Privacy Policy

1. Introduction

1.1. This Privacy Policy ("Policy") describes how Safebooks, Inc. and its wholly owned subsidiaries (collectively, "Safebooks", "we", or "us") collect, use, and process personal information. This Policy applies to visitors, event attendees, and customers (collectively, "Engagers").

1.2. This Policy explains Engagers rights and choices related to the personal information we collect when:

• Interact with our websites, including www.safebooks.ai as well any other websites that we operate and that link to this Policy (our "Sites");
• Visit, interact with, or use any of our offices, events, sales, marketing or other activities;
• Use our platform, including software and other products and services (the "Solutions")

1.3. Safebooks determines the purposes for and means of the processing of personal information as described in this Policy unless expressly specified otherwise.

2. Personal Information Collection

2.1. We may collect the following types of personal information:

• Business contact information, such as first and last name, professional title, business affiliation and address, email, and phone number.
• Services account information, such as the Solutions used by Engagers, webinars and other events Engagers sign up for, transactions, and business relationship information.
• Communications with us, including questions or inquiries Engagers may send us, and any information that was created, input, submitted, posted, uploaded, transmitted, stored or displayed on our Sites.
• Activity Data: Device identifiers and online activity via cookies. For details, see our Cookie Policy.

2.2. We may also obtain personal information from other sources, including:

• Third parties, such as business intelligence services, event co-sponsors, and other data providers
• Public sources, such as company websites and our pages on social media platforms.

3. How We Use Personal Information

3.1. We use personal information for the following purposes:

3.1.1. Service Provision:

• Safebooks Site. When Engagers visit our Sites, we use personal information to interact with them, provide relevant marketing data and information, connect about our Solutions, personalize or customize the experience (based on preferences or geography, for example), conduct research (such as to test the performance and layout of our Sites), and to improve the content and availability of the Sites.
• When Engagers interact with any publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features on our Sites, we may display any information that was posted and that information might be read, collected, and used by others who access it.

3.1.2. Compliance & Protection: We also use personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; protect rights, privacy, safety, or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern our Solutions; and prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

3.1.3. Sharing Notice: We may share personal information with third parties as described in this Policy. Where required by applicable law, Engagers may have the right to opt out of certain disclosures, including disclosures for targeted advertising.

3.1.4. No Sale of Data: Safebooks does not sell personal information as defined by U.S. state privacy laws (see Chapter A for specific definitions regarding "sharing" for advertising).

3.2. Valid Legal Ground: Safebooks will only use Engagers personal information as described in this section if we have a valid legal ground for the processing under applicable laws. Our legal grounds for processing include:

• Consent, where Engagers have consented to the use of your personal information (including, where applicable, to receive marketing communications);
• Legitimate interests, such as to promote, develop and improve our Sites and Services, to protect our legal rights, and to establish, exercise, or defend legal claims, provided that such interests are not overridden by the Engagers interests or their fundamental rights and freedoms;
• Legal obligations, including to comply with tax and accounting obligations.
• We may also process Engagers personal information when necessary to protect vital interests.

4. How We Share Personal Information

4.1. We share personal information with:

4.1.1. All Safebooks entities in the US and worldwide, for purposes consistent with this Policy.

4.1.2. Service providers. Companies and individuals that provide services on our behalf or support our Services (such as hosting, information technology, customer support, email delivery, and website analytics services). Safebooks contractually requires all its third-party business partners with whom it shares personal information to take commercially reasonable steps and implement policies to safeguard your personal information, and not to use your personal information for any purpose other than Safebooks serving its customers.

4.1.3. Professional advisors such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.

4.1.4. Authorities such as but not limited to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

4.1.5. Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Safebooks (including in connection with a bankruptcy or similar proceedings). We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.

4.1.6. Safebooks does not sell the personal information we collect as "sale" is defined in Virginia, Nevada, Colorado, and California.

5. Use of Cookies and Web Technologies

5.1. Safebooks Sites, Solutions, and advertisements may use automatic data collection tools such as cookies, embedded web links, and web beacons. Additional details about how Safebooks uses these technologies, and how Engagers may limit our use of online tracking technologies is described in our Cookie Policy.

6. Third-Party Links

6.1. The Sites may include links to third-party sites, products or services. Engagers' access to and use of these third-party sites, products or services may result in the collection of or sharing of information, including personal information.

6.2. These third parties have separate and independent privacy policies, Safebooks is not responsible or liable for Engagers interactions with such third-parties.

6.3. The option to link to such third-party sites, products or services is not an endorsement or representation regarding any third-party sites, products or services. Safebooks encourage Engagers to review and understand such third parties' privacy policies.

7. Security and International Transfer

7.1. Security Measures: Safebooks maintains organizational and technical measures, including TLS 1.3 encryption for data in motion and AES-256 for data at rest.

7.2. Global Operations: As a U.S.-based company, Safebooks may transfer information globally. Transfers from the EU or Israel utilize European Commission-approved Standard Contractual Clauses.

8. Privacy Choices

8.1. Depending on your location, you may exercise the following rights by contacting privacy@safebooks.ai:

• Unsubscribe from marketing communications: Follow instructions listed at the bottom of received emails or by contacting us.
  • By opting-out from marketing-related communications, you will continue to receive service-related and other non-marketing communications;
• Access/Portability: Request a copy of your personal data.
• Correction/Deletion: Update inaccuracies or request data removal.
• Objection/Restriction: Object to processing based on legitimate interests.
• Verification: To prevent security breaches, we will authenticate your identity before responding to these requests.

8.2. To avoid security breaches, Safebooks will need to authenticate the Engager's identity before responding to the request and to assess whether these rights apply.

8.3. Additionally, applicable law can limit these rights, for example, by prohibiting Safebooks from providing certain sensitive information in response to an access request and limiting the circumstances in which the Company must comply with a deletion request.

8.4. While we endeavor to satisfy the requests we receive, any Engager that might be unsatisfied with the response to their request, has the right to reach out to a privacy or data protection regulator in their country.

9. Children's Personal Information

9.1. Safebooks solutions are not intended for use by children. If you have reason to believe that a child has provided personal information to us, please contact us immediately at privacy@safebooks.ai. We will use commercially reasonable efforts to delete such personal information.

10. U.S. State Privacy Laws

10.1. Some U.S. state privacy and data protection laws like the California Consumer Privacy Act (CCPA) and Virginia Consumer Data Protection Act (VCDPA) require specific disclosures for state residents. If you are a resident of a state that has imposed specific privacy requirements, please refer to Chapter A below: Notice to U.S. Residents (California, Virginia, and others).

11. Retention

11.1. We retain personal information for as long as necessary to fulfill the purposes for which we collect it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

11.2. 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 personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. Changes to This Policy

Material changes to this Policy will be communicated via a prominent notice on our Sites prior to becoming effective. Your continued use of our Sites constitutes agreement to the updated Policy.

13. Contact Information

For any question or inquiry regarding this Policy or about our privacy practices, please contact us:

Email: privacy@safebooks.ai
Postal Address: 1207 Delaware Ave #672, Wilmington, DE 19806

Chapter A: Notice to U.S. Residents (California, Virginia, and others)

This section applies to residents of U.S. states with specific privacy laws, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), and Connecticut (CTDPA).

1. Personal Information We Collect

We have collected the following categories of personal information within the last twelve (12) months:

• Identifiers (e.g., name, IP address, email).
• Commercial Information (e.g., records of products or services purchased).
• Internet Activity (e.g., browsing history, interactions with our Site).
• Professional or Employment-Related Information.

We obtain this information directly from you or indirectly through your activity on our Solutions.

2. Use and Disclosure of Personal Information

We use this information for business purposes as described in our main Privacy Policy (e.g., providing solutions, security, legal compliance). In the preceding 12 months, we have disclosed these categories to our Service Providers (processors) for business purposes.

3. No Sale of Personal Information

Safebooks does not sell personal information for monetary consideration. However, Safebooks may share certain personal information (such as device identifiers and online activity data) with advertising and analytics partners for purposes of targeted advertising or cross-context behavioral advertising, subject to Engagers' cookie preferences.

4. Your Privacy Rights

Depending on your state of residence, you may have the following rights:

• Right to Know / Access: The right to confirm whether we process your personal information and to access such data.
• Right to Delete: The right to request that we delete personal information you provided or that we obtained about you.
• Right to Correct: The right to correct inaccuracies in your personal information.
• Right to Data Portability: The right to obtain a copy of your data in a portable and, to the extent technically feasible, readily usable format.
• Right to Opt-Out: The right to opt-out of the processing of your personal data for purposes of: (i) Targeted Advertising; (ii) The Sale of Personal Data; or (iii) Profiling in furtherance of decisions that produce legal or similarly significant effects.
• Opt-Out via Cookie Preferences: Safebooks uses cookies, pixels, and similar technologies for analytics and targeted advertising (including retargeting). Where required by law, Engagers may opt out of the sharing of personal information for these purposes by adjusting their cookie preferences through our cookie consent tool available on our Site.
• Targeted Advertising Disclosures: In the preceding twelve (12) months, Safebooks may have shared identifiers (such as IP address or device ID) and internet activity information (such as interactions with our Site) with advertising and measurement partners in order to provide and evaluate targeted advertising, subject to Engagers' cookie choices.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

5. Right to Appeal (Virginia, Colorado, Connecticut)

If we decline to take action regarding your request, we will inform you of our decision and reasoning. If you are a resident of Virginia, Colorado, or Connecticut, you have the right to appeal our decision. To appeal, please reply to our decision email or contact us at privacy@safebooks.ai with the subject line "Privacy Appeal".

6. California-Specific Disclosures (CCPA)

• Verification: We may require specific information to verify your identity before processing your request.
• Authorized Agent: You may designate an authorized agent to make a request on your behalf.
• Shine the Light: California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. Safebooks does not share personal information with third parties for their direct marketing purposes.

7. Exercising Your Rights

To exercise any of the rights described above, please submit a verifiable consumer request to: Email: privacy@safebooks.ai.

We endeavor to respond to verifiable consumer requests within 45 days. If we require more time, we will inform you of the reason and extension period in writing.