Scope: Applicability to you

Generally, ChaiOne acts as a service provider (as defined by the CCPA) and offers services to its customers services to collect and analyze workforce member, and customer feedback. As part of our services, our customers (typically either your employer, or other company that is ChaiOne’s direct customer) may share your information with us for ChaiOne to contact you about your experiences. When we are collecting information from you on behalf of our customers, we will only collect, use, and otherwise process your personal information as directed by our customers. Accordingly, this Privacy Policy does not apply to the extent we process Personal Data in the role of a data processor on behalf of our customers.

To this end, if you have received a Survey from ChaiOne on behalf of your employer, or other company that is ChaiOne’s direct customer, this Privacy Policy does not apply to your information. For detailed privacy information related to when we process your information on behalf of a ChaiOne customer, or if you need to access or delete any personal data we may have collected from you as permitted by applicable law, please reach out to the respective customer directly. If you are unsure what customer directed us to collect information on their behalf from you, please consult the survey invitation you received that directed you to our services. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Policy. For more information, please see below.

If you are personnel of a ChaiOne customer who is using our services, analyze, or otherwise process Survey responses in your professional role, this privacy policy does not apply to you. In such a case, we only collect business related information from you (i.e., email and username), and we do not use, share, or otherwise process any of your personal information except to perform our services or as otherwise set forth in the agreement between you and your employer. Accordingly, for detailed privacy information related to your use of the Site when receiving or using our services, or if you need to access or delete any personal data we may have collected from you as permitted by applicable law or the agreement between us and our customer, please reach out to your employer directly.

Further, this Notice does not apply to:

•  Information or organizations excluded from the CCPA’s scope, including:
  • Medical information governed by the California Confidentiality of Medical Information Act (CMIA), protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or a provider of health care governed by the CMIA or covered entity governed by HIPAA to the extent the provider or covered entity maintains patient information in the same manner as medical
    information or protected health information under the CMIA or HIPAA, respectively;

• • Information collected as part of a clinical trial subject to the Common Rule, pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the U.S. Food and Drug Administration (FDA);
• Publicly available information from government records;
• Deidentified or aggregated consumer information; and
  • Other exclusions as set forth under applicable CA law.

Note that information regarding ChaiOne job applicants, employees, owners, directors, officers, or contractors, emergency contact information from the same, and information necessary for ChaiOne to administer benefits to the same, and information ChaiOne obtains from a consumer acting on behalf of a ChaiOne and whose
communications with ChaiOne occur solely within the context of ChaiOne conducting due diligence regarding, or providing or receiving a product or service to or from another ChaiOne, are generally exempt from much of CCPA. In the event that ChaiOne is not acting as a service provider, and your personal information is not otherwise excluded as set forth above, the following information applies to how we, collect, use, and share your personal information, e.g. via the website or through surveys.

Information We Collect

Our Site and Survey forms collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, ChaiOne has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, professional information, email address, account name, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, address, telephone number, online identifier, email address, Internet Protocol address, or some other similar identifiers. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No, unless requested by our customers (in which case this Notice would not apply).
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template, or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
J. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

 

ChaiOne obtains personal information from the following categories of sources:

• We collect Category A and B information directly from you. For example, from forms you complete or other information you provide directly to us. 
• We collect Category A, F, G and J information indirectly from you. For example, from observing your actions on our Website or Survey form.

Use of Personal Information 

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Sharing Personal Information 

Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we generally enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Categories A (Identifiers) and B (California Customer Records personal information categories) collected for a business purpose to third party vendors who provide marketing, payment processing, and other services to us.

Sale of Personal Information 

In the preceding twelve (12) months, Company has not sold personal information, including the sale of personal information of minors under 16 years of age without affirmative parental authorizations.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that ChaiOne disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you: 

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that ChaiOne delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Email us at optout@chaione.com

Contacting us at the contact information listed below.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (“an Authorized Agent”), may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice (2X) within a twelve (12) month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an Authorized Agent. Before completing your request to exercise the below, we will verify that the request came from you by requesting additional information based on the request, including but not limited to, name, email address, date and time you visited our website or responded to our survey, forms completed while visiting our website.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. With few exceptions, we will only review and fulfill a request from your Authorized Agent if (a) you grant the Authorized Agent written permission to make a request on your behalf, (b) you or the Authorized Agent provides us notice of  that written permission, and (c) we are able to verify your and the Authorized Agent’s identity in connection with that notice and the request.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

 

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: privacy@chaione.com
• By visiting this page on our website: https://www.chaione.com/contact
• By phone number: +1-888-316-0357
• By mail: ChaiOne Inc., 1000 Main St, Suite 2300, Houston, TX 77002