Privacy Policy

This Privacy Policy describes the practices of Charm Solutions US, Inc. (“CHARM,” “the Company,” “we,” “us,” or “our”), regarding any and all information collected from visitors (our “Users”) to the CHARM website, www.charmsolutions.ai (the “Site”). It describes what information is collected, how that information is used, and under what circumstances that information may be disclosed to others while providing our services to you (the “Services”) and otherwise operating our business. Please read this Privacy Policy closely, as it describes your privacy rights with respect to such information.

Please carefully read this Privacy Policy and the Terms of Service before accessing or using the Services.  By accessing or using the Services you agree to the terms of this Privacy Policy and the Terms of Services.  If you do not agree to the Privacy Policy and the Terms of Services after your close and careful reading, you should not access or use the Site. You must be 18 years or older to use the Site.

We may modify this Privacy Policy at any time by posting a revised version to the Site. If we do so, we will post a notice of change on the Site. Any modification will be effective on the effective date that appears at the bottom of the page of the amended Privacy Policy. You acknowledge and agree that it is your responsibility to review this privacy policy from time to time to learn about any modifications.

This privacy policy applies to www.charmsolutions.ai and all websites owned and/or operated by the Company on which this privacy policy is displayed (such sites are hereafter referred to as the “Charm site,” or simply the “Site”, whether individually or collectively).

Information We Collect

Personally Identifiable Information (“PII”): Subject to your specific knowledge and consent, we collect personally identifiable information that can identify you such as your name, address, telephone number, cell phone number, and email address.

Non-Personally Identifiable Information (“NPII”): We also collect demographic data, online activity data, and other information which could not be used to identify you.

PII and NPII are collectively referred to as “Information.”

How We Collect Information

Information Collected Automatically: We use third party server log analysis tools (such as Google Analytics) to gather statistics from your computer, mobile phone, or other access device regarding the Site’s usage, such as the number of hits received, and errors experienced through browsers and platforms used to connect to our Site. The Site may place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (collectively “Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to track usage patterns, the movements of individual users, and your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer the Site and/or Service.

The following are examples of information about you that we may collect whenever you visit the Site:

  • The Internet Protocol (IP) address and domain used
  • Type of browser and operating system used
  • Device type and ID
  • Date and time of your visit to the Site
  • Web pages you visited
  • Actions you performed or attempted, including clickstream data
  • Codes that correspond to the status of your actions
  • The geographic location of the computer or mobile device you use to access the Site
  • We may also capture your email address when you enter it on a form, regardless of whether you submit the entire form

The above information is used to improve the content and/or layout of the Site. We do not sell or rent any information we collect automatically. We also do not share this information with third parties; provided, however, that we may share information with our service providers in order to process any Services you have requested or other everyday business purposes, such as fraud prevention. We may also engage in geo-tracking and/or geotagging activities.

We may combine this automatically collected log information with other Information we collect about you. You may choose to set your web browser to refuse cookies or Local Device Storage, or to alert you when cookies are being sent. If you do so, please note that some parts of our Site may not function properly.

In addition to Local Device Storage, we may use web beacons, web bugs, clear gifs, and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”). We use Tracking Technologies for all or some of the same lawful business purposes we describe above for use of Local Device Storage.

Information You Provide to Us: We may collect, store, and use personal information you provide to us when using the Site or our Services. This Information could be provided via an online form, over the phone, or via other means in which you interact with our Services. We may use information you provide to:

  • process any Services you have requested;
  • or fraud prevention purposes;
  • to make the Site more useful and easier to use; and
  • for everyday purposes in operating our business.

We may share the information you provide with our service providers in connection with any of the foregoing uses. We do not sell or rent such information to third parties and, except as described in this paragraph, we do not share such information with third parties.

Information from Service Providers and other Third Parties: In the course of providing our Services, Information about you may be collected from third party service providers, such as contractors, social networks, credit bureaus, and other data vendors who have data on your financial profile or other demographic information. Any Information we collect through these sources is treated the same as Information we collect automatically and Information you provide to us.

How We Use Your Information

We may use your Information to:

  • Deliver the Services you requested and otherwise operate our business
  • Improve our Site and customize your experience
  • Improve customer service
  • Communicate with you about products or services that may be of interest to you

We may also use your Information for certain legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any Information (including PII) as reasonably necessary to:

  • Enforce our Terms of service, including investigating potential violations
  • Protect the rights, safety, and security of our Users, our Services or equipment, or any third-party partner or service provider
  • Detect, prevent, investigate, or otherwise mitigate fraud, security or technical issues related to our Services or our business partners
  • Comply with any applicable law, regulation, subpoena, or legal process; respond to any governmental requests; and/or cooperate with law enforcement, if we believe such action is required or permitted by law

Who Do We Share Your Information With?

CHARM Vendors and Contractors: To the extent necessary, we may share your Information with vendors that perform certain services on our behalf. Vendors may include, but are not limited to, marketing companies, business analysis firms, and technology providers. We may also share your Information with our partner contractors to the extent necessary to provide the Services offered through the Site.

Other Situations: We may also disclose your Information in the following circumstances, at our sole discretion:

  • In response to a court order, subpoena, or similar investigative demand; a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency; to establish or exercise our legal rights or defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • When we believe disclosure is appropriate in order to detect, prevent, investigate, or otherwise take action against actual or suspected illegal activity or other wrongdoing, including fraud; to protect and defend the rights, property, or safety of our company, Users, employees, or others; or to enforce CHARM agreements or policies, including our Terms of Service,.
  • In order to detect, prevent, or otherwise address security or technical issues related to our Services or the services of our Providers or other partners.
  • In connection with state and/or federal licensing and registration requirements which may require the reporting of Information from loan inquiries we receive from you. You authorize CHARM to obtain any and all required information from Providers whose products or services you have purchased in order for us to comply with current laws and regulations, as well as with any requests from state or federal regulators. This information could include, but is not limited to, the terms of the loan you selected.
  • In connection with a corporate transaction, such as a sale, divestiture, merger, consolidation, asset sale, or bankruptcy of CHARM or any entity, brand or division thereof.
  • We may share NPII with third parties, at our sole discretion.
  • There may also be certain situations in which we share your PII after receiving your express consent.

Unsubscribe

If you no longer wish to receive marketing communications from CHARM, you may use the unsubscribe link at the bottom of emails that we send to you.

Interest-Based and Third-Party Advertising

Third-Party Advertisers: We may allow third parties to display advertising on the Site. We may share your information with such third-party advertisers in accordance with this Privacy Policy and our Terms of Use. Those parties may also collect information about you, or about others using your computer, through their own tracking technologies. To understand how such third parties may use the information they collect, you will need to review the particular advertiser’s own privacy policy.

In addition, some of our third-party vendors and business partners are advertising networks, marketers, publishers, and other entities who conduct analytics and advertise our products and services on websites with which we are not affiliated (“Advertising Vendors”). In connection with such services, we or our Advertising Vendors may use cookies, web beacons, and other similar technologies to record your preferences, track the use of our Site or other websites, and collect Information in order to perform marketing and other analytics, or to serve you advertisements that are more likely to be of interest (“Interest-Based Advertisements”). In doing so, these third parties may collect non-personally identifiable data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by third parties is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith.

How to Opt-Out of Third-Party Tracking: For those Advertising Vendors who are members of the Network Advertising Initiative, you may opt out of future advertisements by visiting: http://optout.networkadvertising.org. Other Advertising Vendors may allow opt out through the Digital Advertising Alliance opt-out program (http://optout.aboutads.info).

Disclosure Regarding Google Analytics Tracking and Advertising Features: In addition to services from other analytics and advertising vendors, we use Google Analytics to analyze traffic on the Site. Google Analytics collects data including details about your web browser and the computer you use to access our Site, such as the hostname, browser type, referrer, language, and screen resolution. Google Analytics also sets and reads first-party cookies to obtain user session and ad campaign information from your page request.

Google provides users an opportunity to opt-out of Google Analytics Features through Google Ads Settings and their web browser opt-out plugin (https://tools.google.com/dlpage/gaoptout/). For additional information on opting out of interest-based ads by Google, please visit https://support.google.com/ads/answer/2662922?hl=en&ref_topic=2941003.

Do Not Track Signals: Our Site does not currently respond to automated signals regarding online tracking, such as “do not track” instructions from your web browser. Please note that blocking cookies may affect your browsing experience on the internet and may limit your use of certain parts of our Services, including many of the personalized offers and other customized features we may provide.

Other Third-Party Content: We may display other third-party content or links to third-party websites or applications on the Charm site. Please be advised that when you leave our Services or interact with a third-party feature, you should read the applicable privacy policies and terms of service of those parties so that you understand their own information collection and sharing practices.

How We Protect Your Information

We maintain what we believe to be industry standard technical, physical and administrative security procedures and practices to protect your PII against unauthorized access, disclosure, destruction, use, alteration, or disclosure. We use encryption in the transmission of your Information between your system and ours, and we use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your Information. We require any service providers that may have access to your PII to implement and maintain industry standard security procedures and practices. We also require employees to comply with information security safeguards.

Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, however, we cannot guarantee the security of the information you send to us or the security of our servers, networks or databases, and by using the Service you agree to assume all risk in connection with the information sent to us or collected by us when you access, visit and/or use the Service, including without limitation your personally identifiable information or other information, and we are not responsible for any loss of such information or the consequences thereof.

Moreover, if you elect to store information, such as your personally identifiable information or other user account information, where others may access it, we are not responsible for any loss of such information or the consequences thereof. If you lose a computer, mobile or other device, or it is stolen, that contains your personally identifiable information or other information, it is up to you to take all the steps necessary to protect yourself.

In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you via your computer, mobile or other device.

If you are, or believe you have become, a victim of identity theft, or if you become aware that your personal information has been compromised, you may want to contact one of the three nationwide credit reporting agencies identified below to report possible fraudulent activity under your name and learn more about fraud alerts and security freezes that you can place on your credit reports, your right to obtain a free copy of your credit report from each of the credit reporting agencies, and other preventive measures you can take now to help detect and prevent the improper use of your information:

Equifax
1-800-525-6285
P. O. Box 105788, Atlanta, GA 30348
https://www.equifax.com/personal/identity-theft-protection

Experian
1-888-397-3742
P. O. Box 9554, Allen, TX 75013
https://www.experian.com/help/identity-theft-victim-assistance.html

TransUnion
1-800-680-7289
P. O. Box 6790, Fullerton, CA 92834-6790
https://www.transunion.com/identity-theft

You may also visit the website of the Federal Trade Commission at https://www.identitytheft.gov for free information to help you guard against identity theft and for guidance on the recovery steps you can take if you have been the victim of identity theft, including information on how to file an identity theft complaint.

Visiting our Site From Outside the United States

The Site is governed by the laws of the United States and is intended for use only by residents of the United States. We make no representation that the Site is governed by, or operated in accordance with, the laws of any other nation or jurisdiction.

Compliance with Children’s Online Privacy Protection Rule

We do not knowingly collect, use, or disclose PII from anyone under the age of 18. If we determine that a User is under this age, we will not use or maintain their PII without consent from a parent or guardian. If we become aware that we have collected PII from a child under the age of 18, we will make reasonable efforts to delete such information from our systems and records.

California Consumer Privacy Act

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you certain rights and choices regarding how we collect, share, use, and protect your “personal information” and how you can exercise those rights. The CCPA defines “personal information” as information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

We do not share or sell “personal information,” nor have we sold it, in the last 12 months.

Exceptions

Certain information that we collect may be exempt from the CCPA because it is considered public information or covered by financial privacy laws, such as the Gramm-Leach Bliley Act, the California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect “personal information” that is subject to the CCPA, that information, our practices, and your rights are described below.

Under the California Consumer Privacy Act, California residents have the right to:

  • Request that a business delete any personal information about the consumer which the business has collected from the consumer
  • CHARM collects the following categories of personal information:
    • Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
    • CHARM’s Customers records information: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information; and
    • Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
    • The categories of personal information that it has collected about that consumer.
    • The categories of sources from which the personal information is collected.
    • The business or commercial purpose for collecting or selling personal information.
    • The categories of third parties with whom the business shares personal information.
    • The specific pieces of personal information it has collected about that consumer.
  • Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
    • The categories of personal information that the business collected about the consumer.
    • The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
    • The categories of personal information that the business disclosed about the consumer for a business purpose.
  • Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

You may submit a CCPA request by providing your first name, last name, email address, telephone number and ZIP code via email:

  • Emailing us at [email protected].  Again, please include the above information and your specific CCPA request as described above.

We will not discriminate against you because you exercise any of the rights as described in this section.

Nevada Residents

Nevada residents have the right to opt out of the sale of certain pieces of their information.  We do not sell “personal information” of Nevada residents, but, if you are a Nevada resident who has questions or who wants to make this type of request, please send your email to ([email protected]).

How to Contact Us

If you have any questions about this privacy policy, our business practices, or your relationship with CHARM, please contact us at:

Information Security & Compliance Office
Charm Solutions US, Inc.
535 Middlefield Road
Suite 280
Menlo Park, CA 94025

or by email at [email protected]

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