PANSO INC.
PRIVACY POLICY

Panso is a business-to-business provider of software products and services. This Privacy Policy describes the data handling practices of Panso, LLC and its affiliates (collectively, “Panso” or “we” or “us”) as a data controller in connection with your use of Panso’s website at www.hellopanso.com, including the customer portal, and Panso’s online products and services (including application programming interfaces, or “APIs” ) (all the foregoing, collectively, the “Services” ).

This Privacy Policy describes the types of information we may collect about visitors to our website ( “Visitors”) and individuals (“Customer Representatives”) acting on behalf of our business entity customers (“Customers”) that use our Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read it carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this website or using our Services, you agree to this privacy policy.

We have organized this Privacy Policy into the following sections:

1. Information you share with us
2. Information we collect from you
3. How we use your information
4. Information sharing and disclosure
5. Choices about our communications with you
6. Data security and retention
7. Your privacy rights, choices and disclosures
8. Users outside the United States
9. Privacy Policy changes
10. Contact information

This Privacy Policy does not address: (1) personal information that is collected by our Customers (either with or without the use of the Services) and provided to Panso for processing (“Customer Information”). Such Customer Information may include personal information of Customer’s employees, authorized users and individuals (“Patrons” ) who are the customers of our Customers. Data of Patrons may include transaction data, payment data, bookings and reservations, and communications (via email, text or portal messages) between Customers and their Patrons. Panso’s processing of personal information contained in Customer Information is governed by a separate data processing agreement between Panso and the Customer. If you are an employee, authorized user or Patron of our Customer, please understand that Panso and Customer are independent parties, and Panso has no control over the Customer’s privacy practices; please review the privacy policy of the Customer to understand the Customer’s practices and direct any questions, concerns, or data rights requests to the Customer.

In addition, our Services may contain applications and content by third parties. This Privacy Policy does not apply to such applications and third-party content. We encourage you to review the data privacy terms of any third-party providers you engage with.

1. Information Voluntarily Provided.

If you communicate directly with Panso, Panso may collect and store personal information that you share with us, including, but not limited to, your name, a home, business, or other address, company name, title, billing address, phone number, and email address, as well as other information that you provide or which may be needed to provide a service or information you requested. You may have provided or provide such information

1. through forms you fill out on our website or through your correspondence with us,
2. if you have requested support from us,
3. through our blogs, webinars or social media channels or
4. if you are participating in a survey, contest or other promotional event we may offer from time to time.

Our website may now or in the future utilize a chat feature to provide customer support. Use of a chat feature is completely voluntary. Chat sessions will be recorded and used by both us and our chat service provider. We may now or in the future provide customer support via chatbox or email that utilizes artificial intelligence (AI) and nature language processing (NLP) to understand customer questions and automate responses to them, simulating human conversation. If you do not consent to these terms, please do not use the chat feature and contact us via email

If you inquire about a career at Panso, you will also be asked to provide additional information including your resume. We utilize a third party provider to host our job applications and assist with the application process which has their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms. We will use the personal information of job applicants solely for employment evaluation purposes. Providing this information is completely voluntary.

Our website contains links to other websites, but Panso is not responsible for their privacy practices. We encourage you to learn about the privacy policies of such third-party partners you communicate with.

Panso does not intend to collect information from individuals who identify themselves as under eighteen (18) years of age. No one under the age of 18 may provide any personal information to or on the Services. Panso does not knowingly solicit personal information from children under the age of 18 or send them requests for personal information. Panso will not knowingly disclose personal information of children under 18 to any third party. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at hello@hellopanso.com

2. Information Automatically Collected.

As Visitors, Customer Representatives and Patrons navigate through and interact with our Services, subject to your settings and choices as discussed in this Privacy Policy, we may use common data collection technologies to collect certain statistical information. In particular, our Services may report telemetry data back to us. Such information may include data about your network, including traffic data, location data, logs, and other communication data, devices, internet connection, browser type, internet service provider and operating system. We process and analyze this information in order to build, run and continue to improve our Services and in order to better understand our customers’ needs. The information we collect through these tracking tools is statistical in nature, but may be aggregated with personal information in order to help us to deliver a more personalized website and Product, including by enabling us to estimate our audience size and use patterns, store information about your preferences to allow us to customize our website in accordance with your individual interests, speed up your searches and to recognize you when you return to our website.

The processes we use for automated data collection may include:

Cookies. Cookies are small data files that certain websites write to your hard drive when you visit them, and they record and store your information. A cookie file can contain information such as a user ID that the site uses to track the pages you’ve visited. The Panso website may use cookies to collect this type of information to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information.

Web Beacons. Web beacons also known as pixel tags are electronic images, contained on a website that permit us to count users who have visited those pages, to determine the effectiveness of our communications (e.g., whether you opened an email), and for other website and marketing statistics.

Web Analytics. We also collect some information (ourselves or using third party services) using web analytic tools. We use third-party services that use tracking technologies to capture aggregate usage and volume statistics about online activities over time and across our and third-party websites and other online services. We use Google Analytics to identify the frequency of use of certain areas of our website and to identify preferences. For more information regarding how Google collects, uses and shares your information, please visit www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

Social Media. We operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

Recordings. From time to time our interactions with you may be conducted over the telephone or video-conference, and such telephone calls and video conferences may be recorded.

Mobile Device Information. When using your mobile device to visit, access or use the Services, additional categories of information that we collect may include:

• Your name associated with your mobile device;
• Your telephone number associated with your mobile device;
• Your geolocation;
• Your mobile device ID information; and
• With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps).

3. How We Use Your Information.

Panso uses information that you share with us or that we collect about you, including personal information, for the following purposes:

• to provide you with the Services you have requested from us, respond to your concerns and inquiries, and to provide maintenance and support;
• to present our website and its contents to you and to personalize your experience on our website;
• to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business;
• for testing, research, analysis, and product development, including to develop and improve our website, products, and services;
• as described to you when collecting your personal 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 information held by us about you is among the assets transferred;
• to keep you up to date on the latest Services announcements, software updates, special offers, changes to the website or other information we think you would like to hear about either from us or from our business partners; you may opt-out from receiving such communications by following the process described below;
• to understand and analyze the usage trends of your use of our Services;
• in anonymized form for internal purposes such as performing research and analysis and to provide reporting internally or externally;
• to allow you to purchase and download Services and participate in their interactive features, when you choose to do so;
• to better understand your needs and provide you with better Services;
• to carry out our obligations and enforce our rights from any contracts entered into between you and Panso such as our license agreements or terms of use, including communications related to payments and changes to our terms, conditions and policies;
• to provide our Services to Customers, including processing Patrons’ personal information, such as in connection with transactions and payments, managing accounts and profiles, administering loyalty programs and facilitating contests, giveaways or other promotions;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• to fill employment positions;
• in any other way we describe to you at the time you provide the information or for which you have provided your consent; and
• for other legitimate business purposes.

The information you provide to Panso’s third-party partners will also enable such partners to let us know that you have contacted them. Such communication information may be used to distribute information back to you about Panso.

If you are using our software Services, we may from time to time send you certain communications such as service announcements or administrative messages. Such communications are part of the functionality of our software Services. You can therefore not opt-out of receiving such non-marketing announcements or administrative messages.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal information not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

We may now or in the future use your mobile number to send you a confirmation text when you register with us. We may send you service-related announcements when it is necessary (for example, if we must temporarily suspend our service for maintenance). Also, you may choose to receive promotional texts from us based on preferences that you indicate. Participation in mobile messaging is optional and not a condition of purchase. By providing your mobile number and opting in to receive these communications, you are consenting to receive autodialed or prerecorded marketing mobile messages at the phone number associated with your opt-in. The frequency and number of messages you will receive will vary. While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of our mobile messages are sent using an automatic telephone dialing system ( “ATDS” or “autodialer”). When you opt-in to the service as noted above, we will send you an SMS message to confirm your signup. Text Messaging Opt-Out: You can cancel the SMS service at any time. Just text “STOP”. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. In some cases, you may continue to receive service-related notifications. If at any time you need assistance, just text “HELP”. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

4. Information sharing and disclosure.

Panso shares your personal information to other companies or people to operate our business, including under the following circumstances:

1. between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
2. to Panso’s authorized partners and licensors to operate our business;
3. to our Customers when your information is related to the Services we provide to such Customers;
4. to third parties who perform services on our behalf, including without limitation our technology providers, independent contractors, support providers, and professional advisors;
5. when we have your consent to share the information;
6. to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization or other sale or transfer of some or all of Panso’s assets;
7. if we want to keep you up to date on the latest product announcements, software updates, special offers or other information we think you would like to hear about (unless you have opted out of these types of communications);
8. to our job hosting provider(s), if any, when you apply for a position at Panso;
9. to apply or enforce our Terms of Use and other agreements, including for billing and collection purposes;
10. as needed with the marketing and sales tools we use; and
11. as specified in our Terms of Use and any contract between us and you or your employer as necessary to carry out our contractual obligations.

Panso reserves the right to disclose your personal information if required to do so by law, court order or legal process, including to respond to any government or regulatory request or in the good-faith belief that such action is reasonably necessary to (a) comply with legal process, (b) respond to any claims against Panso, or (c) to protect the rights, property or personal safety of Panso, its employees, its customers or the public – this includes exchanging information with companies and organizations for the purposes of fraud detection and credit risk reduction.

We have relationships with third parties, and we may provide them some personal information such as your name and email so that they may contact you about products or promotions you may be interested in.

If you opt-in to mobile messaging, we will use the mobile phone number you provide to transmit your mobile messages and respond to you, if necessary. This includes sharing information with platform providers, phone companies, and other third-party service providers who assist us in the delivery of mobile messages. As with all information collected by Panso, we reserve the right at all times, to the extent permitted by law, to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.

5. Choices About Our Communications With You.

We are excited about our Services and would like to tell you about updates and new features from time to time. In case you prefer not to receive such information from us or from third party partners we work with, we strive to give you choices regarding whether or not you are contacted with direct marketing or market research information from us. If you have provided personal information to Panso, we will provide you with an opportunity to limit promotional email communications from Panso by “opting-out” of receiving direct marketing or market research information. When applicable, we will provide you with the opportunity to “opt-in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted.

Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information.

6. Data Security and Retention.

We have implemented industry-standard safeguards designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or in our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk.

We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. We will retain personal information required to comply with privacy requests, to manage active accounts, as required by law, in order to resolve disputes, or to enforce our agreements. We will retain the personal information we process on behalf of our users as directed by them. We may also retain copies of your personal information for disaster recovery purposes, to prevent fraud or future abuse, or for our legitimate business purposes.

Notwithstanding the generality of the foregoing, we store email addresses and mobile numbers for marketing purposes until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

7. Your Rights, Choices and Disclosures.

We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction and to which we are subject. Such rights generally include the right to know what information we process, the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal information, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request. We will do our best to honor your requests subject to any legal and contractual obligations, or if we believe the change would violate any law or regulatory requirement, cause the information to be incorrect or impose an undue hardship on us due to technical requirements.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 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.

If you would like to make a request, contact us at hello@hellopanso.com

California’s “Shine the Light” law. Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email tohello@hellopanso.com with “California Shine The Light Rights” in the subject line.

California Do Not Track Disclosures. We do not respond to Do Not Track browser signals.

8. Users Outside the United States.

Panso is a provider of services in the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. By visiting our website or using our Services, you are consenting to the transfer of your information from your jurisdiction to the United States.

9. Privacy Policy Changes.

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of our website or Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal information to us. If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on our home page. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

10. Contact Information.

If you have any questions or comments about this notice, please do not hesitate to contact us at hello@hellopanso.com