Disparate Labs, Inc. Privacy Policy

Disparate Labs, Inc. Privacy Policy

Effective Date: April 1, 2026

Applicability

This Privacy Policy describes how Disparate Labs, Inc., its subsidiaries and affiliates treat customer personal information on the websites, social media and applications, our data processing platform product and services (DL-Platform) in the usual course of business. This policy also applies to our events, sales and marketing activities (collectively, the “Services”). It also contains information about your choices and privacy rights.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with additional information regarding your rights with respect to your personal information. This information is described in our Privacy Notice to California Residents.

The Services

We provide the Services to our customers and users (collectively, “Customers”) under an agreement with them and solely for their benefit and the benefit of their personnel authorized to access and use the DL-Platform (“Authorized Users”). Our processing of Authorized User data is governed by our agreement with the relevant Customer. This Privacy Notice does not apply to (i) the data that our Customers and their Authorized Users upload, submit or otherwise make available to the DL-Platform and other data that we process on their behalf, as defined in our agreement with the Customer; (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notice;
If you have any questions about specific DL-Platform settings and privacy practices, please contact Disparate Labs’ team at legal@disparatelabs.ai

Information Collection

We collect information from and about you.

We collect various types of information from you, as described below. Described below by category is the information we may collect.

We collect contact information. For example, we collect personal identification data, online or in person, among other purposes, to manage your registration as a user, to manage your subscription of products or services, to respond to your queries, and, if you wish, to send you our customized newsletters or other information including name, mailing address, email addresses and phone numbers. If you register as a user, we will also have you create a password. In some cases, we may share this information for the purpose noted above.

We collect payment information. If you buy products or services we (or its payment processors) will collect the relevant data as your credit card number and/or bank information, billing address, to manage payment of the products or services that you purchase, regardless of the method of payment used.

We collect information you submit online. This includes information you post when you interact with us on social media or the DL-Platform. In some cases, we may share this information for the purpose noted above.

We collect information about your device and location. We collect the type of device you use and location to access our DL-Platform, including the access and use of the Wi-Fi that we make available to our customers at our stores. We also collect information about the type of browser you are using. And, we may look at what site you came from or what site you go to when you leave us. If you are using our apps, we may also collect your device identification number or the advertising ID. If you use our app, we may look at how often you use the app and where you downloaded it. We also may process your location and contact information. In some cases, we may share this information for the purpose noted above.

We collect information about your use of the DL-Platform. When an authorized user interacts with the DL-Platform, metadata is generated that provides additional context about the way authorized users work. For example, Company may log browsing activity, how you interact with our websites and mobile apps, the products that you buy, and search terms entered. and what Third Party Services are used (if any). In some cases, we may share this information for the purpose noted above.

We do not use or disclose sensitive personal information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as required by law.

We use information as disclosed and described here

When using our Services, we may collect certain information, such as:

  • Identifiers: We collect your name, email address, phone number, postal address and country to administer your account and provide our Services to you;
  • Professional/Employment-related information: We also collect information about your job title, role and company name;
  • Account information: If you create an account on the Services, we will collect your authentication information used to access the Services;
  • Customer service and other interaction information: We will collect information when you interact and communicate with us, for example, when you request information about our Services, interact with our sales team or contact customer support, complete a survey, provide feedback or post comments, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you disclose during the course of such communications (which may be stored as an audio file or a transcript);
  • Commercial information: We keep records of your history of past purchases and transactions with us.

We use information for sales and marketing purposes. We may record video or phone calls for training and coaching purposes, quality assurance and administration (in accordance with applicable laws), including to analyze sales calls using analytics tools to gain better insights into our interactions with customers;

We use information to improve the Service to you. We may use your information or data to make our Service or products to you better. We may also use your information to customize your experience with us. This includes understanding your interests and preferences.

We use your information to respond to your requests. This includes responding to customer inquiries.

We use your information to communicate with you about our relationship. We may communicate with you about your account or our relationship. This includes electronic messages (as SMS or push notifications) and calls about order status. We may also contact you about this Policy or our Terms & Conditions.

We use your information for marketing purposes. We may provide you with information about new products and special offers. We may also serve you ads, personalized or not, about products and offers. We might tell you about new features or updates.

We use information for security and fraud prevention purposes. We may use your information to protect our company and our customers. We also use information to protect our websites and apps.

We use information as otherwise permitted by law or as we may notify you.

We collect information from you in different ways

We collect information directly from you, online or offline. This includes when you create an account or to manage your purchases of products or services. We also collect information if you contact customer service to respond to your queries or sign up for our newsletter to send you our customized communications. We also collect information when you take a survey or participate in a promotion.

We collect information posted in public forums. Certain features of our Services make it possible for you to post content publicly or viewable by other users, such as through the Disparate Labs Community or through other public forums. Any information you post openly in these ways will be available for viewing and use by other users of these Services, as well as Disparate Labs, and potentially accessible through third-party search engines. Accordingly, please take care when using these features and do not provide personal information that you would not want made available in these ways.

We collect information passively. We use tracking tools like browser cookies and web beacons. To learn more about cookies visit our Cookie policy here. We use these tools on our websites and in emails we send to you. We may also use these tools in our mobile apps. We collect information about users over time when you use our DL-Platform. We have third parties who collect information this way as well.

We get information about you from third parties. This includes social media related to the DL-Platform. We may receive information about you from other sources.

We combine information we collect from different sources

We combine offline and online information. We also combine information across multiple devices. We also combine information we get from a third party with information we already have about you.

We disclose information as described here

We may provide information with our affiliated organizations and parent company. We may share information with our affiliated organizations or parent company related to billing, admin data only. You, and only you, can provide access to any of our affiliated organizations, or parent company to perform specific services you may have contracted with such affiliated organizations or parent company through the DL-Platform. We take yours and your customer data protection very serious and we do not provide such access or share such data.

We may disclose information with third parties who perform services for us. We share information with payment processors. We also share information with advertising and marketing service providers that, for example send emails on our behalf.

We may transfer information with any successor to all our part of our business. For example, if Disparate Labs were sold we may give a customer list as part of that transaction.

We will disclose information if we think we have to in order to comply with the law or to protect ourselves. This could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests.

We may disclose information for other reasons we may describe to you.

Additional information for residents of certain jurisdictions. In certain countries and states in the Unites States of America like the states of California, Nevada, and Virginia require that we tell you if we sell personal information with a third party for monetary or (in California) other valuable consideration. We do not do this. We also do not sell personal information of any age for monetary or other valuable consideration.

You have certain choices about how we use your information

You can opt out of receiving our marketing emails. To stop receiving our promotional emails follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.

Our Cookie Policy

DL-Platform uses cookies and similar technologies in its Websites and Services to help us collect other Information.

The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.

You can control cookies and tracking tools. Your browser may give you the ability to control cookies or other tracking tools.

You can control tools on your mobile devices. For example, you can turn off the Bluetooth, GPS locator, push notifications or your advertising ID in your phone settings.

 See our full Cookie Policy here

Your Privacy Rights

If you live in the state of California or Virginia in the United States of America or a country or other state with similar rights, you have legal rights in addition to the choices listed above. You can email us at legal@disparatelabs.ai Those rights are listed below:

  1. Access: to learn the categories of information we collect and use, and for those in the state of the categories of sources of collection and disclosure and the business purpose for collection;
  2. Portability: a copy of (Virginia) or specific pieces of (California) personal information collected;
  3. Deletion: to have us delete information we collected from you;
  4. Correction: asking us to f ix your information; and
  5. Non-retaliation: not to be discriminated against for exercising a privacy

How it works: When you submit your request, we use information you provide to verify your request. We do this by matching the information you provide with information we already have about you. In some situations we may not be able to process your request. This may include if a legal exception applies. If you disagree with our decision you can contact us as described at the end of this policy.

Nevada residents: you may also opt out of the future sale of their information to a third party so that they may license or sell that information by emailing us at noted at the end of this notice.

Third party agents: If you are submitting a request on behalf of an eligible resident, we may ask for additional information to verify your identity. This may include providing proof that you are registered with the Secretary of State to act on someone’s behalf or proof of a power of attorney. You may also submit a copy of the consumer’s signed permission to submit the specific request.

Notice of Right to Opt-out: you may opt out at any time by managing your cookie preferences as you enter the         DL-Platform.

We use reasonable security measures

The Internet is not 100% secure. We cannot promise that your use of our DL-Platform will be completely safe. We encourage you to use caution when using the Internet. A username and a password are needed to access the DL-Platform. It is your responsibility to protect your username and password.

We may link to DL-Platform or have third party tools on our DL-Platform that we do not control

If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices of third parties. We suggest that you read their privacy policies carefully.

You can contact us if you have questions

If you have additional questions about our privacy practices you can email us at legal@disparatelabs.ai

We may change this policy

From time to time, we may change our privacy policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our DL-Platform. Please check our DL-Platform periodically for updates.

Privacy Notice for California Residents

Last updated: April 1, 2026

We provide the following information to California residents pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This information supplements our general above. For a description of all of our data collection, use and disclosure practices, please read our Privacy Notice in its entirety. Terms that are capitalized but not defined below have the meanings set forth in our Privacy Notice.

Categories of Personal Information

Below, we describe the categories of Personal Information (as defined in the CCPA), that we have collected within the preceding 12 months and may collect on a going-forward basis:

  • Identifiers
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, address, email address)
  • Characteristics of protected classifications under California or federal law
  • Commercial information (e.g., transaction data)
  • Internet or other similar network activity
  • Geolocation data (e.g., general location derived from an IP address)
  • Sensory data (e.g., audio, video)
  • Professional or employment-related information
  • Education information
  • Inferences drawn from the preceding categories of Personal Information

Within these categories of Personal Information, we may also collect the following categories of Sensitive Personal Information (as defined in the CCPA): Account log-in, financial account, debit card, or credit card number, in combination with any required security or access codes, password, or credentials allowing access to the account

Categories of Recipients of Personal Information

For each category of Personal Information (including Sensitive Personal Information) listed above, we disclose this information as described in the “We disclose information as described here” section of our Privacy Notice (which also contains information about the categories of service providers to which we may disclose your Personal Information). In addition, we disclose Identifiers and Internet or other similar network activity to advertising providers that tailor online ads to your interests based on information they collect about your online activity (known as interest-based advertising).

Sources of Personal Information

We obtain the categories of Personal Information listed above directly from you or from devices on which you use our Disparate Labs Services, as well as from the following categories of sources: our corporate affiliates, publicly-available databases, third-party business partners, social media sites, and other third-party sources, and as described in our “We collect information from and about you” section of the Privacy Notice.

 

Purposes for Which We Use Personal Information

We use Personal Information for a variety of business and commercial purposes, as described in the “We disclose information as described here” section of our Privacy Notice, which is linked above.

Retention Period Criteria

Disparate Labs retains the Personal Information described above for as long as you use our Disparate Labs Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in our Privacy Notice (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.

CCPA Rights and Requests

You may make the following types of requests under the CCPA with respect to Personal Information that we process on our own behalf. Note: If you wish to make a CCPA request with respect to Personal Information submitted through or otherwise made available to the Platform Services, please direct your request to the relevant Customer directly, as that data is governed by the terms of our agreement with our Customer.

Requests to Know, Correct, and Delete: You may request:

(i) Access to a copy of the specific pieces of Personal Information that we have collected about you;

(ii) Correction of Personal Information that we maintain about you, if it is inaccurate; and/or

(iii) Deletion of Personal Information, subject to certain exceptions.

You can submit a request online by filling out a request email to legal@disparatelabs.ai . We will respond to your request consistent with the CCPA, and subject to any exceptions that may apply under the CCPA. We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.

Requests to Opt-Out of Sale or Sharing: You also may opt out of the “sale” or “sharing” of your Personal Information, as “sale” and “sharing” are defined under CCPA.

We do not sell Personal Information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “sale” and “sharing” under the CCPA may include the disclosure of your information to certain types of advertising and marketing partners, we provide California residents with the right to opt-out of any such sale or sharing of their Personal Information. As noted above, we may disclose or make available Identifiers or Internet or other similar activity to advertising partners. We allow you to opt out of such disclosures, as they may constitute “sale” or “sharing” as defined under the CCPA. We do not knowingly “sell” or “share” the Personal Information of individuals under 18 years of age.

You may opt-out of the Sale or Sharing of Personal Information (such as for purposes of online analytics and advertising). To opt out based on cookies and similar online identifiers, visit the “Your Privacy Choices” link in our website footer or enable an opt-out preference signal (such as the Global Privacy Control), which we also recognize as required by the CCPA. To opt out based on other identifiers (such as your email address), please email legal@disparatelabs.ai.

Authorized Agents

To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent.

If you are making a Request to Know, Correct, or Delete on behalf of a California resident and have not provided us with a qualifying power of attorney from the resident, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the request.

Nondiscrimination

You have the right to be free from unlawful discriminatory/retaliatory treatment for exercising any of your CCPA rights.

California Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request, on a yearly basis, information about our disclosure of certain categories of “personal information” (as defined in the Shine the Light law) with third parties for their “direct marketing purposes” (as defined in the Shine the Light law), or in the alternative, that we maintain a policy of providing a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes. If you want to opt out of activities that are considered “sales” or “sharing” under the California CCPA, please see the “Requests to Opt-Out of Sale or Sharing” section above, which provides a cost-free mechanism for doing so.