Privacy Policy

Savvy Labs Privacy Policy
Scope: Savvy Labs and respective counterparties, including clients
Effective Date: Aug 4, 2026

This Privacy Policy sets forth the privacy practices of Savvy Labs Inc. (the “Firm,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of personally identifying information (“Personal Information”), including, but not limited to, Personal Information collected through each of our website(s) and any related URLs and services (each and collectively, as appropriate, the “Site”), how such Personal Information is used, and the circumstances under which such Personal Information may be shared and disclosed. By using our Site, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Site is also subject to our Terms of Use which govern your access to the Site and/or your use of the Site and of the Content (as defined in the Terms of Use) and the services made available on or through the Site.

1. Personal Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us.

Registration and Account Information
When you sign up for an account, we ask you for certain Personal Information, including but not limited to, your name, date of birth, residential or business address, mobile telephone number, and e-mail address.

Communications
If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below).

Contact Forms
If you complete one of our contact forms, we may collect information such as your name, company name, job title, whether you’re authorized to open an account on behalf of an entity, and an explanation of your interest.

B. Information We Collect When You Use Our Site.

Location Information
When you use our Site, we receive your location information. For example, we infer your location information by using your IP address.

Device Information
We receive information about the device and software you use to access our Site, including IP address, device type/year/make/model, device identifiers, web browser type and version, and operating system version.

Usage Information
We automatically receive information about your interactions with our Site, like the pages or other content you view; referrer information (the website you visited before coming to our Site); the dates, times, and duration of your visits; and crash logs.

Information from Cookies and Other Tracking Technologies
We and our third-party partners collect information about your activities on our Site using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, and security partners, may also use these technologies to collect information about your online activities over time and across different services.

C. Information We Receive from Other Sources.

Other Third Parties
We may receive additional information about you, from third parties like services providers, affiliates, and government entities, and combine it with other information we have about you.

2. How We Use Personal Information

We use Personal Information for the following business purposes:

• Providing, maintaining, improving, and enhancing our Site;
• Understand and analyzing how you use our Site and develop new products, services, features, and functionality;
• Communicating with you, providing you with updates and other information relating to our Site, providing information that you request, responding to comments and questions, and otherwise providing customer support;
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• To send you text messages;
• Facilitating transactions and payments;
• Confirming your identity;
• Protecting the security and integrity of the Site;
• Preventing or investigating fraud, abuse, or other unlawful activity, detecting security incidents, and responding to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

3. How We Disclose Personal Information

Affiliates
We may disclose any information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers
We may disclose any information we receive to vendors and service providers, for business purposes only, retained in connection with the provision of our Site.

Analytics Partners
We use analytics services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

As Required By Law and Similar Disclosures
We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Site.

Merger, Sale, or Other Asset Transfers
We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent
We may also disclose your information with your permission.

4. Your Choices

Marketing Communications
We may send you promotional emails about our services, new features, or other updates. You may opt out of receiving marketing communications at any time by clicking the "unsubscribe" link in any such email or by contacting us at support@savvylabs.com. Opting out does not affect delivery of transactional or operational communications related to your account.

Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

5. How We Protect Personal Information

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

6. If you are a California resident, please read our Privacy Notice for California Consumers below:

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and is only relevant to residents of the state of California, it applies only to the collection or use of “personal information” or “sensitive personal information” that is subject to the CCPA/CPRA.
Please note that the CCPA/CPRA does not generally apply to personal information that Savvy Labs collects, processes, sells, or discloses by pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Lending Act, and other federal privacy rules and regulations, including personal information collected or processed in order to provide investment advisory services or other financial products or services. Consequently, the CCPA/CPRA does not apply to most of the information that Savvy Labs collects. However, where we collect information for some purpose other than providing a financial product or service, such as when we collect information for marketing purposes, our information collection must meet the requirements of the CCPA/CPRA.

Information We May Collect:
In the past twelve (12) months, we may have collected some of the following categories of sensitive personal information and personal information from California consumers, to the extent such information is subject to the CCPA/CPRA:

We do not knowingly collect, solicit or sell personal information from anyone under the age of sixteen (16).

Purposes for Collection and Use of Personal Information
Savvy Labs collects and uses sensitive personal information and other personal information only as permitted under the CCPA/CPRA, including as reasonably necessary and proportionate to fulfill the intended features of our Site, including for one or more of the following purposes:

• Providing you with information about our products and services;
• Providing performance and other updates;
• One or more of the following business purposes:
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
  • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of advertising impressions, and auditing compliance, etc.);
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Internal research for technological improvement;
  • Internal operations;
  • Marketing and advertising activities, including website analytics and communications, where such activities are not subject to GLBA;
  • Recruiting, employment, and contractor management, where applicable;
  • Activities to maintain and improve our services; and
  • Short-term, transient use, provided that the personal information is not disclosed to another third-party and is not used to build a profile about a consumer.

Sharing Personal Information Savvy Labs does not sell personal information as defined by the CCPA/CPRA. Savvy Labs also does not share personal information for cross-context behavioral advertising, as defined under the CPRA/CPRA. We may disclose sensitive personal information and other personal information in one or more of the categories identified above to:

• Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
• Affiliates;
• Business partners;
• Legal or government regulatory authorities as required by applicable law; and
• In connection with a potential business transfer or in order to service your account under agreed terms.

In the past twelve (12) months, we have not sold any personal information and have only disclosed personal information as described above for business purposes.

Rights of California Consumers
The CCPA/CPRA provides California residents the following rights with respect to personal information that is subject to the CCPA/CPRA:

• The right to request (a) the categories and specific pieces of sensitive personal information and other personal information we collect about you, (b) the categories of sources from which we collect your sensitive personal information and other personal information, (c) our business or commercial purposes for collecting, selling or sharing your sensitive personal information and other personal information, (d) the categories of personal information disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose, (d) the categories of your sensitive personal information and other personal information (if any) that we have either sold or shared, and (e) the categories of third parties to whom personal information has been sold or shared;
• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past twelve (12) months and the names and addresses of those third parties;
• The right to request that we delete the personal information we have collected from you or maintain about you;
• The right to limit the use and disclosure of sensitive personal information;
• The right to opt out of any sale(s) (if any) of your personal information; and
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA/CPRA.

California employees, job applicants, and independent contractors have rights under the CCPA/CPRA with respect to personal information collected in the employment or engagement context. Such individuals may exercise their rights as described above with respect to personal information subject to the CCPA/CPRA. Savvy Labs may provide additional notices specific to workforce-related personal information.
You may designate an authorized agent to submit a CCPA/CPRA request on your behalf. We will require verification of your identity and proof of the agent’s authorization to engage in this capacity as permitted by law.

Savvy Labs does not engage in automated decision-making or profiling that produces legal or similarly significant effects on consumers, as defined under the CCPA/CPRA.

7. Notice for Residents of the European Economic Area and United Kingdom

Savvy Labs does not currently offer its products to natural persons resident in the European Union, Switzerland or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation or similar laws in Switzerland or the United Kingdom (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.

8. International Visitors

Savvy Labs and its servers are located in the United States. Our services are intended for visitors located within the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, you should note that by providing your personal information on or through the Site, you are transferring your personal information to the United States for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site. By providing any information, including Personal Information, on or to the Site, you are consenting to such transfer, storage, and processing.

9. Children’s Privacy

This Site is not intended for, or designed to attract, children under the age of eighteen (18). Consequently, we do not intentionally collect, maintain, or use information from individuals who are under the age of eighteen (18). If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, then you may alert us at hello@savvylabs.com.

10. Updating Your Personal Account Preferences and Disabling Your Account

To update your account information, adjust/cease the frequency by which you receive Savvy Labs communications, or disable/delete your account, please contact us at hello@savvylabs.com.

11. Changes to this Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Site, we will notify you through the Site, by email, or other communication.

12. Contact Us

If you have any questions or comments about our processing activities or this Privacy Policy, please feel free to contact Savvy Labs at hello@savvylabs.com or (888) 401-5517.

Revision History