Privacy Policy

This Privacy Policy describes how Kempt Labs Co. ("Kempt", "we", "us" or "our") processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy, as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the "Service").

PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us includes:

• Contact data, such as your first and last name, salutation, email address, address, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, gender, and age.
• Profile data, such as account name, the username and password that you may set to establish an account on the Service, the inspection report(s) that you upload to the Service, and any other information that you add to the Service.
• User-generated content, such as photos, images, videos, and other content or information that you generate, transmit (including through inputs, prompts and connected data sources), or otherwise make available on the Service, as well as associated metadata (e.g., how, when, where and by what/whom a piece of content was collected and how that content has been formatted or edited).
• Transactional/subscription data, such as information relating to or needed to complete your subscriptions, bookings, or orders on or through the Service, including order numbers, contractor work order details, and transaction history.
• Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information, as described further below.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
• Call/video recordings, such as recordings of customer support calls.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Location data, which may include your precise location when you use certain features of the Service.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about you we get from others. We may receive personal information about you from our users (e.g., we might get your name and email address from your spouse, housemate, or another user who thinks you would enjoy the Service) or someone who gifts you the Service (such as your real estate agent). Please do not refer someone to us or share their information with us unless you have their permission to do so.

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

• Contractors that you engage through the Service.
• Service integrations providers that you elect, including those offered via Plaid and Google Gmail.
• Public sources, such as public records, publicly accessible social media profiles, and other publicly available sources.
• Private sources, such as data providers (e.g., data licensors/brokers, lead generators and cooperative databases), social media platforms (e.g., where you choose to log-in to the Service through a social media platform) and data licensors.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Marketing Partners, such as joint marketing partners and ad networks.

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Location data, which will be approximate (for example, as inferred from network data or device settings) or precise (for example, if you use features to find contractors near you or otherwise if/when you authorize the Service to access your device's location).
• Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Tracking technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a web browser session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our service providers and other third parties place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.
• Chat technologies, such as those provided by third parties that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. These third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats to respond to your questions and for the purposes described in this Privacy Policy.
• Session replay technologies, such as those provided by third parties that employ software code to record users' interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users' clicks, mobile app touches, mouse movements and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to: provide and operate the Service (including to process your orders and transactions with us and third-party contractors you engage through the Service); establish and maintain your user profile on the Service; enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; provide support for the Service, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to: personalize your experience with the Service and our Service-related communications; and remember your selections and preferences as you navigate the Service.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business, develop new products and services.

Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes: Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Opt out of marketing section. Interest-based advertising. We and our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) with the Service, our communications and other third party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online properties. You can learn more about your choices for limiting interest-based advertising in the Your choices section.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to: comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities; protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, deidentified and/or anonymized data. We may create aggregated, deidentified and/or anonymized data from your personal information. We make personal information into deidentified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, deidentified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, commercial purposes, and promote our business.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see the 'How we share your personal information' section.

Further uses. In some cases, we may specifically ask for your consent to collect, use or share your personal information for further purposes not set out above, such as when required by law (e.g., if the law requires this where those further purposes are not compatible with the initial purpose for which that personal information was collected).

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such Stripe. Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/privacy.

Plaid. You may elect to use features that integrate with your bank account(s) and mortgage company, which are facilitated by Plaid. Plaid may use your information in accordance with its privacy policy, available at: https://plaid.com/legal/.

Google Gmail. You may elect to connect your Gmail account so that Kempt can find home-service invoices and receipts for you. Our access to, use of, and transfer of information received from Google APIs is governed by the "Google User Data and Limited Use" section below, which takes precedence over any more general statement in this Privacy Policy. Google may use your information in accordance with its privacy policy, available at: https://policies.google.com/privacy.

Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers to power certain features of the Service, such as reading an invoice you have chosen to import and turning it into a service record. These providers process the content only to return a result to you, under commercial terms that prohibit them from retaining it or using it to train their models. We do not permit any AI provider to train on Google user data, and we do not use Google user data to develop, improve, or train generalized or non-personalized AI or machine-learning models. To learn more about how these providers process information, please refer to their privacy policies.

Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above. This may include certain social networks where we use their ad services to display ads to our customers, or other people like them, on social media. We never share, sell, or transfer Google user data (including Gmail content and anything derived from it) to advertising platforms, data brokers, or information resellers, and we never use Google user data for advertising of any kind.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Kempt, financing of Kempt, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Kempt or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

GOOGLE USER DATA AND LIMITED USE

This section describes how Kempt accesses, uses, stores, and shares data obtained from Google APIs. Where this section conflicts with any other part of this Privacy Policy, this section controls.

Kempt's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

What we access. If, and only if, you choose to connect your Gmail account, Kempt requests read-only access to your Gmail messages (the gmail.readonly scope). We request read-only access because identifying a home-service invoice requires reading the content of the message and its attachments. Narrower scopes do not provide message content and therefore cannot support this feature.

Why we access it. We use this access for one purpose: to find invoices and receipts from home-service providers (for example, an HVAC repair or a roof inspection) and turn them into service records in your home's maintenance history. This feature is visible and prominent in the app, and you review and approve every record before it is saved.

How we use it. Google user data is used only to provide and improve this user-facing feature. We extract the details of a service record, such as the provider, date, amount, and category. We store those extracted service records, and any invoice you choose to save, in your account. We do not store a copy of your mailbox.

Processing by AI providers. To read an invoice and extract its details, message content may be sent to a third-party AI provider that acts as our service provider. This occurs only to deliver the result back to you, under commercial terms that prohibit the provider from retaining the content or using it to train its models. We do not use Google user data to develop, improve, or train generalized or non-personalized artificial intelligence or machine-learning models, and we do not permit our providers to do so.

What we never do. We do not sell Google user data. We do not transfer it to advertising platforms, data brokers, or information resellers. We do not use it for advertising, retargeting, or personalized ads. We do not use it to determine credit-worthiness or for lending purposes.

Human access. Kempt personnel do not read your email. The only exceptions are where you have given us affirmative permission to view a specific message in order to help you, where it is necessary for security purposes such as investigating abuse or a bug, where it is required to comply with applicable law, or where the data has been aggregated and de-identified for internal operations.

Your control. You can disconnect your Gmail account at any time in the app, and you can revoke Kempt's access directly from your Google Account at https://myaccount.google.com/permissions. On disconnection or account deletion, we delete the access tokens and, at your request, the data derived from your Gmail account.

YOUR CHOICES

Access or update your information. You may have the right to access and update personal information we hold about you.

Opt out of communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us using the contact details below. It may take time for your opt-out to be effective. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt out of text messages by texting "STOP" in response to a text that you receive or by other reasonable means.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Mobile location data. You can disable our access to your device's precise geolocation in your mobile device settings.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Advertising choices. You may be able to limit use of your personal information for interest-based advertising through the following settings/options/tools: Browser settings (changing your internet web browser settings to block third-party cookies); Privacy browsers/plug-ins (using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies); Platform settings (some platforms offer opt-out features that let you opt out of use of your personal information for interest-based advertising — you may be able to exercise that option for Google at https://adssettings.google.com/ and Meta at https://www.facebook.com/about/ads); Ad industry tools (opting out of interest-based ads from companies that participate in industry opt-out programs, including the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp, the Digital Advertising Alliance at https://optout.aboutads.info, and the AppChoices mobile app at https://www.youradchoices.com/appchoices); and Mobile settings (using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes). You will need to apply these advertising-related opt-out settings on each device and browser from which you wish to limit the use of your personal information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Shine the Light law opt-out. Under California's Shine the Light law (California Civil Code Section 1798.83), we give you the right to opt out of our disclosure of your personal information (as defined by this law) to third parties for their direct marketing purposes. You may send us requests to support@kemptco.com. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.

Retention period for personal information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject; whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it or deidentify it.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties, such as links to contractors available in your area for certain services. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

SECURITY

We employ technical and organizational safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information. Additionally, you should take care to keep your username and password private, as sharing that information could jeopardize the security of your digital or physical assets associated with the Service.

INTERNATIONAL DATA TRANSFER

We are headquartered in the U.S. and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

CHILDREN AND TEENS

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

CHANGES TO THIS PRIVACY POLICY

The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the "Last Updated" date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

HOW TO CONTACT US

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

Email: support@kemptco.com Website: www.kemptco.com Address: Kempt Labs Co. 1521 Blake St STE 19733, Denver CO 80202