and content based on your activities over time on the Platform and online services operated by third parties, as well as information from other sources, including information collected offline.

Targeted ads may consist of text ads, images, animations or videos and may be displayed to you based on various factors, including the context of the site or app in which they appear (such as, sport or travel section), information you provided to the operator of the site or app (such as when you created an account), your activities on the site or app (such as, pages viewed, searches performed or ads clicked), and information such as your demographic, interests and household information.

To serve you targeted ads, we use information such as your interactions with the Platform or other content. We work with third parties, such as advertisers, publishers, social media networks, search engines, ad serving companies, and advertising companies working on their behalf, to improve the relevance of ads we and third parties serve to you.

On the Platform and on third-party sites, apps or other media, we, our service providers and third parties may use automated means to collect information for targeted advertising purposes and/or serve you targeted ads. These automated means vary depending on the Platform and include technologies such as cookies. These technologies may use unique identifiers associated with your browser or device to support targeted advertising.

We may use and/or combine online and offline information we obtain about you, including your personal information, for targeted advertising purposes. We may aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.

Targeted ads may be displayed to you by us or by third parties, such as ad networks or exchanges.

If you access the Platform from multiple browsers or devices, we, our service providers and third parties may try to establish connections among and link the different browsers and devices you use to access the Platform and our content or ads published elsewhere. This helps us provide you with a seamless experience across the browsers and devices you use and serve you with more relevant content and ads (for example, so that we don’t show you the same article twice).

Targeted Advertising Preferences

We offer you choices about receiving targeted ads. If you choose not to receive targeted ads, you will still see ads in the Platform but they will not be based on your interests.

You can also generally opt out of receiving targeted ads from third party advertisers and ad networks who are members of the Network Advertising Initiative or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the Network Advertising Initiative at https://www.networkadvertising.org/choices or the Digital Advertising Alliance at https://www.aboutads.info/choices.

6. Our Uses of Personal Information in the Last 12 Months

The below chart summarizes the categories of personal information we have collected, disclosed for our business purposes, sold or shared for cross-context behavioral advertising (or targeted advertising) to the identified categories of third parties in the last 12 months. See the above section called, Categories of Third Parties with Whom We Share Your Personal Information, for more details on the categories of third parties.

Our business purposes for disclosing your personal information are all of the business purposes in the above section called, Our Business Purposes for Collecting and Disclosing Personal Information. Our business purposes for selling your personal information or sharing your personal information for cross-context behavioral adverting or targeted advertising are those purposes identified in the bullet beginning with “Market and advertise our and third-party products and services to you, including through targeted advertising,” in the above section called, Our Business Purposes for Collecting and Disclosing Personal Information.

Category of Personal Information

Collected in Last 12 Months

Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties

Sold or Shared for Cross-Context Behavioral Advertising in Last 12 Months to Categories of Third Parties

Identifiers (for example, name, postal address, email address, IP address, unique personal identifiers)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Personal information (for example, name, address, telephone number, credit card number)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Characteristics of protected persons (for example, age, race, national origin, citizenship, religion, sex/gender)

No

—

—

Commercial information (for example, records of services purchased or considered)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Internet or other electronic network activity (for example, browsing history, search history, website interactions)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Geolocation data (for example, device location)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Sensory data (audio, electronic, visual, thermal, olfactory, or similar information)

No*

—

—

Professional or employment-related information

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Non-public education information

No*

—

—

Inferences drawn from other personal data to create a consumer profile

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

Yes to our Affiliates, Vendors and Advertising Providers

Other non-sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it)

Yes

Yes to our Affiliates, Vendors, Advertising Providers, Authorized Parties, Legal Parties and Transaction Parties

No

Sensitive Personal Information

Category of Sensitive Personal Information

Collected in Last 12 Months

Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties

Sold or Shared for Cross-Context Behavioral Advertising in Last 12 Months to Categories of Third Parties

Government identifying numbers (social security, driver’s license, state ID, or passport numbers)

No

—

—

Complete account credentials (account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account)

No

—

—

Precise geolocation

Yes

No

No

Racial or ethnic origin, religious or philosophical beliefs, or union membership

No

—

—

Mail, email, or text message contents not directed at us

Yes

No

No

Genetic data

No*

—

—

Biometric information processing for the purpose of uniquely identifying an individual

No*

—

—

Health, sex life, or sexual orientation

No*

—

—

Other sensitive information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it)

Yes

Yes to our Affiliates, Vendors, Authorized Parties and Legal Parties

No

*Not specifically collected by us but may be included in the category of “other information you choose to provide”.

7. Data Security and Processing

Security of Personal Information

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers. We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.

International Transfer, Storage and Processing

We operate from the United States and the personal information we collect or receive is stored and processed in the United States and may be processed in other countries around the world subject to the provisions of this Privacy Policy.

If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of personal information to the United States or any other country in which we, our affiliates or vendors maintain facilities. You consent to the use and sharing of information about you as described in this Privacy Policy.

8. Changes and Amendments to Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our Platform with a new “Last Updated” date. Your continued use of our Platform, or your provision of personal information to us following the posting of changes constitutes your acceptance of such changes. We encourage you to visit this page regularly for any changes.

9. Contact; Disability Access

Contact Us

You may contact us with questions, concerns, complaints, or disputes related to this Privacy Policy and our privacy policies and practices.

Disability Access

If you have a disability, you may access this Privacy Policy in an alternative format by contacting us at:

Email: legal@smoke.ai