Privacy Policy

1. Collection and Use of Personal Information

When you visit our Services, we may automatically collect certain information. Examples may include your internet protocol ("IP") address, your browser type, operating system, and information about how you interact with the Services, such as pages viewed and links clicked.

Depending on how you interact with the Services, you may choose to provide certain Personal Information to us, or we may collect information automatically in connection with your use of the Services. The categories of Personal Information we collect, and how we use that information, are described below:

• Account Information. If you choose to create an account with Chirp or request more information about one of the Chirp Creators, you may provide certain information to us voluntarily. We collect and maintain the information that you provide to us in connection with the account registration process to manage your account and communicate with you. Personal Information that is collected may include your name, email, phone number, address, alternative contact information, and any other Personal Information you may provide to us.
• Account Access. We collect and maintain your login information when you access your account to help us manage your account.
• Cookies. Our Services use "cookies" and similar technologies, some of which may be placed by us, and others that may be placed by third parties, including Creators, and integrations used by Creators. For more information about how we use cookies and other trackers, please review our Cookie Policy.
• Information Submitted Through Forms and Communications: If you provide your Personal Information through any fillable form or other channel on the Website or our Services for communication purposes, you are authorizing our use and sharing of your Personal Information as described in this Policy and any subsequent revisions to this Policy. We will retain and use your information only as necessary to respond to your communications and to comply with our legal obligations, to resolve disputes, for archival purposes, and to enforce our agreements or other legal rights.
• Information Provided for Newsletters and Similar Communications: If you choose to provide your contact information through the Website or Services to sign up for newsletters, updates, or similar communications, we may use that information to deliver the requested communications and, where permitted by law and subject to applicable consent or opt-out choices, for audience measurement, analytics, advertising, and monetization purposes. This may include using contact information (such as email addresses or phone numbers) to create audience segments or to perform matching activities using privacy-preserving techniques, including hashing and secure data environments. As described in Section 2 of this Policy, such information may be shared with third parties for these purposes, consistent with this Policy and applicable laws.

Importantly, we do not intentionally collect any sensitive information, such as social security numbers, biometric data, or financial data.

Chirp may use the Personal Information it collects for a variety of legitimate reasons. In general, we use the information we collect to enable you to access and use the Services, and otherwise to provide, maintain, and improve the Services. More specifically, we may use the information we collect to:

• Collect information for troubleshooting, diagnostics, and debugging;
• Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
• Communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you, which may be provided by any means, including by e-mail, push notifications and display advertising;
• Administer surveys and conduct user research;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Evaluate and develop new features and improvements to the Services;
• Comply with applicable laws, lawful requests and legal processes, including responding to court orders or requests from regulatory authorities; and
• Detect, investigate and prevent fraudulent transactions and other illegal activities, enhance our security practices, enforce our agreements with Users (including our Terms) and protect the rights and property of ourselves and others.

Although we may use automated algorithms, we do not use such technologies for automated decision-making that has legal or similarly significant effects on you. We may use artificial intelligence, large language models, or machine learning technologies for purposes including providing customer assistance, analyzing, developing, and improving our Services, and for marketing purposes.

2. How We Share Information With Others, and To Whom It Is Shared

This section describes the circumstances in which we may share Personal Information and the categories of recipients with whom it may be shared.

The Personal Information Chirp collects from you is shared only as described in this Policy, including with Creators; Chirp Advertising Partners; through our use of cookies and similar technologies; and with other third parties for the purposes outlined below.

When you choose to interact with, subscribe to, or request information from a Creator hosted on Chirp, Chirp may share certain Personal Information you provide—such as your name, email address, or other contact details—with the relevant Creator for the purpose of enabling the Creator to communicate with you, fulfill your request, or manage their relationship with you.

Creators process your Personal Information independently of us, and in accordance with their own privacy practices. If you subscribe to a Creator, you consent to allow them to reach out to you directly for marketing purposes using their own third-party tools and integrations. Chirp does not control, and is not responsible for, how Creators use Personal Information once shared, or for how Creators use their own tools, platforms, or service providers to contact you.

We may also disclose your information to outside companies that help bring you the Services we offer. For example, we a may work with outside companies to: (a) manage a database of User information; (b) assist in distributing emails; (c) assist with data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) process payments; and/or (h) provide other services designed to assist us in maximizing our business potential and maintaining the Services. We require outside companies keep confidential all information we share with them and to use the information only to perform their obligations to us.

Where permitted by law and subject to applicable consent or opt-out choices, Chirp may share limited Personal Information with selected advertising, analytics, or monetization partners to support audience measurement, creator monetization, and brand discovery. Where appropriate, feasible, and consistent with industry standards, these data collaborations will endeavor to use privacy-preserving technologies — such as hashing and secure data environments (often described as "clean rooms") — to help prevent the disclosure of raw Personal Information or re-identification of individuals. Chirp and these partners act as independent data controllers with respect to their respective processing activities. You may opt-out of this sharing by visiting our Privacy Request Center.

Chirp and its partners use cookies, pixels, SDKs, and similar tracking technologies to operate, analyze, and improve the Services, to personalize content, and to support advertising and measurement activities. These technologies may collect information such as device identifiers, browser information, IP address, and information about your interactions with the Services.

Where required by applicable law, Chirp uses a consent management platform to present a cookie banner that allows you to accept, reject, or manage the use of cookies and similar technologies. You may update your preferences or withdraw your consent at any time through the Your Privacy Choices link on the footer of the Website.

Other than for the legitimate business purposes described in this Policy, including advertising, analytics, and monetization activities carried out in accordance with applicable law, we do not share your Personal Information with third parties for their independent use unless:

• you request or authorize it;
• we go through a business transition, such as a merger, divestiture, acquisition by another company, restructuring, reorganization, bankruptcy, dissolution, or sale of all or a portion of our assets;
• the information is provided to comply with the law (for example, to comply with legal process, a judicial proceeding, a search warrant, subpoena, court order);
• we need to enforce an agreement we have with you or address another legal dispute or claim where the information is relevant;
• we believe it is important to protect our rights, property, or safety, or the rights, property, or safety of our employees or others;
• we need to address emergencies or acts of God; or to address legal disputes or claims, including with persons demonstrating legal authority to act on your behalf.

Separate from Personal Information, we may compile non-personal information and aggregated data about our Users and disclose the results of such aggregated information to our partners, Service Providers (listed below in Paragraph 14), advertisers, and/or other third parties for legitimate business purposes, including to maintain and improve our Services and to provide Linked Sites (as defined in our Terms).

3. Your Information is Processed in the United States

Chirp is located in the United States. Any information we collect from you through the Services will be processed in the United States.

4. How Long We Keep Your Personal Information

We will store Personal Information we collect about you for only as long as necessary to fulfill the purposes set forth in this Policy. For Personal Information that you update yourself, we keep the information as long as you choose to keep your Personal Information on our Services, or until your account is deleted.

While retention requirements vary by country, the duration of time we maintain your information may differ depending on the basis of how the Personal Information needs to be used. This includes considerations such as the amount and nature of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, when the information was collected or created, whether it is necessary in order to continue offering you our Services or to protect the safety, security and integrity of our Services, and whether we are required to hold the information to comply with our legal obligations.

5. We Use Commercially Reasonable Efforts to Secure and Store Your Information

We use commercially reasonable efforts to secure your Personal Information, but we cannot and do not assure that these measures will be sufficient to protect against all efforts to gain unauthorized access to the information.

We have implemented technical, administrative, and physical security measures to protect information from unauthorized access and improper use. We keep information on servers that are protected by firewalls and located in a physically secure facility accessible only to authorized employees of the Company and the Related Entities. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though, that, despite our reasonable efforts, no security measures are impenetrable and any information transmitted to us or through the Site will be at your own risk.

To help us protect your account, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts. We encourage you to keep your phone, computer, or any device you use to access the Services updated to the latest version for security purposes.

6. Children's Privacy

Although content on our Website may be accessible to a general audience, the Services are not intended for anyone under 16 years of age. We do not knowingly collect personal information from anyone under 16, and individuals under 16 may not provide personal information through the Services. If you are under 16, do not use the Services or submit any information to us. In certain circumstances, and if required by law or our internal policies, we may apply additional safeguards to limit the risk of collecting data that may relate to individuals under 16 years of age.

If we learn we have collected or received personal information from a anyone under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about an individual under 16, please contact us immediately.

7. Third Party Services and Linked Sites

The Services, including Creator Pages contain links to many third-party websites, offers, or other events and promotions that are shared by Creators and advertisers, and are not owned or controlled by us (defined in our Terms of Service as "Linked Sites"). Chirp may also include links to third-party payment processors that handle Chirp Creator payments.

We are not liable for any information, content, products, services, software, or other materials available on or through a Linked Site. The use of an external website or any information or other content found on external websites is subject to and governed by the terms and conditions of that website. We encourage you to review the privacy notices posted on the Linked Sites.

If Creators m link to or use third-party websites, tools, or services through their Creator Pages, any Personal Information collected through such third-party services is governed by the privacy practices of those third parties, not by Chirp. Creators are responsible for ensuring that their use of third-party technologies complies with applicable law and Chirp's policies.

Our Services do not track users across third-party websites. While there is no single industry standard for recognizing Do Not Track (DNT) signals, we honor such signals where required by applicable law.

8. Closing Your Account

If you have an account with Chirp, you may close it at any time, either through the deletion process in your account settings in the Services or by contacting our customer support team. When you close your account, you will lose access to it and all the content in it. After you close your account, we may retain certain information if applicable laws or regulations require us to do so, or if it is necessary to protect our legal rights.

9. European Economic Area (EEA) and United Kingdom (UK) Rights

If you are physically located in the EEA or the UK, you can learn about your personal data rights in this section.

Controller: For purposes of the General Data Protection Regulation ("GDPR") and any subsequent revisions or modifications, Chirp is the data controller. We are a private company located in the United States, and you can contact us with any privacy concerns at [email protected].

Legal Bases: We only use, share, or collect your personal data (as defined in the GDPR) based on any of the legitimate legal bases:

• Fulfill Service Obligations: We need your personal data to provide a service you request or fulfill a contractual responsibility we have to you. In most cases, this refers to when we make our Services available to you in accordance with our Terms of Use.
• Legitimate Interest: We have a legitimate interest to use your personal data in ways that you would expect such as to properly run our Services, improve the Services for you, advertise our Services, and protect our legal rights.
• Consent: We have your consent to use your personal data for a specific purpose presented to you before we collect it. You can withdraw any consent you give through options provided via the Services or by contacting our privacy team at [email protected].

Personal Data Rights: You have certain rights related to your personal data which are listed below:

• Access: You have the right to ask for information about the personal data we hold, how it's used, and with whom we share it;
• Portability: Where you provide us with personal data based on consent and it is reasonable for us to do so, you can ask us for a copy of it in a structured, machine-readable format and ask us to send this data to another data controller;
• Correction: You can ask us to correct any personal data that is out of date or inaccurate;
• Erase: In certain circumstances, you can ask us to delete your personal data that we store;
• Object: If we process your personal data based on a legitimate interest, you can object to our legitimate interest. We will honor the request except when we have an overriding interest.
• Restrict: You can ask us to stop or limit how we process your data while we respond to one of your requests.
• Withdraw Consent: If you provide us with personal data based on consent, you can withdraw your consent at any time. We will consider your request and respond within a reasonable time period as required by applicable law.

Not all personal data is covered by the above rights, but we will always provide you with a response to your request. Chirp will try to respond to requests as quickly as possible, but some responses may take longer. If that is the case, we will let you know if we need more time. At times, we may require more information to confirm your identity before processing your request, or in cases where your request is unfounded, repetitive, or excessive, we may deny your request or charge a reasonable fee.

If you wish to make a complaint about how we process your personal data, please contact us at [email protected]. We take all complaints seriously and aim to resolve them with respect. Although we believe we can address most complaints with you directly, you may also choose to file a complaint with the relevant data protection authority.

10. California and Other State Privacy Rights

Certain U.S. state laws, including but not limited to the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, provide residents with specific rights regarding their Personal Information. Depending on the state, some of these rights may include:

• Access Rights: You have the right to request that we disclose the categories and pieces of Personal Information we collect, use, disclose, and sell, as well as the business purposes for collecting your information.
• Deletion Request Rights: Under certain circumstances, you have the right to request that Chirp delete any of your Personal Information that we collected from you and retained over the preceding 12 months.
• Opt Out Rights: Because we may use advertising and analytics for targeted advertising purposes, you may have the right to direct us not to "sell" or "share" your Personal Information at any time (the "right to opt-out").
• Requests to Correct: You may have the right to request that we use commercially reasonable measures to correct any inaccurate information that we have about you.
• Requests to Limit Use of Personal Information: Under certain state laws, you may direct us to only use your sensitive Personal Information (if applicable) for only those purposes that are necessary to perform our Services.
• The Right Against Discrimination: We will not discriminate against you for exercising your privacy rights, consistent with various state laws.

Before granting any request, we are required to evaluate whether the applicable request is provided for under the state laws, as some rights may apply only to residents of certain states. In addition, only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. As such, we cannot grant a request until we are able to identify which Personal Information is associated with you, as well as your state residency. The type of information you must provide depends on the type of request you make.

Alternatively, we may use a third-party verification service to verify your identity. 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. You may only make a verifiable consumer request for Access twice within a 12-month period. If you believe you have a valid right to request any of the rights above, please reach out to us. To exercise the privacy rights to Access, Delete, Correct, and Limit Personal Information as described above, or to exercise your opt-out rights, please visit our Privacy Request Center. We try to respond to all confirmed consumer requests within 45 days of receiving them, or as otherwise permissible under the applicable law. If we need more time, we will reach out to explain why.

11. Appeal Rights

Certain states may allow residents to appeal a denial of a privacy-related request. If we decline to process your request, you may have a right to appeal by emailing [email protected]. We may reject your request for appeal if the state in which you reside does not allow a right to appeal.

12. Privacy Policy Updates

We may revise or update this Policy from time to time. If we make significant changes to how we handle Personal Information, we will post changes to the Policy on our site and change the date on the top of this page. Your use of our Services following the posting of changes on our website shall constitute your consent to the changes. If material changes are made, we will provide additional notice in advance (e.g., a disclaimer on our website).

13. SMS and Email Messaging Consent and Opt Outs

When you provide us with your email address or mobile ("SMS") number upon creating an account with Chirp or by otherwise sharing this information with us through our Services, you are opting in to allow us to send you communications for the purposes of responding to user requests, to address or notify you about account updates, to provide updates about the Services, and for other marketing and advertising purposes including to share special offers only available to Chirp account holders.

You can choose to opt out of email or SMS communications at any time by clicking the unsubscribe or opt-out link in our marketing emails or responding "Stop" to any SMS messages.

For more details on our messaging policies, please review our Chirp Mobile Terms of Service.

14. Contact Us

If you have questions about our privacy practices, email us at [email protected]. If you want to contact us for any other reason unrelated to our privacy practices, you can send an email to [email protected].

15. Service Providers and Advertising Partners

Before engaging with any Service Provider, we carefully review their data protection measures to ensure that your Personal Information is protected in accordance with applicable laws. A list of our current service providers is as follows:

• Braze
• Facebook
• Google
• Instagram
• Membrana Media
• Pexels
• Supabase
• Spotify
• Tipalti
• TikTok
• X
• YouTube. Chirp uses YouTube's API Services for music and video link functions to allow the display of Youtube videos on Chirp pages. By using our Services, you also agree to the YouTube Terms of Service and Google's Privacy Policy. In addition to our normal procedure for deleting stored data, users can revoke access to their data as it relates to the YouTube API by visiting the Google security settings page.
• Zoho

Chirp also works with third-party advertising partners ("Advertising Partners"), including Advolution Inc., to support advertising, audience measurement, attribution, and related activities on certain Chirp Creator Pages.

Advertising Partners are not Service Providers and do not process Personal Information on Chirp's behalf. Instead, they process Personal Information as independent controllers in accordance with their own privacy policies. While Chirp uses commercially reasonable efforts to select Advertising Partners that maintain appropriate privacy and security practices, Chirp does not control their privacy practices. You can opt-out of our sharing of personal information with Advertising Partners through our Privacy Request Center.