This Notice describes Chief’s privacy practices for Personal Data collected by Chief websites (“Sites”) (together the “Service(s)”) as well as other activities, such as if you attend a Chief event or otherwise interact with Chief and provide Personal Data, such as corresponding by email, unless such activities are covered by our other notices outlined below.

Please read this Notice in full. By using our Sites, using the Services, or participating in other activities with Chief described below, you consent to the collection, creation, sharing and use of information as described in this Notice, where consent is required by relevant law.

Unless specifically identified, references to Services will include both the operation of Sites as well as the Services.

As a convenience to visitors to our Sites, we may also provide links to other websites that are not governed by this Notice. These linked websites are not under the control of Chief and we are not responsible for the content on such websites or the protection/privacy of any information which you provide while visiting such websites.

The Personal Data Chief may collect about you will depend on your interaction/relationship with us. It may include:

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• account information you give us about yourself, such as contact information
• equipment information we collect about equipment on our network like the type of device you use, device ID, and phone number if you browse our Sites, information systems data relating to your interaction with our Sites, such as location (e.g., IP address), cookie related information (see section 6 below), usage (e.g., mouse clicks, page visits, feature usage, view time, downloads) and other information, such as language preference;
• location information we collect which is automatically generated when devices, products and services interact with cell towers and Wi- Fi routers. Location can also be generated by Bluetooth services, network devices and other tech, including GPS satellites;
• if you complete a webform on our Sites (e.g., to make a purchase), attend a Chief event (online or in-person), or otherwise send this data to Chief (e.g., by email, telephone, exchange of business cards), identifying/contact information such as your name, job title, work email, organization/employer name, work telephone, and location information such as work address;
• if you purchase Chief products or Services, financial or billing data, such as name, address, credit card number or bank account information;
• if you attend a Chief event (in-person or online), your attendance details (e.g., entry time);
• if you avail yourself of Chief Services, submit a technical support case, your activity with Chief to interact with and take part in these services;
• your image and/or voice, such as for phone/video call recordings (for training, quality assurance and administration purposes), if you attend a Chief event (event recording), post an image/recording to a Chief Site (e.g., add a profile photo to a Forum) or you otherwise send a recording/image to Chief;
• information from otherwise engaging/interacting with you, such as your feedback to us through our Services and responses to any promotional or survey communications; and/or

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We may also collect Personal Data about you from third parties, such as vendors (e.g., web analytics tools, data enrichment providers) and Chief partners (e.g., where your contact details are provided to enable delivery of Chief software, for customer success purposes and/or in relation to maintenance/support, including renewal and/or cancellation of same). We also maintain social media pages and may collect Personal Data from you when you interact with these or communicate with us through our social media pages.

Depending on your relationship with Chief, we may use your Personal Data for different purposes. Where required by applicable law in relation to the particular use, we will obtain your consent to collect and use your Personal Data. Otherwise, we will rely on another legal basis, such as in connection with a contract or for our legitimate interests, as set out below.

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• Perform a contract: We may process your Personal Data in connection with a contract with you or your organization, such as to process relevant payments, deliver (customer) or receive (vendor) products/services.
• Operate our Services: We may use your Personal Data to provide our Services, content and offerings (e.g., downloads, registrations for accounts or profiles, such as a Chief account), including necessary functionality, content customization (e.g., based on what we think will interest you), and functionality to enhance ease of use (e.g., make the Services easier for you to use by not making you enter information more than once, etc.). Unless such processing is in connection with a contract or our legitimate interests, it will be on the basis of your consent.

• Improve our Services: We process your interactions with our Services, content and offerings (e.g., Chief support) to assess and improve these and the user experience, such as by use of cookies (see section 6 below). This data is typically aggregated unless Personal Data is required for the particular processing operation. We process your Personal Data for this purpose for our legitimate interests of maintaining and improving our Services and providing tailored content, or where required by law, on the basis of your consent.
• Manage contact requests: We may use your Personal Data to reply to contact initiated by you, such as through a webform, chatbot, survey responses or Chief support. We process your Personal Data for these purposes for our legitimate interest in replying to/fulfilling your request, collecting survey responses and carrying out our contractual obligations under the applicable terms (e.g., providing Chief support).
• Other communications: We may use your Personal Data to otherwise communicate with you to manage our relationship with you/your organization, such as to manage our offerings, for customer success purposes, to contact you regarding updates to our offerings you may be interested in, and to run surveys. Such processing will be to fulfil our contractual obligations, where necessary for our legitimate interests or, where legally required, with your consent.
• Billing: We may use your personal data for billing, collection, and protection of our property and legal rights.
• Call recording: We may record phone or video calls (e.g., Zoom) for training, quality assurance, the functionality of programs, functionality, or features you have selected, and/or administration purposes. We process this Personal Data on the basis of our legitimate interests however, if required under applicable law, we will obtain your consent or give you the option to object to the call being recorded.
• Marketing: We may use your Personal Data to contact you for marketing purposes, such as to alert you to product upgrades, special offers, updated information/services from Chief, and to contact you (e.g., by phone or email) regarding your interest in our offerings and/or invite you to Chief events. Such contact will be on the basis of legitimate interest or, where legally required, on the basis of your consent. To opt-out of marketing contact, please unsubscribe here dpo@GetChief.com.
• Events: We may process your Personal Data to operate Chief events, including training/education related activities, in-person and online, that you have selected to attend. Such processing will be on the basis of our legitimate interests or to perform a contract with you under the applicable terms of service.
• Manage premises: Where you attend our offices, we may process your Personal Data to administer our premises and fulfil our legal obligations regarding health and safety, and to manage the security of our premises to ensure there is no unauthorized access. Such processing will be on the basis of our legitimate interests and/or to carry out our legal obligations.
• Compliance and Security: We process your Personal Data to comply with our legal obligations and to ensure compliant use/security, such as to ensure the use of our Services, content and offerings in compliance with our terms and/or to ensure their security, to cooperate with courts, regulators or other government authorities to the extent processing/disclosure of Personal Data is required under applicable law, where it is necessary to protect our legal rights or those of others, or for other compliance purposes such as auditing, investigations and responding to legal processes or lawful requests. Where we process health related data for Covid-19 related reasons or to accommodate a reasonable adjustment for a disability, we will only do so to carry out our legal obligations relating to health and safety, under applicable law.
• Professional advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.
• Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
• We may also combine Personal Data we hold about you. For example, we may combine your contact information with your usage data relating to our offerings and our Services for the purposes above, such as to improve our Services and our offerings, as well as to create more tailored experiences by providing content that may be of interest to you. We may also use your Personal Data to fulfil any other purposes disclosed to you at the time of collection or as otherwise required/permitted by applicable law.

We’re using AI tools at Chief to help you solve complex problems, work more efficiently, and gain better insights into your company. We are committed to using AI responsibly. We want you to know how AI works, and how we use your information to make these features and tools available to you with the Chief suite of products.

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Primarily, Chief is an AI assistant that is built to help you understand your data across a range of platforms. Chief’s primary sources of data are the platform on which the Chief tools run, and other platforms to which you grant Chief access.

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Chief uses these data sources to understand the questions you ask it. Chief takes the question you ask, contextualizes the input, and provides you with a best-fit answer. Not every question will have an answer, but this starting point lays the foundation for even deeper functionality in the future.

It is also important to note that as part of your interaction with Chief you may provide prompts, queries, or inputs to Chief’s artificial intelligence tools, which tools may then provide outputs, replies, or answers, all of which may be used to improve Chief’s products.

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What Chief IS:

• It helps you make the most of your data and answers your questions about the data.
• It performs contextual search based on what’s contained within the datasets you expose to Chief.

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What Chief ISN’T:

• It will not perform content creation tasks for you.
• It is not a competitive tool. It will not provide any information from other Chief customers.
• It is not an expert on your business. While Chief is a great tool for getting the most out of your data, it is just a tool. You know what is best for your business and team.

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If you have any questions about our use of AI, including privacy concerns, please email: DPO@getchief.com

Chief may share Personal Data for various purposes, such as:

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• within the international group of Chief companies to operate our business and provide our Sites, products and Services;
• with authorized Chief vendors, advisors and contractors providing services on our behalf (such as a technology or professional service providers) to operate our business, Sites, products and Services;
• if you register for or attend a Chief event, Chief may share participant information (e.g., your name, organization, work email) with other participants, organizers or hosts of the same event in order to facilitate the event and the subsequent exchange of ideas. Chief may also share your contact details with event sponsors where you have consented, e.g., through registration, to these sponsors contacting you regarding their own offerings. Your contact details may also be used by other hosts of the same event, such as to send marketing material, according to their privacy notices provided to you;
• sharing with non-Chief companies or entities where authorized or required by law. This can happen when we: (i) comply with court orders, subpoenas, and lawful discovery requests, and as otherwise authorized or required by law; (ii) detect and prevent fraud; (iii) provide or obtain information related to payment for your service, (iv) route your calls or other communications, (v) defend and enforce our legal rights.

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Chief will only share Personal Data to the extent needed to perform the relevant use and will take such steps as are necessary to safeguard Personal Data. For example, our vendors, advisors and contractors are required to keep such Personal Data confidential and not to use it other than for the purposes intended. Chief partners are obliged to comply with the privacy rules set out in their agreement with Chief. Chief does not sell or rent Personal Data to third parties.

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Chief may also disclose Personal Data to comply with legal requirements, such as in relation to legal proceedings or investigations by governmental or law enforcement agencies (including national security agencies), or to meet tax or other reporting requirements, including to (a) protect and defend the rights or property of Chief, including the defense and management of legal claims and investigations, (b) act in urgent circumstances to protect the personal safety of users our Services, our Chief team members, or the public, (c) as part of a merger or change in corporate ownership or control, and/or (d) as otherwise permitted or required by applicable law.

As is true of most websites, when you visit our Sites, cookies will be placed on your device (computer, mobile or tablet). A "cookie" is a small text file that is placed on your device by websites you visit. Some of the cookies we use are strictly necessary to operate our Sites. Others relate to the Site's performance, functionality and/or to advertising. Information relating to a cookie or similar technology may include identifiers such as IP address, and information like general location, browser type and language, and internet activity such as timestamps. Chief uses the following types of cookies and similar technologies on our Sites:

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A. Strictly Necessary: These cookies enable the Sites to function correctly and deliver the Services and products you have requested. These cookies do not gather information about you that could be used for marketing or remembering other websites you have visited on the internet.

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B. Functional: These cookies do things like remember your preferred language, understand your preferences and associate users to forms submitted to enable pre-completion of subsequent forms as well as improve and customize your experience on our Sites.

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C. Performance: We use third-party analytics tools to help us analyze how our Sites and other electronic mediums are used, such as allowing us to compile reports on website activity, providing us other services relating to website activity and internet usage and whether email communications are opened or left unread.

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D. Advertising: These cookies may be set on our Sites by our advertising partners. They may be used to build a profile of your interests and/or show you relevant adverts on other sites. If you wish to not have your online information used for this purpose, you can also visit resources such as https://optout.networkadvertising.org and/or https://www.youronlinechoices.eu (please note these and similar resources do not prevent you from being served ads as you will continue to receive generic ads).

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Cookies can be session-based (which disappear once you close your device or browser) or persistent (which remain on your device afterwards). Chief may also rely on cookies or similar technology operating on other websites, for example, to display our adverts to you. You can generally disable the use of cookies by changing your browser settings. You may also adjust your browser settings, however if you choose to not have your browser accept cookies from the Chief Sites, you will not be able to experience a personalized visit, and it may limit your ability to use some features on our Sites. For more information about cookies, visit https://www.aboutcookies.org. We may also use pixels, web beacons and similar technologies on our Sites and in emails, for example in a marketing email that notifies us if you click on a link in the email.

Chief takes appropriate precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Such measures may include (i) using security controls such as, passwords, firewalls and/or encryption, (ii) restricting Personal Data to those with a legitimate purpose in receiving/accessing it, (iii) deidentifying Personal Data, or assigning codes or pseudonyms when the personal identifiers are not required for the purpose at hand, (iv) providing training and internal policies to team members to embed privacy and security across our organization, and (v) putting in place relevant procedures (such privacy and security vetting) and contracts relating to the use and protection of Personal Data with third parties.

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Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is fully secure, and no one can guarantee absolute data security.

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You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential

Chief will retain and process Personal Data for a period of time consistent with the purpose of collection (see section 3 above) and/or as long as necessary to fulfil our legal obligations. We determine the applicable retention period by taking into account the (i) amount, nature and sensitivity of the Personal Data, (i) relevant use, including whether we can achieve the use through other means (e.g., by instead using deidentified data); (iii) potential risk of harm from unauthorized use or disclosure of the Personal Data, and (iv) applicable legal requirements (e.g., statutes of limitation).

We don’t knowingly collect personal information from anyone under 18. We also won’t contact a child under 18 for marketing purposes without parental consent. Chief Services are intended for adult use and not for use by minors.

Chief strives to resolve complaints about your privacy and our collection or use of your personal information. Inquiries or complaints should first contact:

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Via US Postal Service at:

Chief, Inc.

Attn: Privacy-Legal

3908 E Elmwood Street

Mesa, AZ 85205

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or

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Via email at:

DPO@GetChief.com

Chief reserves the right to modify or update this Notice from time to time to reflect changes in technology, our practices, law and other factors impacting the collection/use of Personal Data. You are encouraged to regularly check this Notice for any updates. We may also collect, use and disclose Personal Data for other purposes otherwise disclosed to you at the time of collection/processing in a supplementary notice.

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Last updated: Nov 16, 2024