Warmly's Privacy Policy


These terms were last updated on March 7, 2023.

Welcome to the Privacy Policy of Warmly, Inc. ("Warmly", "we", "us", or "our"). Warmly operates the https://warmly.ai, and https://getwarmly.com websites and provides the services described below.

As a data-driven company, we care deeply about privacy and data security. We may update this Privacy Policy from time to time. If we do, we will update the "last updated" date at the top of the page. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

See the State law privacy rights section for important information about the personal information we collect about California residents and their privacy rights.

What does this Privacy Policy apply to?

This Privacy Policy applies to our websites: https://www.warmly.ai, https://getwarmly.com, and all sub-domains (collectively the “Site”), all software (including integrations with third-party software) and services we offer through our Site (“Services”), and email, text, or other electronic messages between you and us. It applies to any information that relates to an identifiable individual (“Personal Information”), which we describe in more detail below. This Privacy Policy does not apply to information collected on sites, applications, destinations, or services linked to from our Site that are not operated or offered by Warmly. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we treat it. By accessing or using the Site and/or the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not want your Personal Information to be processed as described in this Privacy Policy, please do not use our Site or our Services. Note to Enterprise Customers: If you are an enterprise customer of Warmly and wish to enter into a separate data processing agreement with Warmly in order to comply with your obligations under applicable data protection laws, please contact us at [email protected].

Calendar Services: Control Over Your Calendar Information

This section applies only to Warmly’s Calendar Services. 

You may control Warmly’s access to your calendar information through your Google or Microsoft account settings. For Warmly Enterprise Accounts, access controls are available in the Enterprise administrator portal. Additional information about such controls, please see the Warmly Privacy Policy- Calendar Supplement as well as the Access, Correction and Deletion of Information We Collect section below. 

If you reject the invitation to join Warmly, please refer to the Do Not Sell/Do Not Share section of our Privacy Policy to learn how to request the removal of your information via this link: https://warmly.ai/p/removal.

Contact Us

If you wish to ask us any questions about this policy, or to exercise any of your rights described in this Privacy Policy, you can email us at [email protected]

Collection and Use

We use the information described in this subsection for the purposes identified below, including without limitation auditing, security, debugging, internal research and development, maintaining the quality and safety of our Services, and service performance purposes. For example, we use information to measure web traffic and usage activity on our Site for purposes of improving and enhancing the functionality of our Site, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Site. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages on our Site. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technology to identify the fact that you have visited our Site or seen one of our advertisements.

Information we collect directly from you

We collect Personal Information you provide to us:

- Registration and profile and virtual business card information.
When you register for an account, we collect your username, password and email address. Once you register for an account, you may also be able to create a profile and virtual business card that other users can see. Your profile and virtual business card may include information you choose to add such as your profile photo, job title and other work-related information, your approximate location, links to your profiles on various social networks, and other preferences and information. We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account, the Service, and for customer support purposes.

- Billing information. If you make a payment to Warmly, we require you to provide your billing details, such as a name, address, email address and, in some instances, financial information corresponding to your selected method of payment. If you provide a billing address, we will regard that as the location of the account holder.

- Account settings. You can set various preferences and personal details on pages like your account settings page.

- Calendar Information. We offer enhanced functionality to users who opt in to providing us with access to their calendar application, as described in more detail in the Warmly Privacy Policy – Calendar Supplement. Please note that our enterprise customers may choose to permit or restrict calendar integration access at the enterprise level. Please contact [email protected] for more information. 

- CRM information. We offer enhanced functionality to organizations who opt in to providing us with access to their CRM Application. Please note that our enterprise customers may choose to permit or restrict CRM integration access at the enterprise level. Please contact [email protected] for more information.

- Feedback or Contact Us. When you provide us feedback or contact us via email, other electronic communications, or our Site, we will collect your name and email address, as well as any other content included in your communication, in order to send you a reply and to act on the feedback or information you have provided to us.

- Support. We also collect other types of Personal Information that you provide to us voluntarily, such as any information you provide to us if you contact us regarding support for our Services in order for us to respond to your support request or provide to us in person at an event (either manually or electronically).

- Other data you intentionally share. We also collect Personal Information at such other points on our Services that state that Personal Information is being collected so that we may provide the features or functionality for which we collected the Personal Information and for other purposes described in this Privacy Policy. We may also collect your Personal Information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial.

- Linking Information. To the extent we are able to do so, we may link your non-personally identifiable information with your personally identifiable information and we may also link information collected online with information we collect offline or information collected online by third parties.Information we collect about you indirectly or passively when you interact with us- Usage data. We collect usage data about you whenever you interact with our Services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps. Personal Information gathered through tracking technologies may include internet or other electronic network activity information for the purposes of cross-device tracking for targeted advertising, the date and time of visits, the pages viewed, links to/from any page, and time spent at a site.

- Device data. We collect data from the device and application you use to access our Services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.

- Referral data. If you arrive at our Site from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

- Cookies. Like many online services, we and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs. We also use or may use the data collected through cookies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) provide and monitor the effectiveness of our Services; (c) monitor online usage and activities of our Services; (d) diagnose errors and problems with our Services; (e) otherwise plan for and enhance our Services; and (f) facilitate the purposes identified in the “How We Use the Personal Information We Collect” section below. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.  Please note that we link some of the Personal Information we collect through cookies with the other Personal Information that we collect about you and for the purposes described in this Privacy Policy. You may consider visiting aboutcookies.org, which provides helpful information about cookies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using our online Services, as some features and services on our online Services may not work properly.  Depending on your device and operating system, you may not be able to delete or block all cookies.  In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.  You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

- Web Beacons (tracking pixels). Web beacons (also known as tracking pixels) are bits of data that count the number of users who access a website or open an email and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. We also use web beacons to learn if you have clicked on any links contained in emails. We may use this information to help us identify which emails are more interesting to you.

- Information from third parties. We may collect your Personal Information or data from third parties if you give permission to those third parties to share your information with us. For example, you have the option of registering and signing into Warmly with a third- party authentication provider. If you do this, the authentication of your logon details is handled by that third-party authenticator.- Single Sign-On. We may use single sign-on ("SSO") to allow a user to authenticate their account using one set of login information, including through Google. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, language preference, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, customer support, changes, or updates to features of the Site, technical and security notices).

- Social Media. When you interact with our Site through various social media, such as when you click on the social media icon on the Site, follow us on a social media Site, or post a comment to one of our pages, we may receive information from the social network such as your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

- Information from Other Sources. We may obtain information from other sources, including through publicly available sources, third-party information providers, customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

‍- Analytics Services. We use third-party analytics services, such as Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies to collect information such as how often users visit the Services, what pages they visit, and what other sites they used prior to coming to the Services. We use the information we get from Google Analytics only to improve our Services. We do not combine the information generated through the use of Google Analytics with other Personal Information you may provide to us from time to time. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Services, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You may also download the Google Analytics opt-out browser add on, available at https://tools.google.com/dlpage/gaoptout.

How We Use The Personal Information We Collect

In addition to the uses described above, we may use the information we collect from you:

- to provide Services to you; including enriching information for your meetings and displaying your network;
- to operate and improve our Services and products;
- to understand you and your preferences to enhance your experience and enjoyment using our Services;
- to improve the content of our Site or our Services;
- to customize the content and layout of our Site or our Services for individual users;
- to respond to your comments and questions and provide customer service;
- to provide and deliver products and services you request;
- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- to send you targeted messages about new contests, promotions, rewards, upcoming events, and other news about products and services offered by us;
- to use third-party service providers to send and distribute e-mail and to perform other marketing and support functions on our behalf or otherwise to assist us in providing our Services to you;
- to link or combine it with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;-for our own business and commercial purposes;
- for identity management, security, and auditing;
- for any other purpose for which you provide it; or
- in any other way we may describe when you provide the information.

We may create anonymized data (data that is not associated with or linked to your personally identifiable information) records from Personal Information by excluding information (such as your name, email address, personal identification numbers) that makes the data personally identifiable to you. We use this anonymized data to analyze request and usage patterns so that we may enhance the content of our Services and improve Services navigation. We reserve the right to use anonymized data for any purpose and to disclose anonymized data to third parties in our sole discretion.

Sharing and Transfers

Except as disclosed in this Privacy Policy, we do not share, rent, or sell Personal Information you have given us to any third party. This section describes the subset of Personal Information we share with partners, customers, and service providers, or for legal, corporate, or compliance purposes.

Service Providers and Similar Third Parties

We may provide your Personal Information to service providers or contractors to perform functions on our behalf, including, but not limited to, communicating news; web hosting; information technology and related infrastructure (such as cloud computing); performing Site or Services development or maintenance; providing functionality or other services for our Site and our Services; security and other auditing; sending postal mail, email or other communications; customer service; removing outdated and repetitive information from our lists; analyzing our data; developing, enhancing, marketing or providing any of our Services; processing payments; order fulfillment; or assisting us with other marketing and support functions. These third party providers are required not to use your Personal Information other than to provide the services requested by us.

Other Sharing

We may also disclose your Personal Information:
- to a person who in our reasonable judgment is seeking the information as an agent of the individual or company;
- if, in our reasonable judgment, it is necessary enforce compliance with our internal policies, terms of use, or the agreement for our Services;
- to protect the rights, property, and safety of Warmly and our agents, customers, or others;
- in situations where sharing or disclosing your information is required in order to provide you with information that you have requested;
- in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena;
- in response to a law enforcement agency’s request;
- to comply with applicable law;
- in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company;
- to another entity as part of a merger, bankruptcy, insolvency, receivership, a sale of assets or all or part of a business, or any other corporate change or re-organization; or
- to a third party or parties, where you consent to such disclosure or disclosure is required or permitted by law.

We may also share Personal Information with our Enterprise Customers as part of the Services we provide to them. During the course of our business we may also share with third parties aggregated demographic and/or statistical information that is not personally identifiable.

Third-Party Data Collection and Online Advertising

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history.  We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on the Services, on other websites, or services you may use, and on other devices you may use.  Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”), which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information.  We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices.  We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.  We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms.  We may do this by providing a hashed version of your email address or other information to the platform provider.  

Social Media Widgets and Advertising.  The Services may include social media features, such as LinkedIn, Twitter, YouTube or other widgets.  These social media companies may recognize you and collect information about your visit to the Services, and they may set a cookie or employ other tracking technologies.  Your interactions with those features are governed by the privacy policies of those companies.We display targeted advertising to you through social media platforms, such as Twitter, LinkedIn,  and other social media forums.  These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in the Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics.  We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform.  These advertisements are governed by the privacy policies of those social media companies that provide them.  If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.  You may learn more about advertising preferences by clicking on the links provided below.  Please note that these links are provided for your convenience only and we do not control the content or features that may be available on these third-party services.We may also utilize certain forms of display advertising and other advanced features through Google Analytics.  These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting the Network Advertising Initiative’s (NAI) online resources at http://www.networkadvertising.org/choices.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at  www.google.com/policies/privacy/partners/.  You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA).  This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes.  More information about these Principles can be found at www.aboutads.info.  If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements.   Opt-out cookies only work on the internet browser and device they are downloaded onto.  If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use.  If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

For California, Colorado, Connecticut, Nevada, Utah, and Virginia Residents: To exercise your right to opt-out of the sale of sharing of Personal Information as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please see the “Your Privacy Choices” section of our U.S. State Privacy Disclosures.

Protection of Information

Warmly considers the security of all the information and data within our control to be a top priority, and consistent with this we implement commercially reasonable technical and organizational safeguards to protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, such information or data. However, no security system is impenetrable, and unanticipated system failures or the efforts of malicious actors are an unfortunate reality on the internet. Therefore, we cannot guarantee that the information and data within our control, including Personal Information, is absolutely secure.

Our Policy Towards Children

Warmly does not direct our services towards individuals under the age of 18. We do not knowingly collect Personal Information from individuals under the age of 18. If we become aware that we have collected Personal Information from individuals under the age of 18, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If you become aware that Warmly has improperly collected information from individuals under the age of 18, please contact us immediately at [email protected].

Additional Notice to Residents of the European Economic Area (EEA) and Switzerland

Legal Bases for Collection and Processing of Information as ControllerOur collection and processing of your Personal Information is supported by a number of legal bases. Set out below are the most relevant ones. Please note that while we may rely on one legal basis for a particular activity, if that is no longer applicable or available then we may be able to rely on another basis.

With Your Consent. We collect and process some of your Personal Information because we obtain your consent. When we want to use cookies to collect Personal Information from you for performance or marketing reasons, for example, we obtain your consent by displaying a banner when you first visit our Site (or, if you have deleted your cookies, when you next visit) that discloses the reasons we use cookies to collect information and links to this Privacy Policy which in turn contains more detailed information about our collection, third-party collection, and opt-out information. You must accept the use of those cookies or you may not visit or use our Site.

To Fulfill a Contract. We collect and process some of your Personal Information because we need to do so either to enter into or fulfill a contract we have with you. For example, we process your Personal Information when we provide Services to you that you have purchased on our Site.

For a Legitimate Interest. We may process your Personal Information where we or a third party have a legitimate interest in doing so. For example, we have a legitimate interest in understanding how people are using our Services, both to improve them and to market them more effectively. Therefore, we may use your Personal Information to understand and analyze your use of our Services. When we rely on our legitimate interest, we will carry out a balancing test between our legitimate interests and your privacy rights. Our legitimate interests include: understanding how our audience interacts with our content, our marketing and promotions, and our Services; learning about our audience in order to improve our Services for them; developing, delivering, and maintaining relevant and engaging content and promotional information; supporting the dissemination of information on topics of interest to individuals and the community; supporting individuals’ rights to receive information; and conducting our business activities and achieving our business goals.

To Comply with Legal Obligations. We will process your Personal Information when necessary to comply with legal and regulatory obligations or defend claims. For example, we may share your Personal Information in response to a court order, subpoena, or law enforcement agency's request.Retention of InformationWe will only keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it (and whether we can achieve those purposes through other means), and the applicable legal requirements. In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.

Upon expiration of the applicable retention period we will securely destroy your Personal Information in accordance with applicable laws and regulations.

Access, Correction and Deletion of Information We Collect

For Personal Information that we hold about you, you may have the right (subject to exceptions allowed by law) to:
- request access to your Personal Information;
- request we correct any inaccurate Personal Information;
- request we delete any Personal Information;
- restrict the processing of Personal Information;
- object to the processing of Personal Information; and/or
- receive a copy of your Personal Information in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. 

Modifying Profile and Virtual Business Card Information. If you have an account for our Service, you have the ability to modify certain information in your profile/virtual business card (e.g., your contact information) through the account setting page or a similar option provided on the Service. If you have any questions about modifying or updating any information in your account, please contact us at the email address provided below. 

Modifying Service Data. If your personal information has been added to the Services by another Customer (for example when they integrate their Calendar contacts with our Services), please contact the Customer that provided your personal information if you would like to access, correct, or delete your personal information, restrict or object to the processing of your personal information, or receive a copy of your personal information. We will work with the Customer on whose behalf we store, use, or process your personal information to respond to your request within a reasonable time.

Email Communications. From time to time, we may send you emails regarding updates to our Service, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Transfer of Information

We are located in the United States and your Personal Information that we collect is processed and stored in the United States. We rely on derogations for specific situations as set forth in Article 49 of the General Data Protection Regulation (“GDPR”) and on contractual clauses in our agreements. In particular, we collect and transfer to the United States Personal Information with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Given the lack of a finding of “adequacy”, there may be a risk that the supervisory authority and/or data processing principles and/or data subject rights in the United States might not be sufficiently appropriate or comprehensive safeguards from the perspective of the EU. We strive, however, to apply suitable safeguards to protect the privacy and security of your Personal Information and only to use it consistent with your relationship with us and the practices described in this Privacy Notice. Our vendors and others with whom we share your Personal Information in accordance with this Policy are either certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks or we use contractual clauses in our agreements with them that are designed to protect the privacy and security of your Personal Information.

Additional U.S. State Privacy Disclosures

These Additional U.S. State Privacy Disclosures (the “Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our Personal Information processing practices relating to individual residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia. For a detailed description of how we collect, use, disclose, and otherwise process Personal Information in connection with our Services, please visit our Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these disclosures.

Definition of “Personal Information”

As used in these Disclosures, the term “Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, or would otherwise qualify as “Personal Data” or “Personal Information” under U.S. State Privacy Laws (“Personal Information”).

“Personal information” does not include:

-De-identified or aggregated consumer information,
-Publicly available information from government records,
-Information excluded from the scope of the individual U.S. State Privacy Laws including, but not limited to, Personal Information covered by sector-specific privacy laws like the Fair Credit Reporting Act, the Graham-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994, and

-Health or medical information covered by the Health Insurance Portability Accountability Act, the California Confidentiality of Medical Information Act or clinical trial data.


Sales, Sharing or Targeted Advertising
As further described in the “Third-Party Data Collection and Online Advertising” section of our Privacy Policy, we may sell or share your Personal Information (as those terms are defined by U.S. State Privacy Laws), subject to your right to opt out of such sales and sharing (see “Your Privacy Choices” below). We do not sell or share the Personal Information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Sensitive InformationThe following Personal Information elements we collect may be classified as “sensitive” under certain U.S. State Privacy Laws (“sensitive information”): account log-in in combination with any required security or access code, password or credentials allowing access to the account. We use this sensitive information for the purposes set forth in our Privacy Policy. We do not use or disclose sensitive information for any purpose other than for what would reasonably be expected in connection with the Services, for detecting security incidents, fraud and other illegal actions, or for short term transient use. We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.  

Deidentified InformationWe may at times receive, or process Personal Information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.


Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know
The right to confirm whether we are processing Personal Information about you and, under California law only, to obtain certain personalized details about the Personal Information we have collected about you, including:

-The categories of Personal Information collected;The categories of sources of the Personal Information;
-The purposes for which the Personal Information were collected;The categories of Personal Information disclosed to third parties (if any), and the categories of recipients to whom this Personal Information were disclosed;
-The categories of Personal Information sold (if any), and the categories of third parties to whom the Personal Information were sold; and
-The categories of Personal Information shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Information were disclosed for these purposes.

The Right to Access & Portability
The right to obtain access to the Personal Information we have collected about you and, where required by law, the right to obtain a copy of the Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction
The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

The Right to Request Deletion
The right to request the deletion of Personal Information that we maintain about you, subject to certain exceptions.

The Right to Opt Out of Sales or Sharing for Targeted Advertising Purposes
The right to direct us not to sell or share Personal Information for certain targeted or cross-context behavioral advertising purposes.

The Right to Control Over Sensitive Information
The right to exercise control over the use and disclosure of certain sensitive information.

The Right to Non-Discrimination
The right not to receive retaliatory or discriminatory treatment for exercising any of the rights described above.However, please note that if the exercise of the rights described above limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.In addition, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests
You can submit a request to exercise one of the privacy rights identified above by:
Filling out our online form; or
-Emailing us at
[email protected]

We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) before processing your request.  In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include your email address. Although we try to limit the Personal Information collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional Personal Information from you.  In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of rights described above. To the extent prohibited by U.S. State Privacy Laws, if you exercise one of these rights we will not:
-Deny you goods or services.
-Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
-Provide you a different level or quality of goods or services.
-Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To Exercise the Right to Opt Out of the Selling or Sharing of Personal Information for Targeted Advertising Purposes

Unless you have exercised your Right to Opt Out, we have sold or may sell in the future, Identifiers (such as your name, email address and contact information), Commercial Information (such as products purchased or considered), Internet/Network Information (such as analytics data), and Inferences (generated from your interactions with our services) to third parties who may use this information to communicate with you or to offer you products and services that may be of interest to you.

We may also sell or share Personal Information (including Identifiers, Commercial Information, Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We may also sell Identifiers and Commercial Information to our Enterprise Customers and our Business Partners.

The third parties to whom we sell or share Personal Information may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.

You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional Personal Information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use Personal Information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, click the cookie icon on the bottom of our warmly.ai site here.

For Non-Cookie-Based Opt-Outs: You may submit a request by emailing [email protected] or by filling out our online form, available at the following link: https://warmly.ai/p/consumer-rights-request


Authorized Agents
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request. 

Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at [email protected] with the subject line, “Privacy Request Appeal.” 

Minors Under Age 16
We do not sell Personal Information of consumers we know to be less than 16 years of age unless they have opted in (“Right to Opt In”). Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.


The following disclosures only apply to residents of the State of California.

California Categories of Personal Information
California law requires we provide disclosures to you about what Personal Information we collect by reference to the enumerated categories of Personal Information set forth within the California Consumer Privacy Act, as amended (“CCPA”). To address this obligation, we have identified below the relevant enumerated CCPA Personal Information category for the Personal Information, sources and purposes described in our Privacy Policy.

A. Identifiers (examples: real name, postal address, internet protocol address, email address, driver’s license number)

Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (examples: name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.)

Categories of Sources
- You, your agent, or our Customers
- Social Media sites and other third-party sources

C. Characteristics of protected classifications under California or federal law (examples: Age (40 years or older), race, color, religion, marital status, sex)

Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources

D. Commercial information (Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources

F. Internet or other similar network activity (examples: browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)

Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources

I. Professional or employment-related information (examples: employment history. Some Personal Information included in this category may overlap with other categories.)

Categories of Sources
- You or our Customers
- Social Media sites and other third-party sources

All Personal Information collected by us under the various categories listed above is collected for a variety of business purposes as set forth below.

Business Purposes for collection of all categories of Personal Information:
- to provide Services which you have requested from us- to verify your identity- to fulfill or meet the reason for which the information is provided
- to process payments
- to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits
- to improve the content of our Sites or Services, to enhance users’ experiences when visiting our Sites or using our Services, and to customize the content and layout of Sites for each individual user
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
- For testing, research, analysis and product development
- As necessary or appropriate to protect the rights, property or safety of us, our Customers or others
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, or any other transaction in which Personal Information held by us is among the assets transferred or constitutes relevant information for evaluation of the transaction
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA 

How We Sell, Share, and Disclose Personal Information

As described in the Sharing and Transfers section of our Privacy Policy, we disclose Personal Information with a variety of third parties for business purposes or we may sell your Personal Information or share your Personal Information to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see the “Your Privacy Choices” section above). 

In the preceding twelve (12) months, disclosed to third parties the following categories of Personal Information for a business purpose:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category C: Characteristics of protected classifications under California or federal law (age)

We have disclosed Personal Information for a business purpose to the following categories of third parties in the past 12 months:
• Our Customers
• Service providers
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with Services we provide to youIn the preceding twelve (12) months, we have sold or shared for targeted advertising purposes the following categories of personal information:

Category A: Identifiers
Category D: Commercial Information
Category F: Internet or other similar network activity

We have sold or shared personal information for targeted advertising purposes to the following categories of third parties in the preceding 12 months: • Third-party ad networks, social networks and advertising and analytics partners (to deliver targeted advertising and related analytics services)
• Our Business Partners, such as data providers who supplement Personal Information we provide them with additional information relating to the same individuals

Shine the Light

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at [email protected]

If you have any questions that this Privacy Policy could not answer, please contact us at [email protected]