ÁñÁ«ÉçÇøapp

California Privacy Notice

Effective as of: March 5, 2026

This California Privacy Notice (“Notice”) is for to “Consumers” pursuant to the California Consumer Privacy Act (“CCPA”) and supplements the company Privacy Policy regarding its practices in California.

This Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding the Effective Date. This Notice also covers rights California Consumers have under the CCPA, as well as other legal notices for Californians.

Terms defined in the CCPA used in this Notice have the same meaning as in the CCPA.

1. PI We Collect

Within the past 12 months, we have collected the following types of PI about California Consumers. This notice will be updated annually.

Category of PI	Examples of PI
1. Identifiers	This may include but is not limited to: contact information (e.g., address, city, state, province/territory, ZIP code, email address and telephone number), account credentials, online identifiers, IP address, device identifier, alias/account name, and in limited circumstances, state ID number, business tax ID, and other identifiers for professional use.
2. Personal Records under Cal. Civil Code § 1798.80(e)	This may include information such as: identifiers described above, date of birth, payment information or other financial account information, and other personal, financial, and consumer complaint information.
3. Characteristics of Protected Classifications	This may include but is not limited to demographic information such as gender, sex, race, or age.
4. Commercial Information	This may include but is not limited to: customer account details, products or services purchased or considered, service history, other purchasing histories, and transaction records.
5. Internet and other Electronic Network Activity Information	This may include but is not limited to: information about your use of our sites or services, websites that referred you to us, information regarding your interaction with our sites and apps and advertisements displayed on our or third-party sites and apps, and data regarding network connected hardware, browsing activity, IP address, and device identifiers. Cookie categories are those that are necessary, your preferences, statistical, and for marketing.
6. Geolocation Data	This may include but is not limited to: physical location or device location. Device GPS location data is not collected.
7. Audio, Visual, or other Sensory Data	This may include but is not limited to: customer-submitted photographs, videos, and audio. As permitted by law, we may also record calls to our customer service and product support lines.
8. Professional or Employment-related Information	This may include but is not limited to: information from resumes or cover letters, third-party employment status, employment history, education, background screening information, and professional licenses.
9. Inferences from PI Collected	Except for sensitive personal information, inferences may be drawn from any of the categories of information listed in this section, and from any other information we process, and may include: consumer preferences, trends, characteristics, predispositions, and behavior, including in connection with profiles created about consumers.
10. Sensitive PI	This may include account login credentials, as described above. Some aspects of protected classifications listed above may be sensitive personal information. If you provide sensitive personal information when communicating with us, such as when calling our support lines, it may be collected. If you apply for a position through our website, we may also collect government-issued IDs, and information you choose to provide about protected classifications.

A. Sources of PI.

We may collect your PI directly from you or your device, or from service providers, vendors and suppliers, our affiliates, or other individuals and businesses as well as public data sources further described in the “Information Collected” Section above. Web-based sources include information from organic web searches and advertisements.

B. Use of PI.

We may collect and use the PI we collect for one or more of the following business purposes:

• Processing and Managing Interactions and Transactions
• Performing Services
• Quality & Safety Assurance, Verification, Maintenance, Debugging, Improvement, or Enhancement
• Security & Integrity, including protecting against security incidents and fraudulent, malicious, illegal, or wrongful conduct
• Conducting market research to assess advertisement effectiveness
• Sending marketing-related communications with information about our products and services
• Enabling our service providers and business partners (and their service providers and/or subcontractors) to provide services to us

2. Sharing of PI

We have disclosed PI in all or substantially all the categories identified in this Notice for the business purposes listed in this Notice and our general Privacy Policy. For more information about the categories of entities with which we have disclosed this information, see the section of our general Privacy Policy titled “Sharing Personal Information.”

Charm does not sell personal information for money. Through our website, we may disclose the following categories of personal information in a way that could be deemed a “sale” or “sharing” of data for cross-context behavioral advertising under California law to third parties including advertising companies and social networks: certain identifiers, cookies, commercial information, professional information, internet & other electronic network activity information, and inferences. We do not “sell” personal information of individuals we know to be under the age of 16 or share the personal information of individuals we know to be under the age of 16 for cross-context-behavioral advertising.

3. California Privacy Rights

We provide California Consumers with the privacy rights described in this section. You may exercise these rights directly or by an authorized agent who meets the agency requirements of the CCPA. Any request you submit is subject to verification. To verify your request, you must provide your name, email, and state of residence, along with any other information we may require to verify your identity or your request. We may not fulfill your CCPA request unless you have provided sufficient information for us to appropriately verify you and your request.

You are not required to create an account with us to make a Verifiable Consumer Request. We will typically not charge a fee to respond to requests; however, we may charge a fee if permitted under applicable law. The California Consumer privacy rights outlined in this Notice, and our obligation to fulfill requests to exercise them, may be subject to legal limitations and exceptions. To make a request, contact us using the “Contact us” information in this policy.

Your California Consumer privacy rights are:

A. The Right to Know and Have Access to Data

You have the right to obtain a copy of the specific PI that we have collected about you.

B. Right to Delete

You may request that we delete the PI that we have collected from you. However, applicable law may permit or require us to retain PI collected to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, complying with law, exercising or defending legal claims, and cooperating with law enforcement. If you have requested a service that requires the use of your PI, we may not be able to provide that service if you choose to delete your PI.

C. Right to Correct

You may request that we correct inaccurate PI that we maintain about you.

D. Right to Opt Out of Sale or Sharing

You may opt out of “sales” or “sharing” of PI (as defined under applicable law) using the link at the bottom of our web pages to by clicking “Deny” on the initial cookie banner or changing your settings using the icon on the bottom left. Note, this preference works only if your browser accepts cookies. If you clear cookies your preference will be erased, and you’ll need to reset it.

E. No Right to Limit.

Charm does not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer consumers a “Right to Limit” the use or disclosure of sensitive personal information. California law provides California residents with the right to limit the use or disclosure of Sensitive Personal Information for the purpose of inferring characteristics about an individual; however Charm does not collect, use, or disclose such information for such purposes.

F. Non-Discrimination

As required by the CCPA, we will not discriminate against you because you exercise your CCPA rights.

G. Authorized Agents

As permitted by the CCPA, any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury.

4. Retention

We keep your information depending on the duration of our ongoing relationship with you, the length of time needed to carry out the purposes outlined in this Notice, and as required to adhere to law or our policies on keeping records. We retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, and to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this Notice.

5. Contact us

ÁñÁ«ÉçÇøapp, Inc. (Headquarters)
659 Andover Street
Lawrence, MA 01843-1032 USA
1.978.687.9200
Toll Free: 800.343.2170

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ÁñÁ«ÉçÇøapp, Inc. Privacy Policy

ÁñÁ«ÉçÇøapp, Inc. is committed to protecting your privacy and providing you with a positive experience while using our websites, products, and services.

Charm may, at any time, modify this Privacy Policy. If we revise the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. If we make material changes to our Privacy Policy, we will also notify you via email as well as by posting a notice on our website. You should review this Privacy Policy periodically to keep up to date on our most current policies and practices. The effective date is at the end of this Privacy Policy.

1. Scope

This Privacy Policy provides you with guidance on your rights and obligations in relation to your personal information. Privacy rights and obligations may differ in certain locations based on local law, in which case Charm will comply with the local legal requirements. If a notice conflicts with this Privacy Policy, the specific notice or supplemental privacy statement controls.

2. Collection of Personal Information

“Personal information” is any information that can be used to identify an individual and includes categories depending on the business context such as your name, physical address, email address, phone number, login information, marketing preferences, company affiliation, or geographic location and Information about the user and use of our website, including device identifiers and telemetry (such as IP or MAC address) when such data is linked or tied to an individual’s device. Charm may collect personal information that is necessary for legitimate business purposes, which is disclosed to you at the time of collection. Charm will only use this information for the purposes for which it was collected. Charm may also collect personal information from legally compliant third-party sources and engage third parties to collect personal information to assist us.

One of the most common methods of collecting personal information is during the online form submission or registration process, including where a website user is requesting some information, a courtesy newsletter, registration for an event, or responding to similar offers or further product information.

Charm and the third parties we engage may automatically collect and aggregate data using cookies, weblogs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of our content delivery services and to help us tailor content or offers for you. Please read the “Cookies” section below for more information.

3. Purpose and Use of Personal Information

Charm may use your personal information for operational, legal, administrative, and other legitimate purposes permitted by applicable law. Charm has not and does not sell personal information. Some of the ways we may use personal information include:

• Providing you with requested products or services.
• Providing you with information regarding our products or services.
• Analyzing and monitoring extent of website use.
• Analyzing and monitoring whether website visits result from clicks on advertisements, search engine results, or by referral link.
• Providing customized product and service information.
• Allowing users to participate voluntarily in mailings or other events.
• Providing product service updates, information, and alerts.
• Sending communications, including for marketing or other customer satisfaction purposes.
• Order processing, and to provide transaction documents.
• To contact users for information verification purposes.

4. Right to Access, Correct and Delete Personal Information

You may access your personal information to the extent required by law to review, update, correct inaccuracies and, delete such personal information, pursuant to applicable regulations. On request, we will provide you with reasonable access to the personal information we collect about you. Because personal information, for example, your email address is required to communicate with you, we retain personal information if your account is active. You will have the opportunity to correct, transfer, update, modify, or delete this information. You may also limit the use and disclosure of your information by either unsubscribing from marketing communications or contacting us at the address listed below or by emailing info@charm.com. Some information may remain in our records even after you request deletion, to the extent permitted by the EU General Data Protection Regulation 2016/679 and other applicable laws. Additionally, there may be limits to the amount of information we can practically provide. We may limit access to personal information where the burden or expense of providing access would be disproportionate to the risks to an individual’s privacy or if it would violate others’ rights. Charm does not discriminate based on a user’s exercise of privacy rights.

5. Sharing Personal Information

Charm may disclose personal information to its subsidiaries, vendors, and affiliates.

Charm may disclose your personal information without providing you with a choice in order to honor a request that you have made through the products or services; comply with the law or in response to a court order, government request, or other legal process; protect the interests, rights, safety, or property of Charm or others; protect against fraud or for risk management purposes; or respond to adverse third parties in the context of litigation. In addition, if Charm sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Charm may transfer your personal information to a third party as part of that transaction.

Charm requires all unaffiliated third parties to treat personal information as confidential. Charm will not provide personal information to third parties for their own marketing purposes without your consent.

If you participate in a discussion forum, chat room, or provide comments related to Charm on a social media or other public platform, the information you provide there will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither Charm nor you have control over. Charm may offer you the ability to share personal information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). These tools enable you to share personal information with other individuals or the public, depending on your settings. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s tools, please visit the privacy policies of the entities that provide these sites. Charm is not responsible for any information you choose to submit on these forums or sites that are not Charm-controlled.

6. Security of Personal Information

Charm has physical, administrative, and technical safeguards to help protect the personal information it collects. Charm will take reasonable and appropriate steps to ensure safety of your personal information in compliance with applicable regulations.

7. Retention of Personal Information

Charm will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

8. Cookies

When visiting the Charm website, our servers may query your computer to see if there are cookies previously set by Charm. A cookie is a text file that is created when your browser visits a website. Afterwards, every time you visit the Charm website, your browser retrieves and sends this file to the Charm website’s server. Cookies enhance the website user experience by:

• Helping Charm authenticate you as a user when you log in to a secure area
• Storing information about your website user activities so you may easily pick up where you left off
• Storing your user preferences, which allows you to customize how information is presented through site layouts or themes
• Personalizing the manner Charm responds to you via marketing communications

The cookies Charm collects may include the following information: a unique identifier, user preferences, and profile information used to personalize the content shown to the individual users. You will be informed about our use of cookies when you visit the Charm website. It is your choice whether you allow Charm to store such information on your device. You may be able to set your web browser to alert you when a cookie is used, and may use your browser to accept or reject the cookie; additionally, you may disable the cookie feature on your browser entirely. However, disabling cookies may prevent you from using some features on Charm websites. You can find more detailed information about cookies at aboutcookies.org.

We may collect and share the physical location of your device with your consent for purposes consistent with this Privacy Policy, such as to comply with applicable laws and provide you with personalized location-based products or services. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized products or services.

Some web browsers and devices permit you to broadcast a preference that you are not “tracked” online. At this time, Charm does not modify your experience based upon whether such a signal is broadcast.

9. Cross Border Transfer of Personal Information

Charm is a global organization, we may transfer your personal information to a subsidiary or affiliate, or to third parties as described above in various countries. By using our websites or products, or providing any personal information to us, where applicable law permits, you consent to the transfer, processing, and storage or such information outside of your country of residence where data protection standards may be different.

If you have any complaints regarding our compliance with this Privacy Policy, you should first contact us at the address listed below or by emailing privacy@charm.com. We will investigate and attempt to resolve complaints and disputes regarding collection, use, and disclosure of personal information in accordance with this Privacy Policy.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local supervisory authority. Under certain conditions you may invoke binding arbitration when other dispute resolution procedures are exhausted.

10. Prospective Employee and Employee Information

If you apply for employment to or are currently an employee of Charm, Charm is authorized to collect the information it obtains through your application for employment or continued employment with Charm, and your submission of employee related documents, including the personal information that you submit in connection with your employment or intended employment (collectively “Employee Information”). Examples of Employee Information collected include your name, date of birth, government issued identification (passport, social security number, driver’s license number), banking information, marital status, benefit information, title, employment history, education, job qualifications, and other relevant employee personal data. We also collect some of this information about your dependents when you provide it to us when you enroll in health and other benefits or provide contact information. Employee Information does not include any information that is available to the public and excludes generally available information.

Charm will collect, use, store and retain, and secure your social security or other identification numbers in accordance with this Privacy Policy. Charm will not intentionally communicate or make available, in any manner, your social security or other identification number to the public. Charm will not require you to transmit your social security or other identification number over the Internet, unless the connection is secure or the social security, or other identification number, is encrypted. Charm will not print your social security or other identification number on any materials that are mailed to you, unless state or federal law requires or permits the social security or other identification number to be on or in the document(s) to be mailed.

Charm may use Employee Information to evaluate applications for employment, manage your employment (i.e., training, payroll, benefits, travel, reimbursement expenses, performance appraisals, succession planning, team member safety), investigate and respond to any claims related to your employment, and comply with applicable laws. Your Employee Information will not be used for marketing purposes by us or any third party, unless you specifically consent to such use.

Charm shares your Employee Information with vendors who provide human resource functions to us. Those third parties are required to protect your Employee Information. Charm may disclose your Employee Information if required or permitted to do so by law (e.g. governmental action or litigation), or to relevant third parties such as site technicians, brokers, auditors, lawyers, or professional advisors. If Charm or substantially all its assets are acquired Employee Information may be part of the transferred assets.

Employee Information may be stored in hard copy or electronic format within company offices or in the cloud in the United States or other countries where Charm, its affiliates, agents, or contractors conduct business. Your Employee Information may be transferred into our human resources systems and used to manage your employment, may become part of your personnel file, and may be used for other work-related purposes. Your Employee Information will be kept for as long as legally required.

If you have any complaints regarding our compliance with this Privacy Policy, you may email privacy@charm.com.

11. EU General Data Protection Regulation

The Charm Privacy Policy addresses our commitment to the processing of personal data in accordance with the EU General Data Protection Regulation 2016/679.

12. Other Contractual Relationships

If you enter into a separate contract with Charm which requires, or contemplates, collecting, using, or sharing information about you in a manner that is different than described in this Privacy Policy, the terms of that agreement apply.

13. Other Websites

This Privacy Policy does not apply to sites or applications offered by other companies or individuals, including third-party products and services, that may be displayed as content in a search on our website. Charm encourages you to read the privacy policy of any third-party before transmitting personal information.

14. Contact Information

If you have any questions or concerns related to this Privacy Policy, please contact Charm, by email, letter, or by toll-free call at:

privacy@charm.com

ÁñÁ«ÉçÇøapp, Inc.
659 Andover Street
Lawrence, MA 01843-1032 USA
Toll Free: 800.343.2170

If Charm needs, or is required, to contact you concerning any event involving your information, we may by email, telephone, or mail.