Privacy Policy

Privacy Policy

Last Updated: Sept 8, 2026

Parley Technologies, Inc. (“Parley,” “we,” “us,” or “our“) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information when you visit www.parley.so, create or administer an account, subscribe to or use the Parley platform, contact us, or otherwise interact with a website, application, or service that links to this Privacy Policy (collectively, the “Services“).


1.- Scope and Our Role

This Privacy Policy applies when Parley processes personal information as a controller, including information about website visitors, prospective customers, account administrators, authorized users, billing contacts, and people who communicate with us.

The Services permit customers and their authorized users to upload, create, generate, and otherwise provide content that may contain personal information about clients, employees, counterparties, or other individuals (“Customer Content“). When Parley processes Customer Content solely on a customer’s behalf in providing the Services, Parley acts as that customer’s service provider or processor under the applicable customer agreement and Data Processing Addendum (or equivalent data-processing terms). The customer’s privacy notice and those data-processing terms govern that processing; this Privacy Policy does not apply to Customer Content processed solely on a customer’s behalf.

If you provide personal information directly to Parley—for example, to open or administer an account, subscribe to the Services, contact support, receive marketing communications, or use our public website—Parley processes that information as a controller as described in this Privacy Policy.

2.- Personal Information We Collect

We may collect the following categories of personal information:

·       Account and contact information, such as name, business email address, phone number, company or firm name, professional title, mailing address, username, account credentials, and account-administration information.

·       Subscription and transaction information, such as selected plan tier, free-trial enrollment, subscription status, billing contact details, invoices, payment status, purchase history, applicable tax information, and payment-processor identifiers. Our designated payment processors process payment-card and ACH information; Parley does not intentionally store full payment-card numbers.

·       Service and usage information, such as account settings, features used, Credit consumption and metering records, prompts and activity within the Services, support interactions, logs, and information about the devices and browsers used to access the Services.

·       Communications and feedback, such as inquiries, support requests, survey responses, messages exchanged with us, and feedback regarding the Services.

·       Marketing information, such as preferences for receiving marketing communications and engagement with those communications.

·       Device and online activity information, such as IP address, browser type, device type, operating system, approximate location derived from IP address, access times, pages viewed, and interactions with our website and communications.

·       Information from third parties, such as business contact information, public profile information, and information from referral, marketing, identity-verification, payment, and service providers, where permitted by law.

We may receive personal information contained in Customer Content. Where we process that Customer Content solely on a customer’s behalf, the customer—not Parley—is responsible for its privacy notice and for responding to requests concerning that Customer Content.

We do not require customers or authorized users to provide sensitive personal information to create or administer an account. Customer Content or communications that a customer or authorized user elects to provide may nonetheless contain sensitive personal information. We process it only as necessary to provide, secure, support, and comply with applicable obligations relating to the Services.

The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16.

3.- How We Use Personal Information

We use personal information to provide, operate, secure, maintain, and improve the Services; create and administer accounts; process subscriptions, purchases, and payments; provide customer support; communicate about accounts, billing, security, and service changes; measure and administer plan usage, including Credit consumption and applicable charges; personalize and improve the user experience; conduct research and development; develop and use aggregated or deidentified information; send marketing communications where permitted by law; protect against fraud, abuse, security incidents, and other harmful or unlawful activity; comply with legal obligations; enforce our agreements; and establish, exercise, or defend legal claims.

Where applicable law requires a legal basis, we process personal information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations.

4.- Artificial Intelligence and Automated Processing

The Services use artificial intelligence to assist users with legal-work workflows, including analyzing Customer Content, generating drafts and other work product, extracting information, populating or updating records, and executing automated workflows and agentic tasks. AI-generated output may be inaccurate, incomplete, or inappropriate for a particular purpose. A qualified human user must review AI-generated output before relying on or using it.

Parley does not use Customer Content to train, fine-tune, or otherwise develop AI models made available to other customers, except where the applicable customer expressly authorizes that use in a separate agreement. We may use account, service, and usage information, and aggregated or deidentified information, to operate, secure, support, and improve the Services as described in this Privacy Policy.

Parley does not make decisions that produce legal or similarly significant effects concerning individuals based solely on automated processing of personal information. If our practices change, we will provide any notice, choice, or rights required by applicable law.

5.- How We Disclose Personal Information

We may disclose personal information to:

·       Service providers and subprocessors that provide hosting, infrastructure, payment processing, customer support, analytics, security, communications, and other services for us;

·       Professional advisors, including lawyers, accountants, auditors, insurers, and financing sources;

·       Business partners, where you direct us to share information or where disclosure is otherwise consistent with your relationship with us;

·       Government authorities and other third parties, when we reasonably believe disclosure is required by law, legal process, or a governmental request, or is necessary to protect rights, safety, security, or property; and

·       Parties to a corporate transaction, such as a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets.

We may also use and disclose aggregated or deidentified information that does not reasonably identify an individual.

We disclose only the personal information reasonably necessary for a service provider or subprocessor to perform its services. We require service providers that process personal information on our behalf to process it only for authorized purposes and subject to appropriate confidentiality, security, and data-protection obligations.

Parley’s current material subprocessors are listed at www.trust.parley.so. They may process the categories of information identified in connection with the stated service function.

We may update this list as our Services evolve. If we add or replace a subprocessor that will access or process Customer Content, we will provide any advance notice, opportunity to object, or other process required by the applicable customer agreement or data-processing terms.

Google API Services and Workspace Data

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.

6.- Retention and Security

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. The applicable retention period depends on the nature of the information, the purpose of processing, the duration of the account or customer relationship, and applicable legal requirements.

We retain account-profile and account-administration information for the life of the account and thereafter only as necessary for security, fraud prevention, dispute resolution, legal compliance, or enforcement of our agreements. We retain subscription, invoice, payment-processor identifier, and tax information as required for billing, accounting, tax, chargeback, dispute, and legal-compliance purposes. We retain Credit-consumption and service-usage records as reasonably necessary to administer subscriptions, resolve billing questions, protect the Services, and improve service operations. We retain support communications and security logs for periods reasonably necessary for support, security, abuse prevention, incident response, and legal compliance.

Customer Content is retained and deleted in accordance with the applicable customer agreement and the Services’ account-deletion and download functionality. Under the current Terms of Service, a customer may request Customer Content and generated content during its subscription period and for 30 days thereafter; after that period, Parley may delete the content.

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information. These measures include encryption in transit and at rest, access controls, security assessments, secure infrastructure practices, and procedures intended to protect the confidentiality, integrity, and availability of the Services. Our security program is designed to align with industry standards, including SOC 2 Type II controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data Breach and Security Incident Notification

If we become aware of a security incident involving personal information, we will promptly investigate, take appropriate measures to contain, mitigate, and remediate the incident, and document and assess the incident as required by applicable law. Where notice is required, we will notify affected individuals, customers, regulators, or other authorities within the time and in the manner required by applicable law.

When Customer Content is processed on a customer’s behalf, Parley will notify the customer in accordance with the applicable customer agreement or data-processing terms and will provide information reasonably necessary for the customer to meet its own notification obligations. The content and timing of any notice will depend on the nature and scope of the incident, the information involved, and applicable legal requirements.

7.- U.S. State Privacy Rights

This section applies to residents of U.S. states with comprehensive consumer privacy laws, to the extent those laws apply to Parley and the individual’s personal information. It supplements the other parts of this Privacy Policy.

Subject to applicable law and exceptions, you may have the right to confirm whether we process your personal information and access it; correct inaccurate personal information; delete personal information; obtain a portable copy of personal information in a readily usable format; opt out of the sale of personal information, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects; limit the use or disclosure of sensitive personal information where that right applies; and appeal our decision regarding a privacy-rights request.

To submit a request, email [email protected] with the subject line “U.S. Privacy Rights Request” and identify the right you wish to exercise. Authorized agents may submit requests where permitted by law. We may require proof of the agent’s authority and may verify the consumer’s identity. We will not discriminate against you for exercising a privacy right.

We verify requests using information associated with the request and may ask for additional information where necessary. If we deny a request, you may appeal by replying to our decision with the subject line “Privacy Rights Appeal.” If your appeal is denied, you may have the right to contact your state attorney general or other regulator, as applicable.

To the extent required by applicable U.S. state privacy laws, Section 2 identifies the categories of personal information we collect, Section 3 identifies the purposes for which we process it, and Section 5 identifies the categories of recipients to which we disclose it. Depending on the features used, we may process identifiers, commercial information, internet or other electronic network activity information, professional or employment-related information, communications, Customer Content, and inferences or usage records derived from Service activity. We do not use personal information to make decisions that produce legal or similarly significant effects concerning individuals.

For California residents, the categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of recipients to which we disclose it are described in Sections 2 through 5 of this Privacy Policy. In the preceding 12 months, we have disclosed the categories of personal information described in Section 2 to the categories of recipients described in Section 5 for the business and commercial purposes described in Section 3. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law (including California Civil Code § 1798.121 and analogous provisions in other state privacy laws) without providing any notice and opportunity to limit such use or disclosure that may be required.

Parley does not knowingly sell or share the personal information of consumers under 16 years of age. California residents may request information about our disclosure of personal information to third parties for their direct-marketing purposes under California’s “Shine the Light” law by contacting [email protected].

Sale, Sharing, Targeted Advertising, and Profiling. We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws (including the California Consumer Privacy Act as amended by the CPRA). We do not process personal information for the purpose of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. If our practices change in a manner that would constitute a sale, share, targeted advertising, or covered profiling, we will provide any required notice, opt-out mechanism, and recognition of applicable opt-out preference signals (including Global Privacy Control signals) before engaging in that practice.

8.- EEA, UK, Switzerland, and Related Countries

This section applies to individuals in the European Economic Area (“EEA“), the United Kingdom (“UK“), Switzerland, and other jurisdictions with substantially similar privacy laws, to the extent Parley acts as a controller of their personal information.

Controller and Legal Bases

Parley Technologies, Inc. is the controller of the personal information described in this Privacy Policy. We process that information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

Necessity of Information

Where we need personal information to enter into or perform a contract, process payment, or comply with a legal obligation, failure to provide that information may prevent us from providing or continuing to provide the relevant Services. We will identify when information is required and when its provision is optional.

Your Rights

Subject to applicable law, you may request access to, correction of, deletion of, or a copy of your personal information; object to processing based on legitimate interests; request restriction of processing; withdraw consent; and request data portability. You may also have rights relating to automated decision-making and profiling. To exercise these rights, contact [email protected]. You also have the right to lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or place of the alleged infringement.

We will respond to privacy-rights requests within the period required by applicable law. We may request information reasonably necessary to verify a request, confirm the requester’s identity or authority, and protect personal information from unauthorized disclosure. An individual may authorize another person to submit a request where permitted by law, subject to appropriate verification.

If Parley processes Customer Content on behalf of one of its customers, that customer is ordinarily responsible for responding to data-subject requests. Please submit your request directly to that customer; we will assist the customer as required by applicable law and our contractual commitments.

The rights described in this Section 8 arise under the EU General Data Protection Regulation, the UK GDPR, and the Swiss Federal Act on Data Protection. They are separate from the recourse available under the Data Privacy Framework Principles, which is described under “Data Privacy Framework” below. Nothing in that subsection limits your right to lodge a complaint with your supervisory authority, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner.

International Transfers

Parley is based in the United States and may process personal information in the United States and other countries where Parley, its affiliates, service providers, or subprocessors operate. For personal data transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland, we rely on our certification under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, as described below. Where another transfer mechanism is required, we use an adequacy decision, standard contractual clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.

Where required by applicable law, Parley will identify an authorized representative in the EEA or UK and provide the representative’s contact information before offering the Services in a manner that triggers that requirement.

Data Privacy Framework (EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF)

Parley Technologies, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Scope of our certification. Our certification covers personal data relating to individuals in the European Union, the United Kingdom (and Gibraltar), and Switzerland that we receive in the United States in the course of our commercial activities, including personal data we receive as a controller and personal data we process on behalf of our customers when providing the Services. Our certification does not cover human resources data. No U.S. subsidiaries or affiliates of Parley Technologies, Inc. are covered by this certification.

Personal data covered and purposes of processing. The categories of personal data we receive in reliance on the DPF are described in Section 2, the purposes for which we collect and use each category are described in Sections 3 and 4, and the third parties to which we disclose personal data and the purposes of those disclosures are described in Section 5.

Choice. Where we intend to use personal data received in reliance on the DPF for a purpose that is materially different from the purpose for which it was collected or subsequently authorized, or to disclose that personal data to a third party acting as a controller, we will first offer you a clear, conspicuous, and readily available means to opt out. For sensitive personal data, we will obtain your affirmative express consent (opt in) before such a use or disclosure. You may opt out of marketing communications at any time using the unsubscribe link in those messages or by contacting us at [email protected]. Where we process personal data on behalf of a customer, that customer determines the purposes of processing, and choice requests should be directed to that customer.

Access, correction, and deletion. Individuals whose personal data we receive in reliance on the DPF have the right to access that personal data and to have it corrected, amended, or deleted where it is inaccurate or has been processed in violation of the Principles, subject to the limitations permitted by the Principles. Requests may be submitted to [email protected]. Where the personal data was provided to us by a customer for whom we act as a processor, we will refer the request to that customer and assist as required by our agreement with that customer.

Onward transfers and liability. We may transfer personal data received in reliance on the DPF to third parties acting as our agents, including the service providers and subprocessors described in Section 5, for the purposes described in this Privacy Policy. We require those third parties to provide at least the same level of protection for personal data as is required by the Principles. We remain responsible under the Principles for personal data that we transfer to a third party acting as an agent on our behalf, and we may be liable if that agent processes such personal data in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Government access. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution and independent recourse. In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Parley Technologies, Inc. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Parley Technologies, Inc. at [email protected] or at 425 Gough Street, STE 200, San Francisco, CA 94102, United States.

Parley Technologies, Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Enforcement. Parley Technologies, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

9.- Copyright and DMCA Notices

Parley respects intellectual-property rights. If you believe that content available through the Services infringes your copyright, you may submit a notice to Parley at [email protected] containing the information required by applicable law, including the information required by 17 U.S.C. § 512. A valid notice should identify the copyrighted work, identify the allegedly infringing material and its location, provide your contact information, include the required good-faith and accuracy statements, and be signed physically or electronically.

10.- Cookies and Similar Technologies

We and our service providers may use cookies, local storage, log files, pixels, software-development kits, and similar technologies to operate the Services, remember preferences, secure accounts, prevent fraud, process payments, measure website or Service performance, and, where applicable, understand engagement with our communications. You can control certain browser storage and cookies through your browser settings. Disabling necessary technologies may affect the availability or functionality of the Services.

Where required by law, we will obtain consent before placing or accessing non-essential cookies or similar technologies and will provide a mechanism to change consent choices.

11.- Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes—including material changes to the categories of personal information we collect, the purposes for which we use it, the categories of recipients to which we disclose it, or applicable retention practices—we will provide notice as required by law, such as by email to the address associated with the account, a conspicuous notice in the Services, and an updated “Last Updated” date. Where legally required, we will provide advance notice and obtain consent before a material change takes effect. Non-material updates, corrections, and clarifications may be effective when posted. Continued use of the Services after the effective date of an updated Privacy Policy is subject to the updated policy to the extent permitted by law.

12.- Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

Parley Technologies, Inc.
425 Gough Street, STE 200
San Francisco, CA 94102
Email: [email protected]

For privacy-rights requests, email [email protected] with the subject line “Privacy Rights Request.” To report a suspected security vulnerability, contact [email protected].

For privacy inquiries and complaints, including inquiries and complaints under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, contact [email protected]

Parley Technologies, Inc. (“Parley,” “we,” “us,” or “our“) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information when you visit www.parley.so, create or administer an account, subscribe to or use the Parley platform, contact us, or otherwise interact with a website, application, or service that links to this Privacy Policy (collectively, the “Services“).


1.- Scope and Our Role

This Privacy Policy applies when Parley processes personal information as a controller, including information about website visitors, prospective customers, account administrators, authorized users, billing contacts, and people who communicate with us.

The Services permit customers and their authorized users to upload, create, generate, and otherwise provide content that may contain personal information about clients, employees, counterparties, or other individuals (“Customer Content“). When Parley processes Customer Content solely on a customer’s behalf in providing the Services, Parley acts as that customer’s service provider or processor under the applicable customer agreement and Data Processing Addendum (or equivalent data-processing terms). The customer’s privacy notice and those data-processing terms govern that processing; this Privacy Policy does not apply to Customer Content processed solely on a customer’s behalf.

If you provide personal information directly to Parley—for example, to open or administer an account, subscribe to the Services, contact support, receive marketing communications, or use our public website—Parley processes that information as a controller as described in this Privacy Policy.


2.- Personal Information We Collect

We may collect the following categories of personal information:

·       Account and contact information, such as name, business email address, phone number, company or firm name, professional title, mailing address, username, account credentials, and account-administration information.

·       Subscription and transaction information, such as selected plan tier, free-trial enrollment, subscription status, billing contact details, invoices, payment status, purchase history, applicable tax information, and payment-processor identifiers. Our designated payment processors process payment-card and ACH information; Parley does not intentionally store full payment-card numbers.

·       Service and usage information, such as account settings, features used, Credit consumption and metering records, prompts and activity within the Services, support interactions, logs, and information about the devices and browsers used to access the Services.

·       Communications and feedback, such as inquiries, support requests, survey responses, messages exchanged with us, and feedback regarding the Services.

·       Marketing information, such as preferences for receiving marketing communications and engagement with those communications.

·       Device and online activity information, such as IP address, browser type, device type, operating system, approximate location derived from IP address, access times, pages viewed, and interactions with our website and communications.

·       Information from third parties, such as business contact information, public profile information, and information from referral, marketing, identity-verification, payment, and service providers, where permitted by law.

We may receive personal information contained in Customer Content. Where we process that Customer Content solely on a customer’s behalf, the customer—not Parley—is responsible for its privacy notice and for responding to requests concerning that Customer Content.

We do not require customers or authorized users to provide sensitive personal information to create or administer an account. Customer Content or communications that a customer or authorized user elects to provide may nonetheless contain sensitive personal information. We process it only as necessary to provide, secure, support, and comply with applicable obligations relating to the Services.

The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16.


3.- How We Use Personal Information

We use personal information to provide, operate, secure, maintain, and improve the Services; create and administer accounts; process subscriptions, purchases, and payments; provide customer support; communicate about accounts, billing, security, and service changes; measure and administer plan usage, including Credit consumption and applicable charges; personalize and improve the user experience; conduct research and development; develop and use aggregated or deidentified information; send marketing communications where permitted by law; protect against fraud, abuse, security incidents, and other harmful or unlawful activity; comply with legal obligations; enforce our agreements; and establish, exercise, or defend legal claims.

Where applicable law requires a legal basis, we process personal information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations.


4.- Artificial Intelligence and Automated Processing

The Services use artificial intelligence to assist users with legal-work workflows, including analyzing Customer Content, generating drafts and other work product, extracting information, populating or updating records, and executing automated workflows and agentic tasks. AI-generated output may be inaccurate, incomplete, or inappropriate for a particular purpose. A qualified human user must review AI-generated output before relying on or using it.

Parley does not use Customer Content to train, fine-tune, or otherwise develop AI models made available to other customers, except where the applicable customer expressly authorizes that use in a separate agreement. We may use account, service, and usage information, and aggregated or deidentified information, to operate, secure, support, and improve the Services as described in this Privacy Policy.

Parley does not make decisions that produce legal or similarly significant effects concerning individuals based solely on automated processing of personal information. If our practices change, we will provide any notice, choice, or rights required by applicable law.


5.- How We Disclose Personal Information

We may disclose personal information to:

·       Service providers and subprocessors that provide hosting, infrastructure, payment processing, customer support, analytics, security, communications, and other services for us;

·       Professional advisors, including lawyers, accountants, auditors, insurers, and financing sources;

·       Business partners, where you direct us to share information or where disclosure is otherwise consistent with your relationship with us;

·       Government authorities and other third parties, when we reasonably believe disclosure is required by law, legal process, or a governmental request, or is necessary to protect rights, safety, security, or property; and

·       Parties to a corporate transaction, such as a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets.

We may also use and disclose aggregated or deidentified information that does not reasonably identify an individual.

We disclose only the personal information reasonably necessary for a service provider or subprocessor to perform its services. We require service providers that process personal information on our behalf to process it only for authorized purposes and subject to appropriate confidentiality, security, and data-protection obligations.

Parley’s current material subprocessors are listed at www.trust.parley.so. They may process the categories of information identified in connection with the stated service function.

We may update this list as our Services evolve. If we add or replace a subprocessor that will access or process Customer Content, we will provide any advance notice, opportunity to object, or other process required by the applicable customer agreement or data-processing terms.

Google API Services and Workspace Data

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.


6.- Retention and Security

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. The applicable retention period depends on the nature of the information, the purpose of processing, the duration of the account or customer relationship, and applicable legal requirements.

We retain account-profile and account-administration information for the life of the account and thereafter only as necessary for security, fraud prevention, dispute resolution, legal compliance, or enforcement of our agreements. We retain subscription, invoice, payment-processor identifier, and tax information as required for billing, accounting, tax, chargeback, dispute, and legal-compliance purposes. We retain Credit-consumption and service-usage records as reasonably necessary to administer subscriptions, resolve billing questions, protect the Services, and improve service operations. We retain support communications and security logs for periods reasonably necessary for support, security, abuse prevention, incident response, and legal compliance.

Customer Content is retained and deleted in accordance with the applicable customer agreement and the Services’ account-deletion and download functionality. Under the current Terms of Service, a customer may request Customer Content and generated content during its subscription period and for 30 days thereafter; after that period, Parley may delete the content.

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information. These measures include encryption in transit and at rest, access controls, security assessments, secure infrastructure practices, and procedures intended to protect the confidentiality, integrity, and availability of the Services. Our security program is designed to align with industry standards, including SOC 2 Type II controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data Breach and Security Incident Notification

If we become aware of a security incident involving personal information, we will promptly investigate, take appropriate measures to contain, mitigate, and remediate the incident, and document and assess the incident as required by applicable law. Where notice is required, we will notify affected individuals, customers, regulators, or other authorities within the time and in the manner required by applicable law.

When Customer Content is processed on a customer’s behalf, Parley will notify the customer in accordance with the applicable customer agreement or data-processing terms and will provide information reasonably necessary for the customer to meet its own notification obligations. The content and timing of any notice will depend on the nature and scope of the incident, the information involved, and applicable legal requirements.


7.- U.S. State Privacy Rights

This section applies to residents of U.S. states with comprehensive consumer privacy laws, to the extent those laws apply to Parley and the individual’s personal information. It supplements the other parts of this Privacy Policy.

Subject to applicable law and exceptions, you may have the right to confirm whether we process your personal information and access it; correct inaccurate personal information; delete personal information; obtain a portable copy of personal information in a readily usable format; opt out of the sale of personal information, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects; limit the use or disclosure of sensitive personal information where that right applies; and appeal our decision regarding a privacy-rights request.

To submit a request, email [email protected] with the subject line “U.S. Privacy Rights Request” and identify the right you wish to exercise. Authorized agents may submit requests where permitted by law. We may require proof of the agent’s authority and may verify the consumer’s identity. We will not discriminate against you for exercising a privacy right.

We verify requests using information associated with the request and may ask for additional information where necessary. If we deny a request, you may appeal by replying to our decision with the subject line “Privacy Rights Appeal.” If your appeal is denied, you may have the right to contact your state attorney general or other regulator, as applicable.

To the extent required by applicable U.S. state privacy laws, Section 2 identifies the categories of personal information we collect, Section 3 identifies the purposes for which we process it, and Section 5 identifies the categories of recipients to which we disclose it. Depending on the features used, we may process identifiers, commercial information, internet or other electronic network activity information, professional or employment-related information, communications, Customer Content, and inferences or usage records derived from Service activity. We do not use personal information to make decisions that produce legal or similarly significant effects concerning individuals.

For California residents, the categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of recipients to which we disclose it are described in Sections 2 through 5 of this Privacy Policy. In the preceding 12 months, we have disclosed the categories of personal information described in Section 2 to the categories of recipients described in Section 5 for the business and commercial purposes described in Section 3. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law (including California Civil Code § 1798.121 and analogous provisions in other state privacy laws) without providing any notice and opportunity to limit such use or disclosure that may be required.

Parley does not knowingly sell or share the personal information of consumers under 16 years of age. California residents may request information about our disclosure of personal information to third parties for their direct-marketing purposes under California’s “Shine the Light” law by contacting [email protected].

Sale, Sharing, Targeted Advertising, and Profiling. We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws (including the California Consumer Privacy Act as amended by the CPRA). We do not process personal information for the purpose of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. If our practices change in a manner that would constitute a sale, share, targeted advertising, or covered profiling, we will provide any required notice, opt-out mechanism, and recognition of applicable opt-out preference signals (including Global Privacy Control signals) before engaging in that practice.


8.- EEA, UK, Switzerland, and Related Countries

This section applies to individuals in the European Economic Area (“EEA“), the United Kingdom (“UK“), Switzerland, and other jurisdictions with substantially similar privacy laws, to the extent Parley acts as a controller of their personal information.

Controller and Legal Bases

Parley Technologies, Inc. is the controller of the personal information described in this Privacy Policy. We process that information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

Necessity of Information

Where we need personal information to enter into or perform a contract, process payment, or comply with a legal obligation, failure to provide that information may prevent us from providing or continuing to provide the relevant Services. We will identify when information is required and when its provision is optional.

Your Rights

Subject to applicable law, you may request access to, correction of, deletion of, or a copy of your personal information; object to processing based on legitimate interests; request restriction of processing; withdraw consent; and request data portability. You may also have rights relating to automated decision-making and profiling. To exercise these rights, contact [email protected]. You also have the right to lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or place of the alleged infringement.

We will respond to privacy-rights requests within the period required by applicable law. We may request information reasonably necessary to verify a request, confirm the requester’s identity or authority, and protect personal information from unauthorized disclosure. An individual may authorize another person to submit a request where permitted by law, subject to appropriate verification.

If Parley processes Customer Content on behalf of one of its customers, that customer is ordinarily responsible for responding to data-subject requests. Please submit your request directly to that customer; we will assist the customer as required by applicable law and our contractual commitments.

The rights described in this Section 8 arise under the EU General Data Protection Regulation, the UK GDPR, and the Swiss Federal Act on Data Protection. They are separate from the recourse available under the Data Privacy Framework Principles, which is described under “Data Privacy Framework” below. Nothing in that subsection limits your right to lodge a complaint with your supervisory authority, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner.

International Transfers

Parley is based in the United States and may process personal information in the United States and other countries where Parley, its affiliates, service providers, or subprocessors operate. For personal data transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland, we rely on our certification under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, as described below. Where another transfer mechanism is required, we use an adequacy decision, standard contractual clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.

Where required by applicable law, Parley will identify an authorized representative in the EEA or UK and provide the representative’s contact information before offering the Services in a manner that triggers that requirement.

Data Privacy Framework (EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF)

Parley Technologies, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Scope of our certification. Our certification covers personal data relating to individuals in the European Union, the United Kingdom (and Gibraltar), and Switzerland that we receive in the United States in the course of our commercial activities, including personal data we receive as a controller and personal data we process on behalf of our customers when providing the Services. Our certification does not cover human resources data. No U.S. subsidiaries or affiliates of Parley Technologies, Inc. are covered by this certification.

Personal data covered and purposes of processing. The categories of personal data we receive in reliance on the DPF are described in Section 2, the purposes for which we collect and use each category are described in Sections 3 and 4, and the third parties to which we disclose personal data and the purposes of those disclosures are described in Section 5.

Choice. Where we intend to use personal data received in reliance on the DPF for a purpose that is materially different from the purpose for which it was collected or subsequently authorized, or to disclose that personal data to a third party acting as a controller, we will first offer you a clear, conspicuous, and readily available means to opt out. For sensitive personal data, we will obtain your affirmative express consent (opt in) before such a use or disclosure. You may opt out of marketing communications at any time using the unsubscribe link in those messages or by contacting us at [email protected]. Where we process personal data on behalf of a customer, that customer determines the purposes of processing, and choice requests should be directed to that customer.

Access, correction, and deletion. Individuals whose personal data we receive in reliance on the DPF have the right to access that personal data and to have it corrected, amended, or deleted where it is inaccurate or has been processed in violation of the Principles, subject to the limitations permitted by the Principles. Requests may be submitted to [email protected]. Where the personal data was provided to us by a customer for whom we act as a processor, we will refer the request to that customer and assist as required by our agreement with that customer.

Onward transfers and liability. We may transfer personal data received in reliance on the DPF to third parties acting as our agents, including the service providers and subprocessors described in Section 5, for the purposes described in this Privacy Policy. We require those third parties to provide at least the same level of protection for personal data as is required by the Principles. We remain responsible under the Principles for personal data that we transfer to a third party acting as an agent on our behalf, and we may be liable if that agent processes such personal data in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Government access. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution and independent recourse. In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Parley Technologies, Inc. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Parley Technologies, Inc. at [email protected] or at 425 Gough Street, STE 200, San Francisco, CA 94102, United States.

Parley Technologies, Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Enforcement. Parley Technologies, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).


9.- Copyright and DMCA Notices

Parley respects intellectual-property rights. If you believe that content available through the Services infringes your copyright, you may submit a notice to Parley at [email protected] containing the information required by applicable law, including the information required by 17 U.S.C. § 512. A valid notice should identify the copyrighted work, identify the allegedly infringing material and its location, provide your contact information, include the required good-faith and accuracy statements, and be signed physically or electronically.


10.- Cookies and Similar Technologies

We and our service providers may use cookies, local storage, log files, pixels, software-development kits, and similar technologies to operate the Services, remember preferences, secure accounts, prevent fraud, process payments, measure website or Service performance, and, where applicable, understand engagement with our communications. You can control certain browser storage and cookies through your browser settings. Disabling necessary technologies may affect the availability or functionality of the Services.

Where required by law, we will obtain consent before placing or accessing non-essential cookies or similar technologies and will provide a mechanism to change consent choices.


11.- Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes—including material changes to the categories of personal information we collect, the purposes for which we use it, the categories of recipients to which we disclose it, or applicable retention practices—we will provide notice as required by law, such as by email to the address associated with the account, a conspicuous notice in the Services, and an updated “Last Updated” date. Where legally required, we will provide advance notice and obtain consent before a material change takes effect. Non-material updates, corrections, and clarifications may be effective when posted. Continued use of the Services after the effective date of an updated Privacy Policy is subject to the updated policy to the extent permitted by law.


12.- Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

Parley Technologies, Inc.
425 Gough Street, STE 200
San Francisco, CA 94102
Email: [email protected]

For privacy-rights requests, email [email protected] with the subject line “Privacy Rights Request.” To report a suspected security vulnerability, contact [email protected].

For privacy inquiries and complaints, including inquiries and complaints under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, contact [email protected]

Parley Technologies, Inc. (“Parley,” “we,” “us,” or “our“) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information when you visit www.parley.so, create or administer an account, subscribe to or use the Parley platform, contact us, or otherwise interact with a website, application, or service that links to this Privacy Policy (collectively, the “Services“).


1.- Scope and Our Role

This Privacy Policy applies when Parley processes personal information as a controller, including information about website visitors, prospective customers, account administrators, authorized users, billing contacts, and people who communicate with us.

The Services permit customers and their authorized users to upload, create, generate, and otherwise provide content that may contain personal information about clients, employees, counterparties, or other individuals (“Customer Content“). When Parley processes Customer Content solely on a customer’s behalf in providing the Services, Parley acts as that customer’s service provider or processor under the applicable customer agreement and Data Processing Addendum (or equivalent data-processing terms). The customer’s privacy notice and those data-processing terms govern that processing; this Privacy Policy does not apply to Customer Content processed solely on a customer’s behalf.

If you provide personal information directly to Parley—for example, to open or administer an account, subscribe to the Services, contact support, receive marketing communications, or use our public website—Parley processes that information as a controller as described in this Privacy Policy.

2.- Personal Information We Collect
We may collect the following categories of personal information:

·       Account and contact information, such as name, business email address, phone number, company or firm name, professional title, mailing address, username, account credentials, and account-administration information.

·       Subscription and transaction information, such as selected plan tier, free-trial enrollment, subscription status, billing contact details, invoices, payment status, purchase history, applicable tax information, and payment-processor identifiers. Our designated payment processors process payment-card and ACH information; Parley does not intentionally store full payment-card numbers.

·       Service and usage information, such as account settings, features used, Credit consumption and metering records, prompts and activity within the Services, support interactions, logs, and information about the devices and browsers used to access the Services.

·       Communications and feedback, such as inquiries, support requests, survey responses, messages exchanged with us, and feedback regarding the Services.

·       Marketing information, such as preferences for receiving marketing communications and engagement with those communications.

·       Device and online activity information, such as IP address, browser type, device type, operating system, approximate location derived from IP address, access times, pages viewed, and interactions with our website and communications.

·       Information from third parties, such as business contact information, public profile information, and information from referral, marketing, identity-verification, payment, and service providers, where permitted by law.

We may receive personal information contained in Customer Content. Where we process that Customer Content solely on a customer’s behalf, the customer—not Parley—is responsible for its privacy notice and for responding to requests concerning that Customer Content.

We do not require customers or authorized users to provide sensitive personal information to create or administer an account. Customer Content or communications that a customer or authorized user elects to provide may nonetheless contain sensitive personal information. We process it only as necessary to provide, secure, support, and comply with applicable obligations relating to the Services.

The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16.


3.- How We Use Personal Information

We use personal information to provide, operate, secure, maintain, and improve the Services; create and administer accounts; process subscriptions, purchases, and payments; provide customer support; communicate about accounts, billing, security, and service changes; measure and administer plan usage, including Credit consumption and applicable charges; personalize and improve the user experience; conduct research and development; develop and use aggregated or deidentified information; send marketing communications where permitted by law; protect against fraud, abuse, security incidents, and other harmful or unlawful activity; comply with legal obligations; enforce our agreements; and establish, exercise, or defend legal claims.

Where applicable law requires a legal basis, we process personal information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations.


4.- Artificial Intelligence and Automated Processing

The Services use artificial intelligence to assist users with legal-work workflows, including analyzing Customer Content, generating drafts and other work product, extracting information, populating or updating records, and executing automated workflows and agentic tasks. AI-generated output may be inaccurate, incomplete, or inappropriate for a particular purpose. A qualified human user must review AI-generated output before relying on or using it.

Parley does not use Customer Content to train, fine-tune, or otherwise develop AI models made available to other customers, except where the applicable customer expressly authorizes that use in a separate agreement. We may use account, service, and usage information, and aggregated or deidentified information, to operate, secure, support, and improve the Services as described in this Privacy Policy.

Parley does not make decisions that produce legal or similarly significant effects concerning individuals based solely on automated processing of personal information. If our practices change, we will provide any notice, choice, or rights required by applicable law.


5.- How We Disclose Personal Information

We may disclose personal information to:

·       Service providers and subprocessors that provide hosting, infrastructure, payment processing, customer support, analytics, security, communications, and other services for us;

·       Professional advisors, including lawyers, accountants, auditors, insurers, and financing sources;

·       Business partners, where you direct us to share information or where disclosure is otherwise consistent with your relationship with us;

·       Government authorities and other third parties, when we reasonably believe disclosure is required by law, legal process, or a governmental request, or is necessary to protect rights, safety, security, or property; and

·       Parties to a corporate transaction, such as a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets.

We may also use and disclose aggregated or deidentified information that does not reasonably identify an individual.

We disclose only the personal information reasonably necessary for a service provider or subprocessor to perform its services. We require service providers that process personal information on our behalf to process it only for authorized purposes and subject to appropriate confidentiality, security, and data-protection obligations.

Parley’s current material subprocessors are listed at www.trust.parley.so. They may process the categories of information identified in connection with the stated service function.

We may update this list as our Services evolve. If we add or replace a subprocessor that will access or process Customer Content, we will provide any advance notice, opportunity to object, or other process required by the applicable customer agreement or data-processing terms.

Google API Services and Workspace Data

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.


6.- Retention and Security

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. The applicable retention period depends on the nature of the information, the purpose of processing, the duration of the account or customer relationship, and applicable legal requirements.

We retain account-profile and account-administration information for the life of the account and thereafter only as necessary for security, fraud prevention, dispute resolution, legal compliance, or enforcement of our agreements. We retain subscription, invoice, payment-processor identifier, and tax information as required for billing, accounting, tax, chargeback, dispute, and legal-compliance purposes. We retain Credit-consumption and service-usage records as reasonably necessary to administer subscriptions, resolve billing questions, protect the Services, and improve service operations. We retain support communications and security logs for periods reasonably necessary for support, security, abuse prevention, incident response, and legal compliance.

Customer Content is retained and deleted in accordance with the applicable customer agreement and the Services’ account-deletion and download functionality. Under the current Terms of Service, a customer may request Customer Content and generated content during its subscription period and for 30 days thereafter; after that period, Parley may delete the content.

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information. These measures include encryption in transit and at rest, access controls, security assessments, secure infrastructure practices, and procedures intended to protect the confidentiality, integrity, and availability of the Services. Our security program is designed to align with industry standards, including SOC 2 Type II controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data Breach and Security Incident Notification

If we become aware of a security incident involving personal information, we will promptly investigate, take appropriate measures to contain, mitigate, and remediate the incident, and document and assess the incident as required by applicable law. Where notice is required, we will notify affected individuals, customers, regulators, or other authorities within the time and in the manner required by applicable law.

When Customer Content is processed on a customer’s behalf, Parley will notify the customer in accordance with the applicable customer agreement or data-processing terms and will provide information reasonably necessary for the customer to meet its own notification obligations. The content and timing of any notice will depend on the nature and scope of the incident, the information involved, and applicable legal requirements.


7.- U.S. State Privacy Rights

This section applies to residents of U.S. states with comprehensive consumer privacy laws, to the extent those laws apply to Parley and the individual’s personal information. It supplements the other parts of this Privacy Policy.

Subject to applicable law and exceptions, you may have the right to confirm whether we process your personal information and access it; correct inaccurate personal information; delete personal information; obtain a portable copy of personal information in a readily usable format; opt out of the sale of personal information, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects; limit the use or disclosure of sensitive personal information where that right applies; and appeal our decision regarding a privacy-rights request.

To submit a request, email [email protected] with the subject line “U.S. Privacy Rights Request” and identify the right you wish to exercise. Authorized agents may submit requests where permitted by law. We may require proof of the agent’s authority and may verify the consumer’s identity. We will not discriminate against you for exercising a privacy right.

We verify requests using information associated with the request and may ask for additional information where necessary. If we deny a request, you may appeal by replying to our decision with the subject line “Privacy Rights Appeal.” If your appeal is denied, you may have the right to contact your state attorney general or other regulator, as applicable.

To the extent required by applicable U.S. state privacy laws, Section 2 identifies the categories of personal information we collect, Section 3 identifies the purposes for which we process it, and Section 5 identifies the categories of recipients to which we disclose it. Depending on the features used, we may process identifiers, commercial information, internet or other electronic network activity information, professional or employment-related information, communications, Customer Content, and inferences or usage records derived from Service activity. We do not use personal information to make decisions that produce legal or similarly significant effects concerning individuals.

For California residents, the categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of recipients to which we disclose it are described in Sections 2 through 5 of this Privacy Policy. In the preceding 12 months, we have disclosed the categories of personal information described in Section 2 to the categories of recipients described in Section 5 for the business and commercial purposes described in Section 3. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law (including California Civil Code § 1798.121 and analogous provisions in other state privacy laws) without providing any notice and opportunity to limit such use or disclosure that may be required.

Parley does not knowingly sell or share the personal information of consumers under 16 years of age. California residents may request information about our disclosure of personal information to third parties for their direct-marketing purposes under California’s “Shine the Light” law by contacting [email protected].

Sale, Sharing, Targeted Advertising, and Profiling. We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws (including the California Consumer Privacy Act as amended by the CPRA). We do not process personal information for the purpose of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. If our practices change in a manner that would constitute a sale, share, targeted advertising, or covered profiling, we will provide any required notice, opt-out mechanism, and recognition of applicable opt-out preference signals (including Global Privacy Control signals) before engaging in that practice.


8.- EEA, UK, Switzerland, and Related Countries

This section applies to individuals in the European Economic Area (“EEA“), the United Kingdom (“UK“), Switzerland, and other jurisdictions with substantially similar privacy laws, to the extent Parley acts as a controller of their personal information.

Controller and Legal Bases

Parley Technologies, Inc. is the controller of the personal information described in this Privacy Policy. We process that information to perform a contract with you or your organization; for our legitimate interests in operating, securing, supporting, improving, and marketing the Services; with your consent where required; and to comply with legal obligations. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

Necessity of Information

Where we need personal information to enter into or perform a contract, process payment, or comply with a legal obligation, failure to provide that information may prevent us from providing or continuing to provide the relevant Services. We will identify when information is required and when its provision is optional.

Your Rights

Subject to applicable law, you may request access to, correction of, deletion of, or a copy of your personal information; object to processing based on legitimate interests; request restriction of processing; withdraw consent; and request data portability. You may also have rights relating to automated decision-making and profiling. To exercise these rights, contact [email protected]. You also have the right to lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or place of the alleged infringement.

We will respond to privacy-rights requests within the period required by applicable law. We may request information reasonably necessary to verify a request, confirm the requester’s identity or authority, and protect personal information from unauthorized disclosure. An individual may authorize another person to submit a request where permitted by law, subject to appropriate verification.

If Parley processes Customer Content on behalf of one of its customers, that customer is ordinarily responsible for responding to data-subject requests. Please submit your request directly to that customer; we will assist the customer as required by applicable law and our contractual commitments.

The rights described in this Section 8 arise under the EU General Data Protection Regulation, the UK GDPR, and the Swiss Federal Act on Data Protection. They are separate from the recourse available under the Data Privacy Framework Principles, which is described under “Data Privacy Framework” below. Nothing in that subsection limits your right to lodge a complaint with your supervisory authority, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner.

International Transfers

Parley is based in the United States and may process personal information in the United States and other countries where Parley, its affiliates, service providers, or subprocessors operate. For personal data transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland, we rely on our certification under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, as described below. Where another transfer mechanism is required, we use an adequacy decision, standard contractual clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.

Where required by applicable law, Parley will identify an authorized representative in the EEA or UK and provide the representative’s contact information before offering the Services in a manner that triggers that requirement.

Data Privacy Framework (EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF)

Parley Technologies, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Parley Technologies, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Scope of our certification. Our certification covers personal data relating to individuals in the European Union, the United Kingdom (and Gibraltar), and Switzerland that we receive in the United States in the course of our commercial activities, including personal data we receive as a controller and personal data we process on behalf of our customers when providing the Services. Our certification does not cover human resources data. No U.S. subsidiaries or affiliates of Parley Technologies, Inc. are covered by this certification.

Personal data covered and purposes of processing. The categories of personal data we receive in reliance on the DPF are described in Section 2, the purposes for which we collect and use each category are described in Sections 3 and 4, and the third parties to which we disclose personal data and the purposes of those disclosures are described in Section 5.

Choice. Where we intend to use personal data received in reliance on the DPF for a purpose that is materially different from the purpose for which it was collected or subsequently authorized, or to disclose that personal data to a third party acting as a controller, we will first offer you a clear, conspicuous, and readily available means to opt out. For sensitive personal data, we will obtain your affirmative express consent (opt in) before such a use or disclosure. You may opt out of marketing communications at any time using the unsubscribe link in those messages or by contacting us at [email protected]. Where we process personal data on behalf of a customer, that customer determines the purposes of processing, and choice requests should be directed to that customer.

Access, correction, and deletion. Individuals whose personal data we receive in reliance on the DPF have the right to access that personal data and to have it corrected, amended, or deleted where it is inaccurate or has been processed in violation of the Principles, subject to the limitations permitted by the Principles. Requests may be submitted to [email protected]. Where the personal data was provided to us by a customer for whom we act as a processor, we will refer the request to that customer and assist as required by our agreement with that customer.

Onward transfers and liability. We may transfer personal data received in reliance on the DPF to third parties acting as our agents, including the service providers and subprocessors described in Section 5, for the purposes described in this Privacy Policy. We require those third parties to provide at least the same level of protection for personal data as is required by the Principles. We remain responsible under the Principles for personal data that we transfer to a third party acting as an agent on our behalf, and we may be liable if that agent processes such personal data in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Government access. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution and independent recourse. In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Parley Technologies, Inc. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Parley Technologies, Inc. at [email protected] or at 425 Gough Street, STE 200, San Francisco, CA 94102, United States.

Parley Technologies, Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Enforcement. Parley Technologies, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).


9.- Copyright and DMCA Notices

Parley respects intellectual-property rights. If you believe that content available through the Services infringes your copyright, you may submit a notice to Parley at [email protected] containing the information required by applicable law, including the information required by 17 U.S.C. § 512. A valid notice should identify the copyrighted work, identify the allegedly infringing material and its location, provide your contact information, include the required good-faith and accuracy statements, and be signed physically or electronically.


10.- Cookies and Similar Technologies

We and our service providers may use cookies, local storage, log files, pixels, software-development kits, and similar technologies to operate the Services, remember preferences, secure accounts, prevent fraud, process payments, measure website or Service performance, and, where applicable, understand engagement with our communications. You can control certain browser storage and cookies through your browser settings. Disabling necessary technologies may affect the availability or functionality of the Services.

Where required by law, we will obtain consent before placing or accessing non-essential cookies or similar technologies and will provide a mechanism to change consent choices.


11.- Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes—including material changes to the categories of personal information we collect, the purposes for which we use it, the categories of recipients to which we disclose it, or applicable retention practices—we will provide notice as required by law, such as by email to the address associated with the account, a conspicuous notice in the Services, and an updated “Last Updated” date. Where legally required, we will provide advance notice and obtain consent before a material change takes effect. Non-material updates, corrections, and clarifications may be effective when posted. Continued use of the Services after the effective date of an updated Privacy Policy is subject to the updated policy to the extent permitted by law.


12.- Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

Parley Technologies, Inc.
425 Gough Street, STE 200
San Francisco, CA 94102
Email: [email protected]

For privacy-rights requests, email [email protected] with the subject line “Privacy Rights Request.” To report a suspected security vulnerability, contact [email protected].

For privacy inquiries and complaints, including inquiries and complaints under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, contact [email protected]

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© 2026 Parley Technologies, Inc. All rights reserved.

© 2026 Parley Technologies, Inc. All rights reserved.

© 2026 Parley Technologies, Inc. All rights reserved.