Privacy Policy

This Privacy Policy explains how Partyhat Technologies Inc. ("Partyhat," "we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with our website at partyhat.ai and its subdomains, the Partyhat web application, the Partyhat desktop application, our email and text message programs, and any other product or service that links to this Privacy Policy (collectively, the "Services").

Partyhat is a platform that coordinates social media campaigns between businesses ("Brands") and individual social media users ("Participants") who choose to post, comment, like, follow, share, or review on third-party social media and review platforms. Capitalized terms not defined here have the meanings given in our Terms of Service.

This Privacy Policy does not cover our practices relating to Partyhat job applicants, employees, or contractors, or information that is not personal information under applicable law (such as de-identified or aggregated information).

The Services are intended for people in the United States who are 18 or older.

1. Our Role

Partyhat is the business (or "controller") responsible for the personal information described in this Privacy Policy, meaning we decide why and how it is processed.

When a Brand receives Participant information through the Services, the Brand uses it under its own privacy practices and our Terms of Service, which limit Brands to using that information to manage their Campaigns (see Section 5).

2. Personal Information We Collect

The personal information we collect depends on how you interact with us.

2.1 Information You Provide

• Identity and contact information, such as your name, email address, phone number, mailing city and state, and confirmation that you are at least 18 and a U.S. resident.
• Account information, such as your username, password or single sign-on credentials, account preferences, and communication preferences.
• Social media profile information (Participants), such as the social media and review handles and profile URLs you connect or enter, and information about those profiles (see Section 2.3).
• Interests and demographics (Participants), such as products and brands you use, your interests, your general location (city and state), gender, and age range, which we use to match you with relevant Campaigns.
• Submissions (Participants), such as links, screenshots, and other proof of Actions you take. Screenshots may incidentally include other people's names, handles, profile photos, or content shown on the page.
• Business information (Brands), such as your company name, job title, business email and phone, billing contact, and Campaign information, including briefs, talking points, and other Brand Materials.
• Payment information (Brands). Brand payments are processed by our payment processor, Stripe. Stripe collects your payment card or bank details directly; we receive only limited information, such as the card type, last four digits, expiration date, and billing address. Stripe's use of your information is governed by the Stripe Privacy Policy. Participants are not paid and we do not collect payment information from them.
• Communications and support information, such as the contents of emails, chat messages, support requests, surveys, and feedback you send us.

2.2 Information Collected Automatically

When you use the Services, we and our third-party partners automatically collect information using cookies, pixels, web beacons, software development kits, session replay tools, log files, and similar technologies:

• Device and network information, such as IP address, device type, operating system, browser type, app version, language settings, and unique device, cookie, and advertising identifiers.
• Usage information, such as pages and screens viewed, features used, links clicked, referring and exit pages, time and date of access, and whether you open our emails or click links in them.
• Session replay information. We use session replay tools that record how you interact with our website and web application, including clicks, mouse movements, scrolling, page navigation, and text you type into certain fields. We configure these tools to mask password and payment fields. See Section 7.3 for your choices.
• Desktop application diagnostics, such as crash reports, error logs, performance data, and app version information, which we use to keep the desktop application working.
• Approximate location, such as city, state, or region, derived from your IP address. We do not collect precise geolocation.

We may combine automatically collected information with other information we have about you.

2.3 Information from Other Sources

• Social media and review platforms. When you connect or enter a social media or review account, we collect publicly available information about it, such as your handle, display name, profile photo, bio, follower and following counts, public posts and engagement, and audience statistics made available by the platform. We also review the public Actions you submit to verify them.
• Single sign-on providers. If you log in through a third-party account (such as Google), we receive information that provider shares with us, such as your name, email address, and an authentication token. We do not receive your password for that account.
• Brands. Brands may provide us with information about their own representatives and about Campaign activity.
• Service providers and partners, such as analytics, advertising, and fraud-prevention providers.
• Publicly available sources.

2.4 Inferences

We may infer information about you, such as your interests and the types of Campaigns that may be relevant to you, from the other information we collect.

3. How We Use Personal Information

We use personal information to:

• Provide the Services, including creating and maintaining accounts, authenticating users, operating Campaigns, and processing Brand payments;
• Match Participants with Campaigns, based on the interests, demographics, social profile information, and products you tell us you use;
• Verify Actions and Submissions, show Campaign results to the Brand that ran the Campaign, and report on Campaign performance;
• Enforce our Terms, including verifying eligibility, monitoring compliance with our rules on honest opinions, reviews, disclosures, and compensation, and investigating misuse;
• Communicate with you, including sending account, security, Campaign, and service notices by email, in-app notification, or text message, and responding to support requests;
• Market our Services, including by email and, with your consent, text message, and through advertising on other websites and platforms (see Section 6);
• Analyze and improve the Services, including understanding how people use the Services, fixing bugs, and developing new features;
• Power AI-assisted features, such as Campaign matching, content moderation, and help drafting Campaign briefs and talking points (see Section 4);
• Protect the Services and others, including detecting, preventing, and responding to fraud, abuse, security incidents, and illegal activity;
• Comply with law and protect our rights, including responding to legal process, enforcing our agreements, and establishing, exercising, or defending legal claims;
• Facilitate business transactions, such as a merger, acquisition, financing, or sale of assets; and
• Fulfill any other purpose we describe when you provide the information or for which you give consent.

We may also create aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use de-identified information in de-identified form and do not attempt to re-identify it, except as permitted by law.

4. Artificial Intelligence

Some features of the Services use artificial intelligence models provided by third parties, such as Anthropic and OpenAI. When you use those features, we send the information needed for the feature to the provider to generate a response. We use these providers under terms that do not permit them to use the personal information we send to train their models.

We do not use your personal information to train artificial intelligence or machine learning models. We may use aggregated or de-identified information that does not identify you to develop and improve our models and features.

5. How We Disclose Personal Information

We disclose personal information as follows:

• To Brands. When you participate in a Campaign, we show the Brand that ran the Campaign your public social media profile information (such as your handle, profile URL, display name, profile photo, and public follower count), your Submissions, and your results for that Campaign. We do not give Brands your email address, phone number, or mailing location. Our Terms of Service prohibit Brands from using this information for anything other than managing their Campaigns, from selling or sharing it, and from using your content in their marketing without your separate permission.
• To service providers. We use vendors that process personal information on our behalf to help us run the Services, under contracts that limit their use of it. These include:
  • hosting and infrastructure (such as Amazon Web Services, Vercel, Heroku, and MongoDB Atlas);
  • payment processing (Stripe);
  • analytics and session replay (such as Google Analytics, PostHog, and Hotjar);
  • artificial intelligence (such as Anthropic and OpenAI);
  • email and text messaging (such as SendGrid and Twilio); and
  • customer support, security, and fraud prevention.
• To advertising partners. We work with advertising partners, such as Meta, Google, TikTok, and LinkedIn, whose pixels and similar technologies collect information about your use of our website (such as pages viewed and actions taken) to measure the effectiveness of our ads and to show you ads for Partyhat on other websites and platforms. We may also share a hashed email address or similar identifier with these partners to help them match you to their users. This may be considered a "sale" or "sharing" of personal information, or "targeted advertising," under some state laws. See Sections 7.4 and 9 for how to opt out.
• In a business transaction. We may disclose or transfer personal information in connection with a merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or part of our business or assets, including during negotiations.
• For legal reasons. We may disclose personal information to law enforcement, government authorities, courts, legal advisors, and others when we believe in good faith it is necessary to comply with law or legal process; to protect the rights, property, or safety of Partyhat, our users, or others; to enforce our agreements; or to detect, prevent, or address fraud, security, or technical issues.
• With your consent or at your direction. For example, with your permission we may publish your testimonial on our website.

Text messaging consent. We do not share your text messaging opt-in data or consent with any third parties for their marketing purposes. We share it only with the service providers that help us deliver text messages.

6. Cookies, Pixels, and Similar Technologies

We use cookies and similar technologies to:

• keep you logged in and remember your preferences (essential);
• understand how the Services are used and improve them, including through session replay (analytics); and
• measure our advertising and show you Partyhat ads on other sites and platforms (advertising).

You can manage non-essential cookies through the cookie settings available on our website, and through your browser settings. Blocking some cookies may affect how the Services work.

7. Your Choices

7.1 Email

You can unsubscribe from marketing emails using the link in any marketing email. We will still send you service-related emails, such as account, security, billing, and Campaign notices.

7.2 Text Messages

You can stop marketing text messages by replying STOP to any message. We may still send you service-related texts, such as verification codes, if you have requested them.

7.3 Analytics and Session Replay

You can opt out of analytics and session replay through our cookie settings. You can also opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

7.4 Targeted Advertising

You can opt out of the sale or sharing of your personal information for targeted advertising by clicking the "Do Not Sell or Share My Personal Information" link in the footer of our website, or by enabling the Global Privacy Control signal in your browser, which we honor as an opt-out request for that browser. You can also use:

• the Digital Advertising Alliance's opt-out tools at optout.aboutads.info and youradchoices.com/appchoices;
• the ad settings on your device (such as Apple's "Limit Ad Tracking" or Android's "Opt out of Ads Personalization"); and
• the ad settings within each social media platform.

Opting out does not mean you will stop seeing ads, only that they should not be based on your activity on our website.

7.5 Connected Accounts and Account Deletion

You can disconnect social media accounts and update your profile information in your account settings. You can delete your account in your account settings or by emailing privacy@partyhat.ai. Deleting your account does not delete Actions you posted on third-party platforms; you must remove those on the platform itself.

8. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information:

• Access / Know: to confirm whether we process your personal information and to obtain a copy of it, including the categories of information we collect, the sources, our purposes, and the categories of third parties to whom we disclose it;
• Correction: to correct inaccurate personal information;
• Deletion: to delete personal information we have collected from or about you;
• Portability: to receive your personal information in a portable, readily usable format;
• Opt Out: to opt out of the sale or sharing of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects (we do not engage in such profiling);
• Limit Use of Sensitive Personal Information: we collect account login credentials, which some laws treat as sensitive, but we use them only to provide the Services and keep your account secure, so this right does not apply to our current practices; and
• Appeal: to appeal our decision on your request.

How to make a request. Email privacy@partyhat.ai with the subject line "Privacy Request." To opt out of sale, sharing, or targeted advertising, use the methods in Section 7.4.

Verification. We will verify your request by matching information you provide with information we have, which may include asking you to confirm the email address on your account. We may deny a request if we cannot verify it.

Authorized agents. You may use an authorized agent to make a request on your behalf. We may require proof of the agent's authority and may ask you to verify your identity directly.

Appeals. If we deny your request, you may appeal by replying to our decision or emailing privacy@partyhat.ai with the subject line "Privacy Request Appeal." If you are not satisfied with the outcome of your appeal, you may contact your state attorney general.

Non-discrimination. We will not discriminate against you for exercising your privacy rights.

9. Notice to California Residents

This section supplements this Privacy Policy and applies to California residents under the California Consumer Privacy Act, as amended (the "CCPA").

Notice at collection. In the past 12 months, we have collected the following categories of personal information, from the sources described in Section 2, for the purposes described in Section 3:

We do not sell or share personal information for money. We do "sell" or "share" the categories noted above with advertising partners for targeted advertising, as those terms are defined in the CCPA. You can opt out as described in Section 7.4. We do not knowingly sell or share the personal information of consumers under 16.

Retention. We keep each category of personal information for the periods described in Section 11.

Shine the Light. We do not disclose personal information to third parties for their own direct marketing purposes as described in California Civil Code § 1798.83.

10. Children

The Services are not directed to, and may not be used by, anyone under 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will delete it. If you believe a minor has provided us personal information, contact privacy@partyhat.ai.

11. Retention

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, to comply with our legal, tax, and accounting obligations, to resolve disputes, and to enforce our agreements. In general:

• Account and profile information is kept while your account is active and deleted or de-identified within 90 days after you delete your account, except as needed for the purposes above.
• Submissions and Campaign records are kept for the life of the Campaign and up to 24 months after it ends, so that Brands can review results and we can resolve disputes and enforce our Terms.
• Brand billing records are kept as long as required by tax and accounting law (generally up to 7 years).
• Analytics and session replay data are kept according to our providers' retention settings, generally no more than 13 months.

When we no longer need personal information, we delete or de-identify it. If that is not immediately possible (for example, because it is stored in backups), we securely store it and isolate it from further use until it can be deleted.

12. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no system is completely secure, and we cannot guarantee the security of your personal information.

13. Data Location

We are based in the United States, and we store and process personal information in the United States. The Services are intended for use in the United States.

14. Third-Party Platforms and Websites

The Services link to, and depend on, third-party social media and review platforms and other websites that we do not control. Anything you post on those platforms, including Actions you take in Campaigns, is public according to your settings there and is governed by that platform's privacy policy, not this one. Please review the privacy settings and policies of every platform you use.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date above. If we make material changes, we will notify you by email or through the Services before the changes take effect.

16. Contact Us

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

Partyhat Technologies Inc. Attn: Privacy 1401 Pennsylvania Avenue, Suite 105 Wilmington, DE 19806 privacy@partyhat.ai