Privacy Policy

Scope of this Privacy Statement and our role

Switch Holdings, LLC ("switchbooks", "we", "us", or "our") responsibly leverages technology to power prosperity for businesses. We believe that everyone has a right to privacy. As a financial services and technology company, we're providing this Global Privacy Statement ("Privacy Statement") to explain how we collect, use, share, or otherwise process information that we collect through our services. These services include, as applicable, our websites, mobile applications, social media pages, marketing activities, and other activities described in this Privacy Statement, or when other businesses provide us your personal information (collectively, the "Services").

This Privacy Statement describes our privacy practices when we process personal information for the purposes of providing the benefits of our websites and the switchbooks platform, which includes all of switchbooks' services, sites, experiences and software (including through our mobile applications and desktop applications) (the "switchbooks Platform").

switchbooks determines the purposes and means of the processing of your personal information as described in this Privacy Statement, and therefore acts as a 'data controller' (or equivalent/similar terms under applicable data privacy laws) of such information.

In certain circumstances, there may be more than one data controller processing your personal information. For example, your employer or a financial partner may also act as a data controller. In these situations, we act as an independent data controller over our processing activities. This means we determine how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable data privacy laws. switchbooks is not responsible for other data controllers' processing activities, and you should contact them directly for questions about how they process your personal information and about how to exercise your privacy rights in relation to such processing.

This Privacy Statement does not apply to certain processing activities where we are not the controller. For example, where switchbooks processes personal information as a processor or service provider on behalf of our customers. When we act as a processor or service provider, the privacy statement of the customer who uses our Services applies, instead of this Privacy Statement, and our processing of such personal information is governed by our agreements with such customers. If you have concerns about personal information that we process on behalf of a customer, or wish to exercise your privacy rights regarding such personal information, please contact the customer directly.

If you have any questions about how switchbooks processes your personal information, please see How to contact us below.

The switchbooks Platform

The switchbooks Platform and your personal information

When we say "platform," we mean that when you choose to share data with us, or bring over information from third parties (like a bank or financial institution), switchbooks uses that data together, not just within the individual offering(s) you're using. This means that, for example, we may use your bookkeeping details from switchbooks, transaction details, and financial information together to provide you with a comprehensive view of your business finances. The personal information we use in this centralized way may relate to you as an end user of our Services or as a customer or vendor of a switchbooks customer whose personal information has been included in the switchbooks Platform.

Business account information

Some experiences and services within the switchbooks Platform allow you to interact with a business (such as your employer). If you are granted access to a business account (for example, in switchbooks), the business owner or a designated administrator may control and administer details of your account, for example, by deciding your access rights; making decisions about your personal information; or requiring you to take certain actions. If the owner or designated administrator changes your access rights, then you may lose access to the information the business controls.

Your use of the switchbooks Platform as part of a business account may be subject to the business's policies, which may differ from this Privacy Statement. We are not responsible for the privacy or security practices of other businesses, and you should consider both the business's policies and whether you are comfortable giving the business access to your personal information before connecting to their services.

Personal information we collect

The personal information that we collect or otherwise receive about you depends on the context of your interactions with switchbooks, how you configure your account, and the choices you make, including your privacy settings. The way we process your personal information may also depend on the particular Services, functionalities, or experiences you use, your location, and applicable law.

Information you provide to us

You may provide us with your information as follows:

• Contact data and account profile data. We collect information when you (or your organization) create an account, activate a subscription, and/or upload information to the switchbooks Platform. Personal information may include your name, title and honorifics, professional title and company name, billing and mailing addresses, email address, profile photo, billing information (your payment information), purchase history, demographic information, preferences, subscription data, and your username and account credentials.
• Identity verification information. We collect information to verify your identity, including your name, date of birth, and similar information to verify your identity and help secure your account.
• Communications, feedback and survey data. We may collect personal information such as your name, email address, and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include: call center recordings and call monitoring records, chat and text records, voicemails, photographs, and video images.
• Marketing data. You may provide us with your contact information and preferences for receiving marketing communications.
• Social and community content. We receive content you post on our social media pages and our community pages.
• Business and financial information. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payment details, details about your customers, vendors, or employees, income and wage information, and/or investment information.
• Interactions with experts. The switchbooks Platform provides opportunities for you to connect with live experts, including, for example, accountants or bookkeepers. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts, and the guidance provided to you.
• Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive bots across the switchbooks Platform.
• Device and contact data. If you grant permission in your device settings, certain features may have access to your device and contacts.
• Business connection data. We may collect information about you when you interact with the switchbooks Platform through our customers. If you are a customer, vendor or prospect of a switchbooks customer and interact with the switchbooks Platform (for example, to pay an invoice, make a purchase, interact with an email, provide contact details or complete a survey), we will use this information to make recommendations about you to our customers. Our customers may also provide business connection data directly about you to us.

Third-party sources

The switchbooks Platform is designed to help you connect with other people and businesses. As a result of those connections, others may be able to input personal information about you, including other customers using the switchbooks Platform. For example, a switchbooks customer may share personal information about you with us in order to use and benefit from the switchbooks Platform. You also may be able to input or process personal information about others, for example, if you are an account administrator of one of our products or use switchbooks to manage customer lists. If you input information about others into the Platform, you must only do so if you have first provided sufficient notice and received any required permissions, and have an appropriate legal basis if required by applicable law.

We may also receive personal information about you from other third parties where you have provided consent or where permitted by applicable law. We protect and process the personal information obtained from those third parties as described in this Privacy Statement, consistent with any additional restrictions imposed by the source of the information. Our third-party sources may vary over time and depend upon how you use the switchbooks Platform. For example, we receive information from:

• Linked third-party services. If you choose to sync a non-switchbooks account/service with your switchbooks account, we will receive information from that account/service according to your settings with that account/service. This may include details of your bank account information, financial institution information, purchase history or your business's sales records.
• Supplemental information and identity verification providers. We work with certain third parties to help us verify your identity, the specifics of your business, and/or supplement the personal information you have provided and ensure the accuracy of your personal information. For example, we use third-party providers to validate your contact information (e.g., name, mailing address, email address) or to provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.
• Customer support providers. We receive personal information about you or your interaction with the switchbooks Platform from certain third parties for troubleshooting purposes. For example, we may obtain information about your interaction(s) with customer support and information about technical issues you have raised, including call center recordings, call monitoring records, voicemails, photographs and chat records.
• Other users. As described above, we may receive personal information about you from other switchbooks Platform users, such as your accountant, bookkeeper, spouse, employer, or other business customers using the switchbooks Platform (e.g., businesses from which you buy products or services, or with which you otherwise interact). We may also collect such personal information through features like member referral programs.
• Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our offerings, including to help combat fraud and illegal activity and to help protect your personal information.
• Data providers. We may receive information from information services and data licensors that provide demographic and preference information to us.
• Content providers. We may receive personal information from companies that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
• Public information. We collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.

Automatic data collection

We, our service providers, and our business partners may automatically log personal information about you, your computer or mobile device, and your interaction over time with the Services, such as:

• Device information. We may collect information about your device(s) such as IP addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
• Usage information. We may collect information about your use of the switchbooks Platform, such as the pages you viewed, the services and features you used or interacted with, your browser type, and details about any links or communications with which you interacted.
• Location information. Certain features in the switchbooks Platform may collect your precise location information, device motion information, or both, if you or your organization grant(s) us permission to do so through your device settings.
• Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. In doing so, we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.
• Communication interaction data. We or our third-party service providers may collect information from email providers, communication providers and social networks, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
• Online behavioral data. We may automatically collect certain personal information about your use and interactions with our websites, customers' websites or e-commerce stores, social media websites, and marketing campaigns that we or our customers organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.

Cookies and similar technologies

switchbooks and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively "cookies") to collect information about you ("Cookie Information") so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers' experiences. For example, we may use session-replay technologies that employ software code to record users' interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users' clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement.

You have control over some of the information we collect from Cookies and how we use it. Please see Your Personal Information Rights and Choices section for more information.

How we use personal information

We may use your personal information in a number of ways or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to:

• Provide you with the switchbooks Platform, create your account and manage our relationship with you
• Run and manage our business, including resolving billing and financial disputes
• Evaluate your eligibility for marketing offers, products and services
• Provide a product or service that you have requested through the switchbooks Platform
• Connect you with experts and other users
• Communicate with you, such as sending you electronic notifications concerning your financial privacy
• Understand your needs and interests, and personalize your experience with the Services and our communications
• Provide you with support and resolve disputes
• Authenticate your identity
• Manage event registrations and attendance, including sending related communications to you
• Register visitors to our offices for security reasons and manage non-disclosure agreements that visitors may be required to sign

Research and development

We may use your personal information to:

• Improve and develop our products and services by analyzing how they are used and interacted with, by training our artificial intelligence models and other machine learning models, as well as by assessing the use of and interactions with our Platform and certain content our customers send or display through the Platform, including by conducting data analytics to develop insights about you, your needs, and your preferences, so we can make more informed predictions, recommendations, and products for our customers
• Combine and anonymize information about your interactions with switchbooks to create aggregate, anonymized statistics for use in research (including by contracting with academic institutions) and for marketing, promoting, improving, and developing our platform

Marketing and advertising

We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes to:

• Market services, products and experiences, including to deliver gifts and promotional materials, product recommendations and other non-transactional communications via email, post, or push notifications, in accordance with your marketing preferences
• Personalize your experience and tailor recommendations, advertising, and offers presented to you, including through the development of insights about you and your needs based on your interactions with the switchbooks Platform's products, services, and offerings. These advertisements may be displayed to you on switchbooks' digital properties, including our websites and mobile apps, media platforms, connected devices, or other third-party platforms and channels

Compliance and protection

We may use your personal information to:

• Protect against misuse or abuse of our Services and ensure compliance with our Terms of Service, including in relation to content our customers send or display through the Platform
• Comply with legal and regulatory requirements
• Protect the rights, property, safety or security of the switchbooks Platform, our customers, employees or others and prevent fraudulent or illegal activity
• Exercise our rights in the course of judicial, administrative, or arbitration proceedings
• Enforce, remedy, or apply our Terms of Service or other agreements

We may process your personal information for other purposes that are compatible with the above purposes where permitted by applicable law.

Artificial Intelligence (AI) and Automated processing

When you use or interact with features on the switchbooks Platform like chatbots, digital assistants, or other digital conversational experiences powered by artificial intelligence, we may process your personal information using automated and manual (human) methods. For example, when we use automated processing on your personal information to provide a more personalized and enhanced experience in the switchbooks Platform, you may see instantly tailored recommendations and insights to manage your cash flow and grow your business. Or when we analyze personal information and transactions we have collected or received about you, we can provide you with personalized advice, predictions, recommendations and experiences, including providing personalized recommendations for financial products and services. Certain laws may provide you with the right to object to the automated processing of your personal information.

How we share your personal information

When you interact with our services

We may share your personal information in the following circumstances:

• For certain product features. We may use third party API services for certain product features. If you choose to use those features, you acknowledge and agree that you are also bound by the third party's privacy policy.
• When you connect with a switchbooks Platform partner. You may be provided with offers, products, and services from third-party companies who integrate with our switchbooks Platform. If you choose to interact with a platform partner, apply for their services or offerings, or otherwise link or sync your account to a platform partner's product or service, you consent and direct us to share your personal information to the platform partner providing the service or offering.
• When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider's privacy policies (not this Privacy Statement).
• For joint features, sales, promotions and events. With your consent we may share your personal information with third parties who are jointly providing features, sales initiatives, promotions or events with us.
• When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content that may include personal information, such as your name or username. Anything you share in a public forum is public, and you should think carefully before you decide to share.

Other circumstances

We also share your personal information with third parties in the following circumstances:

• For research. With appropriate controls, we may share information with third parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that does not identify any individual.
• With financial services providers. In connection with our financial products, we may share personal information with collection agencies, credit bureaus and loan services providers, and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.
• With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Statement. Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business. Service providers or agents also include AI providers, including generative AI providers.
• For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your personal information with that company and its advisors before and after the transaction date.
• With our affiliates and subsidiaries. We may share your personal information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes, for improving and developing our offerings, and for personalizing your experience on our Platform.
• For advertising and analytics. switchbooks may use advertising networks and other providers to display advertising on our switchbooks Platform or on other sites. switchbooks may share personal information with advertising networks and other providers to tailor advertising and offers presented to you based on your interactions with the switchbooks Platform's products, services, and offerings.
• For legal reasons. We may share your personal information with third parties for legal reasons without your consent, and as permitted by law, including when we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process; to protect the rights, property, or safety of switchbooks, the switchbooks Platform, our customers or others; to protect or defend against attacks; to enforce, remedy, or apply our Terms of Service or other agreements; to prevent fraud, cybersecurity attacks or illegal activity; for debt collection; and with regulatory agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or the switchbooks Platform, or in required institutional risk control programs.

Your personal information rights and choices

Your choices

At switchbooks, we believe that you have choices about information that pertains to you or your business.

• Update your privacy settings. You may update your privacy settings by visiting your account settings.
• Correct your personal information. You can edit and correct certain personal information at any time by changing it directly in our products and services.
• Access your personal information. You may download a copy of the personal information we have about you by visiting your account or by contacting us at info@switchbooks.ai.
• Delete your personal information. You may ask us to delete your personal information by visiting your account settings or by contacting us at info@switchbooks.ai.
• Cookies and other tracking technologies. You may be able to opt-out of interest based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page or by visiting your account settings.
• Manage marketing communications from us. To update your marketing communication preferences, you can go to the marketing preference tools in your account settings or you may unsubscribe using the link found at the bottom of all marketing and promotional emails.

Verification

To help protect privacy and the security of your personal information, you may be asked to provide additional information to verify your identity and/or ownership rights before we can fulfill your data rights request. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.

Data retention

Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the switchbooks Platform and successfully run our business. Even if you submit a deletion request, we may be required to maintain your personal information for as long as necessary to:

• comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);
• to exercise, establish or defend legal claims; and/or
• to protect against fraudulent or abusive activity on our service.

This means we may keep different information for different periods. If your account is canceled because you haven't used it for a long time, we may delete this information immediately.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

International data transfers

switchbooks reserves the right to store and process your personal information in the United States and in any other country where switchbooks or its affiliates, subsidiaries, or service providers operate facilities in accordance with and as permitted by applicable laws and regulations. Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

When we transfer, store or process personal information outside of your jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Statement and applicable law.

Security of your personal information

We use reasonable physical, technical and organizational safeguards that are designed to protect your personal information. However, despite these controls, we cannot completely ensure or warrant the security of your personal information.

Changes to our Privacy Statement

From time to time we may change or update our Privacy Statement. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your personal information, we will notify you by posting a notice in the switchbooks Platform or on a community post; by sending you a notification; or by other means consistent with applicable law.

You can see when this Privacy Statement was last updated by checking the "last updated" date at the top of this Privacy Statement. Please review this Privacy Statement periodically to stay informed about how switchbooks protects your privacy.

Children

Our services are not intended for or directed to children under the age of 13. We do not knowingly collect personal information from children. If you believe we may have information from a child, please contact us at info@switchbooks.ai.

How to contact us

If you have questions or comments about this Privacy Statement or our practices, please contact us at info@switchbooks.ai.

If you have an unresolved privacy or information use concern or complaint that we have not addressed satisfactorily, please contact us directly at info@switchbooks.ai.