Effective date: April 24, 2024

Introduction

P2P Labs, LLC (“P2P Labs”, “P2P”, “us”, “we”, or “our”) recognizes and supports the privacy rights of all persons, and we respect these rights when we collect and process personal information (“PI”). This page informs you of our policies regarding the collection, use, and disclosure of personal data. P2P Labs operates the URL https://www.engagehelios.ai/ website (the “Service”). We have developed and adopted this privacy policy (the “Privacy Policy”) to describe our privacy values and guide our processing of personal information when you use our Service and the choices you have associated with that personal data. We use your personal data to provide and improve the Service.

By purchasing, subscribing to, or utilizing the Service, you agree to the collection and use, and to be bound to the terms and conditions of this Privacy Policy. The obligations and responsibilities set out in this Privacy Policy are applicable to P2P Labs and its personnel and will be made available on P2P Labs’ website at URL https://www.engagehelios.ai/privacy-policy. The obligations and responsibilities set out in the Privacy Policy are in addition to any other applicable policies or agreements entered into with P2P Labs and any applicable laws and regulations.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our General Terms and Conditions, accessible from URL https://www.engagehelios.ai/terms.

General Statement

P2P Labs is dedicated to the use of Internet Protocol and related technologies to improve the telecommunications industry and the lives of individuals throughout the world.

P2P Labs’ goal is to deliver carrier-grade communications applications and tools to all its Clients at a reasonable price and to make available all the benefits these applications and tools offer as broadly as possible. In order to achieve this goal, a Privacy Policy is necessary.

Scope

At P2P Labs, privacy matters. P2P Labs respects the privacy of its Clients and other individuals with whom P2P has business interactions’. This policy is global, applying to all P2P locations. It applies to personal information regardless of format. For example, the policy applies to computerized records and electronic information as well as paper-based files. It is also applicable to all personal information that is collected, maintained or processed by P2P. The concepts enumerated in this policy will guide P2P’s selection and expectations of its Clients, partners, agents and/or contractors to whom P2P transfers and relies on for processing of personal information.

Data Processor

P2P Labs provides the technology platform for hosted or “cloud” omni-channel communications as a service offerings (“OmniCX” or “OCX”). These Products merely act as a conduit for data transmitted by third parties and Client’s customers. P2P processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. P2P also processes personal information in the course of providing support for P2P’s products. P2P shall protect the personal information, comply with all laws that regulate the processing of such personal information, and process the information only as authorized by the data controller or the data subject. Accordingly, P2P relies on guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information. In some cases, P2P may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning P2P processing.

While P2P Labs does process data in its role of providing a technology platform, it does not own, control or direct the use of any of the personal information stored or processed by any Client or Client’s customer(s). P2P only processes such personal information in order to provide and invoice for purchased and/or subscribed Products and Services.

What Information We Collect or Process

P2P Labs processes and in certain situations collects personal information as needed to deliver its Products and Services and manage its business. When collecting personal information, P2P does so in a reasonable and lawful manner.

The types of information and the purposes for which P2P collects or processes personal information may include:

Indirect End User Phone Contact Information (Personal Identifiable Information)

P2P acts as a data processor with regard to indirect end user personal identifiable information and our Clients act as the data controller of such data. In the course of P2P’s processing and protection of such data, all use will be in conformity with the data controller’s instructions. Specifically, only when enabled via system permission on Helios OCX, P2P may show personal contacts within the respective application. When the user sends an instant message, webchat, SMS message or other enabled communication channel to one of his/her contacts, agents or callers, or when the user initiates or receives a call to one of his/her phone or system contacts, the phone number and other related information is sent securely through P2P’s API. P2P stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and P2P does not share this data with any advertisers or third parties under any circumstances.

CLIENTS

P2P Labs uses such personal information only for relevant, appropriate, and customary purposes. P2P will not share or disclose personal information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in Client’s Master Services Agreement (MSA) including the General Terms and Conditions. The following are examples of some of the personal information P2P may process.

Business Contact Information:

P2P Labs may collect and use personal information about individual contacts of Clients and others who access P2P’s public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals in the course of receiving Products and Services from P2P Labs and/or requesting information about P2P. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding P2P Labs Products and Services.

Customer Proprietary Network Information (CPNI):

Customer Proprietary Network Information (CPNI) may include information regarding quantity, destination, technical configuration, location, amount of use and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our Products and Services. The date, time and duration of the calls may also be collected. This data is used for billing and service level assurance.

P2P Labs provides Products and Services that are primarily for the benefit of Clients and Authorized Users in that P2P transmits, routes, switches or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and users. P2P does not determine the purposes and means of processing this personal information. Except for Authorized User data provided by the Client (the Authorized Users service provider) for which P2P is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, P2P requires and collects only essential CPNI and billing information; and opting out or declining to provide the requested data may hinder the provision or delivery of subscribed services. However, for CPNI data that is collected by P2P that is not subject to the control of others, P2P shall obtain consent from the user for the processing of this data.

P2P collects end-user CPNI in the course of providing Product support. This data may pertain to Clients of P2P or Authorized Users (eg: end users of P2P’s direct Clients). This data may include but is not limited to IP address, telephone number, email address, call detail records, call recordings and other information sufficient to identify an individual end user.

Indirect End User’s CPNI:

P2P acts as a data processor with regard to indirect end user personal information and our Clients act as the data controller of such data. In the course of P2P’s processing and protection of such data, all use will be in conformity with the data controller’s instructions.

Direct End User’s CPNI:

P2P typically collects and processes direct end user (eg: Clients, vendors, and partners) personal information for the purposes of providing Products and Services, support, conducting data analytics and managing product performance.

Anonymized, Non-Identifying Voice and Traffic Data

P2P may use anonymized, non-identifying data collected from use of our P2P Products and Services. This anonymized, non-identifying data may be used to enhance such items, but is not limited to, system and communication channel activation, improve traffic analysis algorithms and techniques, and recognition algorithms. This processing is executed under applicable terms and supports P2P’s legitimate interests in tuning, maintaining, and enhancing these Products and Services.

Cookies

P2P websites may use cookies to collect certain kinds of personal information about Clients or users. For more information on how P2P uses cookies and choices available to Clients and users please refer to the following section.

How We Collect Information

We collect information in various ways, including the following:

When you use one of our Products or Services, P2P collects, and stores certain information that you provide directly. We also collect information about your use of the Products and Services.

Cookies and Similar Collection Methods

P2P also collects technical information about your usage of the Products and Services, and we use various technologies to collect information about cookies, IP addresses, device type and device identifiers, application state and the date and time of activity with our Products and Services, and other similar information. P2P may associate this information with your user identification and/or account number for our internal use.

Other Passive Site Tracking

Websites may also utilize Internet Protocol (IP) addresses and log files to identify network and server concerns and problems. P2P also utilizes web beacons and other passive tracking mechanisms to perform standard website traffic analysis in a similar manner to how we utilize cookies.

Credit Card Information

P2P only collects credit card information in order to bill for purchased or subscribed to Products and Services. P2P utilizes third-party credit card payment processing agents (where these agents are required to implement reasonable and appropriate measures to protect and secure this information from loss or misuse) solely for the purpose of processing payments for those Products and Services purchased or subscribed to. These payment processors use of your personal information is governed by their privacy policies, as well as adhering to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like American Express, Visa, Mastercard, and Discover.

HOW DOES P2P UTILIZE COOKIES

General Information about Cookies

A cookie (also known as an HTTP cookie, web cookie, or browser cookie) is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to

the server to notify the website of the user’s previous activity. Cookies were designed to be a reliable mechanism for websites to remember useful information (such as items in a shopping cart) or to record the user’s browsing activity (including clicking particular or specific buttons, logging in or recording which pages were visited by the user as far back as months or years ago).

Utilization of Cookies A visit to a page on www.engagehelios.ai (or other P2P website) may generate the following types of cookie(s):

Anonymous Analytics Cookies

Every time a user visits a P2P website, software provided by another organization (such as Google Analytics) generates an ‘anonymous analytics cookie’. These cookies can tell us whether you have visited the site before. Your browser will inform us if you have these cookies and, if you don’t, our website generates new ones. This allows P2P to track how many individual users we have and how often they visit the site. Unless you are signed in to www.engagehelios.ai (or any other P2P website), we cannot use these cookies to identify individuals. We use these cookies to gather statistics: for example, the number of visits to a page. If you are logged in to the P2P website, we will also be provided with the details you gave to us for this, such as but not limited to your username and email address.

Registration Cookies When you register with a P2P website, such as www.engagehelios.ai, P2P generates cookies that inform us whether you are signed in or not. Our servers use these cookies to determine which account you are signed in with and whether you are allowed access to a particular Product or Service.

Advertising (Ad) Cookies

These cookies allow P2P to know whether you’ve seen a specific ad or the type of ad, and for how long you have viewed it. We also utilize cookies to help us direct targeted advertising.

Other Third-Party Cookies

On some pages of our websites, other organizations may also set their own anonymous cookies. They do this to track the success of their products and/or services, or to customize the experience for you. Because of how cookies function, our websites cannot access these Third-Party cookies, nor can the other organization access the data in cookies P2P uses on our websites. For example, when you share an article or post using a social media sharing button (Facebook, LinkedIn or other social media outlets) on www.engagehelios.ai, the social network that has created the button will record that you have done this.

How Do I Turn Cookies Off

It is usually possible to stop your browser from accepting cookies, or to stop it accepting cookies from a specific website. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, you can use the ‘Help’ option in your browser for more details. It is solely your responsibility to stop cookies in your browser.

Note: If you block the use of cookies, then this will limit the service that we are able to provide to you and may affect your visitor/user experience.

VENDORS, SUPPLIERS AND SUBCONTRACTORS

P2P may collect personal information about individuals who are employed by our suppliers and vendors. This business contact and payment information are strictly used to administer existing and future business arrangements.

OTHERS

Additional personal information may be collected, processed and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders, and other legal obligations. For example, we may collect information about individuals that visit our office or other facilities. When we do collect data, such collection shall be relevant, proportionate, and limited to the purposes for which they are processed.

International Cross-Border Personal Information Transfers

P2P Labs is a U.S.-based, global company. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which P2P has operations for the purposes described in this Privacy Policy. P2P may also transfer your personal information to our third-party processors as detailed here, who may be located in a different country. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. Whenever P2P shares personal information originating in the European Economic Area (the “EEA”) with an entity outside the EEA, P2P will rely on lawful measures such as the Privacy Shield Framework detailed in this Privacy Policy. If you are visiting our Website(s) from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which P2P operates in accordance with this Privacy Policy.

Transfer of Personal Information from the EU, United Kingdom and Switzerland to the United States

P2P Labs, LLC complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred to the U.S. from the European Union (EU), the United Kingdom (UK) and/or Switzerland, respectively. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

In addition to the protections provided under other sections of this Privacy Policy, P2P will provide the following protections for personal data transferred from the EU, United Kingdom, and Switzerland to the U.S.

CHOICE

Individuals will be offered a clear, conspicuous, and readily available mechanism to choose (opt-out) whether their personal information is (1) to be disclosed to a third party (other than a third party acting as an agent to perform tasks on behalf of and under the instruction of P2P or (2) to be used for a purpose that is materially different than or incompatible with the purpose for which it was originally utilized or subsequently authorized by the individual.

Additionally, individuals will be offered a similar choice mechanism to give affirmative or explicit (opt in) choice whether their sensitive personal information is to be disclosed to a third party or used for a purpose other than the purposes for which it was originally collected or subsequently authorized by the individual by opt-in choice. However, explicit (opt in) choice is not required when the disclosure of the sensitive personal information is (1) in the vital interests of the individual or another person; (2) necessary for the establishment of legal claims or defenses; (3) required to provide medical care or diagnosis; (4) necessary to carry out the organization’s obligations in the field of employment law, or (5) related to personal information that is manifestly made public by the individual.

Transfer of Personal Data from the EU, United Kingdom and Switzerland to Processors in the United States

P2P Labs, LLC may transfer personal information to a processor in the United States solely for processing purposes. A “processor” is a third party who processes personal information on behalf of and in accordance with the instructions of P2P. When personal information is transferred from the EU, United Kingdom and Switzerland to the United States solely for processing purposes, P2P will comply with the applicable data protection laws including the EU General Data Protection Regulation (or “GDPR”) and the Swiss Federal Act on Data Protection (or “FADP”), respectively, and enter into a contract with the processor to ensure that the processor (1) acts only on instructions of P2P; (2) provides appropriate technical and organizational measures to protect the personal information against unlawful destruction or accidental loss, alteration, unauthorized disclosure or access; and understands whether onward transfers are allowed; and (3) assists P2P in responding to individuals exercising their rights under the Privacy Shield Principles, taking into account the nature of the processing.

Onward Transfers to Third Party Agents

After personal information is transferred from the EU, United Kingdom and/or Switzerland to P2P in the United States, P2P may thereafter transfer the personal information to third parties acting as controllers. A “controller” is a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal information. When P2P makes such onward transfers to third-party controllers, P2P will comply with the Privacy Shield notice and choice principles and enter into a contract with the third party controller that provides that (1) such personal information may be processed only for limited and specified purposes consistent with the consent provided by the individual; (2) the third party controller will provide the same level of protection as the Privacy Shield principles; (3) the third party controller will notify P2P if the third party can no longer meet its obligation to provide the same level of protection for the personal information as required by the Privacy Shield principles; and (4) upon such notice by the third party controller, the third party controller will cease processing the personal information and/or take reasonable and appropriate steps to remediate any unauthorized processing.

Recourse Mechanisms for Personal Data Transferred Under Privacy Shield

Inquiries or complaints regarding transfers of personal data from the EU, United Kingdom and Switzerland to the U.S. pursuant to Privacy Shield should be directed to:

P2P Labs, LLC 1 E. Broad Street, Suite 130-1173 Bethlehem, PA 18018 Email: legal@engagehelios.ai

P2P has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent alternative dispute resolution mechanism. P2P has selected JAMS Mediation, Arbitration and ADR Services (JAMS) as the administrator of P2P’s independent recourse mechanism for Privacy Shield disputes. P2P has committed to refer such unresolved Privacy Shield complaints to JAMS in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, you may find more information about dispute resolution and how to file a claim with JAMS at https://www.jamsadr.com/eu-us-privacy-shield.

Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please visit Privacy Shield Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Liability

In the context of an onward transfer of personal information, P2P has responsibility for the processing of personal information they receive under the Privacy Shield and subsequently transfers to a third-party agent. P2P will remain liable under the Privacy Shield Principles if their third-party agent processes such personal information in a manner inconsistent with the Privacy Shield Principles unless P2P proves that it is not responsible for the event giving rise to the damage.

Accountability for Onward Transfer

P2P will only transfer or provide direct access to personal information covered by this policy to third parties that have:

Additionally, P2P is committed to subjecting all personal information received from European Union (EU) member countries, the United Kingdom (UK), and Switzerland, in reliance on the EU-US and Swiss-US Privacy Shield Frameworks, to the Privacy Shield Frameworks’ applicable Privacy Shield Principles. P2P will only transfer or provide direct access to EU, UK and Swiss personal information covered by this policy to third parties that:

Accordingly, P2P requires the following of its onward transfer agents:

How We Use the Information We Collect

We use your information primarily and as necessary to provide you with the various P2P Products and Services, including but not limited to one or more of the following ways: to create your accounts and allow use of our Products, to provide technical support and respond to Client inquiries, to prevent fraud or potentially illegal activities, enforce our other agreements with you, to notify Clients of application updates, and to inform Clients about new products or promotional offers.

SENSITIVE INFORMATION

P2P recognizes that for some sensitive information, affirmative express consent from individuals is required and must be obtained if such information is to be (i) disclosed to a third party or (ii) processed for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in

choice. In addition, P2P shall treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

SERVICE PORTALS

If you have created a user profile on any P2P service portal, you may access and revise the personal information in your user profile when you log into your account. In general, these portals will only require minimal personal information that is necessary to provide and administer the service.

MARKETING MATERIALS

If you provide us with your email address or other business contact information to enable us to provide communications and information to you, we may use the information for providing such communications including the delivery of press releases and other P2P marketing materials. You may request to no longer receive P2P marketing communications by following the “unsubscribe” instructions in emails from P2P or by sending a request to the contact identified below. In the rare and unlikely event that P2P wishes to use an individual’s personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals, P2P will seek consent in advance as required by applicable law.

Sharing Your Information

We may disclose or report information that individually identifies Clients, Authorized Users, users or devices in certain circumstances, such as:

(i) if we have a good faith belief that we are required to disclose the information in response to a valid legal process (for example, a court order, search warrant or subpoena, or to defend or respond to legal actions, and as otherwise authorized by law, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements); (ii) to satisfy applicable laws, (iii) if we believe that the Products and Services are being used in an unauthorized, unlawful or abusive manner, such as to commit a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction, (iv) if we have a good faith belief that there is an emergency that poses a threat to the health or safety of a person or the general public, (v) in order to protect the rights or property of P2P Labs, including enforcement of our Intellectual Property Rights and terms of the Agreement(s), and (vi) for all other purposes with your consent. We may also provide your information to third party companies to perform services on our behalf, including but not limited to payment processing, data analysis, message delivery, hosting services, customer service, and marketing.

If P2P Labs enters into a merger, acquisition or sale of all or a portion of its assets or business, Client and user information, including personal information, will also be transferred as part of or in connection with the transaction as per applicable law.

INFORMATION DISCLOSURE

Internal Disclosure

In general, personal information may be shared within P2P, where legally permitted for reasonable and appropriate corporate purposes. However, even within P2P, we restrict access to personal information to those employees, agents, or contractors who need access to carry out their assigned functions.

External Disclosure

P2P uses vendors and partners for a variety of business purposes, such as to help us develop, deploy and invoice for the various Products and Services we provide. We share information with those vendors and partners when it is necessary for them to perform work on our behalf. P2P requires that these vendors and partners protect the customer information we provide to them and limit their use of such information to their respective processing activity. P2P will only transfer or provide direct access to personal information covered by this policy to third parties that have made a commitment to respect the privacy rights of the data subject; limit processing of personal information to comply with data controller instructions; and provided P2P contractual assurances that they will provide at least the same level of privacy protection as is required by applicable privacy laws.

Security of Your Information

We implement security measures we believe are reasonable to protect your information. It is important that you protect and maintain the security of your account and you need to immediately notify us of any unauthorized use of your account. Remember, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee its absolute security.

Protecting Personal Information

To help protect the confidentiality of personal information, P2P employs security safeguards appropriate to the sensitivity of the information and in accordance with this Privacy Policy. These safeguards include reasonable administrative, technical, and physical measures to safeguard the confidentiality and security of personal information against anticipated threats and unauthorized access to personal information. No transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal

information. Additionally, we convey safeguard obligations to our agents who receive personal information from or on behalf of P2P in the course of their relationship with our organization as described above in the section titled External Disclosure.

Transfer of Data

Your information, including personal information, may be transferred to, and maintained on, computers, servers or other data storage located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you reside outside the United States and choose to provide information to P2P, please note that we transfer the data, including personal information, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Retention of Data

Personal information collected by P2P will be retained for as long as necessary and legally permitted for the purposes for which it was collected, to provide you with Products and Services, enforce our legal agreements and policies and to conduct our legitimate business interests or where otherwise required by law.

Data Integrity

P2P employs reasonable means to keep personal information accurate, complete, and current, as needed for the purposes for which it was collected.

How to Access and Update Your Information

We generally provide individuals with an opportunity to examine their own personal information, confirm the accuracy and completeness of their personal information, and have their personal information updated, if appropriate.

The ability of an individual to access his or her personal information is not unlimited, however. An individual’s ability to access personal information may be limited, for example, where (i) the burden or expense of providing access would be unreasonable or disproportionate to the risks to the individual’s privacy, (ii) the information should not be disclosed due to legal or security reasons or to protect confidential commercial information; or (iii) providing access would compromise the privacy of another person.

If you have created a user profile on a portal, you may also access and revise the personal information in your user profile when you log into your account. Individuals who wish to access or update their personal information not accessible via a portal should direct such communications to P2P Labs Legal Department at: legal@engagehelios.ai

Third-Party Websites, Plugins or Widgets

P2P Labs websites, Products and/or Services may include social network or other third-party plugins and widgets not operated by us. Accessing these links to other sites is done at your own option and is not part of any P2P offerings. P2P has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services. We strongly advise you to review each privacy policy provided at the respective site.

Health Insurance Portability and Accountability Act

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) is United States legislation that provides data privacy and security provisions for safeguarding medical information. Client acknowledges and agrees that unless the P2P Labs Products and Services description expressly states otherwise, the P2P Labs Products and Services do not comply with the requirements of the Health Insurance Portability and Accountability Act, as amended, and its implemented regulations. Unless the P2P Labs Products and Services description expressly states otherwise, Client agrees that it will not use the Products and Services to create, receive, transmit, maintain, store, use, disclose, or otherwise cause the Products and Services to handle Protected Health Information (“PHI”) as defined under HIPAA. Client retains complete and full responsibility to ensure that the P2P Labs Products and Services are only applied to use-case scenarios where the Products and Services do provide the necessary level of security and privacy protections. CLIENT’S AGREEMENT TO THIS PROVISION IS A MATERIAL CONDITION OF MAKING THE P2P LABS PRODUCTS AND SERVICES AVAILABLE TO CLIENT. In addition to any indemnity requirements in these Terms, Client shall indemnify, defend and hold harmless P2P Labs, LLC, P2P Labs Affiliates and all of the directors, officers, managers, partners, employees, agents, representatives, heirs, successors and assigns of P2P Labs and each of P2P Labs’ Affiliates against all actions, claims, losses, penalties, fines, assessments, administrative costs, credit protection costs, damages and expenses (including reasonable attorneys’ fees) arising out of Client’s violation of the provisions of this section, caused in whole or in part by any act or omission of Client, or of anyone employed by or acting as a subcontractor, representative or agent of Client. Any limitation on liability set forth in the terms of the Master Services Agreement or any other agreement (including without limitation the P2P Labs General Terms and Conditions) between P2P Labs or its Affiliates and Client shall not apply to Client’s liability under this provision.

California Privacy Rights

The California Data Protection Act (Cal. Civ. Code §§ 1798.83), also known as S.B. 27 “Shine the Light Law”, applies to a business that owns or retains California residents’ personal information and, requires such business to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third-parties’ direct marketing purposes.

A business subject to California Business and Professions Code Section 22581 and the Privacy Rights for California Minors in the Digital World Act (Cal. Bus. & Prof. Code §§ 22580-22582) must allow California residents under age 18 who are registered users of online sites, services, or applications to request and obtain removal or other forms of anonymization of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be so removed.

Children’s Privacy

Our Products and Services do not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

If you are a California resident and would like to make such a request, email or contact us at: legal@engagehelios.ai

Changes to Our Privacy Policy

P2P Labs reserves the right to change this Privacy Policy at our discretion subject to business or legal requirements. You are advised to review and check this Privacy Policy from time to time and particularly before you provide personal information to P2P. Changes to this Privacy Policy are effective when they are posted on this page. By continuing to use our Products and/or Services you are irrevocably agreeing to be bound by any changes or revisions made to this privacy policy.

Contacting Us

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to legal@engagehelios.ai or write to P2P at the following address:

P2P Labs, LLC 1 E. Broad Street, Suite 130-1173 Bethlehem, PA 18018