Parler Privacy Policy

Sovren Technologies, Inc., and its affiliates ("Company," "Sovren," "Parler," "we," "our," and/or "us") value the privacy of individuals who use our social applications, the websites where this Privacy Policy is posted ("Websites"), and related services (collectively, our "Services"). Parler is a service operated by Sovren Technologies, Inc. This Privacy Policy (the "Privacy Policy") explains how we collect, use, and share information from our users ("Users," "you," and/or "your") to facilitate your commenting, social news, and influencer networking experience. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

We do not sell your Personal Information in the traditional sense. We also do not share your Personal Information with third parties for their own direct marketing purposes without your consent. However, certain data practices, such as the use of service providers, analytics providers, or similar technologies, may be considered a "sale" or "sharing" under applicable law. We handle such information as described in this Privacy Policy and provide any required rights or choices to users where applicable. (See Section 2 "How We Share the Information We Collect" below for more detail).

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new privacy practices or adopt new privacy policies.

Information We Collect

"Personal Information" is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. We may collect Personal Information (as we have done in the past) from you on or through the Services in a variety of ways, including when you register on the Services, sign up for communications, or make any purchases. We also may, from time to time, use Personal Information about you to improve the Services, and for the various purposes outlined in this Privacy Policy.

Information You Provide to Us

Registration and Profile Information. When you sign up for an account or update your profile information, we collect Personal Information you provide to us such as your name, email address, phone number, display name, profile photo, cover photo, preferred language, date of birth, and any Personal Information you voluntarily provide in your profile biography, including gender, location, and website. Either an email address or phone number is required for registration, and both are recommended for account security and recovery.

If you choose to register or sign in using a third-party identity provider such as Apple or Google, we receive certain information from that provider, which may include your name, email address, profile photo, and a unique identifier. The information we receive depends on your settings with the third-party provider and the permissions you grant. We do not receive your password.

If you register or sign in using your phone number, we use a third-party SMS provider to deliver a one-time verification code. We collect the phone number you provide and the date and time the code was sent and verified.

Direct Messages. We collect the content of direct messages you send and receive through our Services, including text, media, links, and reactions. We also collect metadata associated with direct messages, such as sender, recipient, timestamps, and delivery status. Direct messages are not end-to-end encrypted. We may access and review direct message content to operate the Services, respond to user reports, enforce our Terms and Community Guidelines, comply with legal obligations, and protect user safety.

Stories. When you create a Story, we collect the content you post and any associated metadata, such as audience selection (including Close Friends), duration, and interactive elements. When you respond to or interact with another user's Story, including replies, reactions, polls, quizzes, sliders, questions, and countdowns, we collect your response and associate it with your account. Story creators may see who has viewed and responded to their Story, including responses to interactive elements.

Lounges and Community Spaces. When you create or participate in a Lounge, we collect information about your activity, including the channels you join, messages you post, members you invite, moderation actions you take, and threaded replies. Lounge creators and moderators may have visibility into member activity, membership lists, and content posted within their Lounge. If voice features are available within a Lounge, we may collect audio data only while you are actively participating in a voice room. We do not record voice rooms unless explicitly disclosed to participants at the time of recording.

Browsing Without an Account. You may browse certain parts of our Services without creating an account. When you browse in guest mode, we still collect Device Identifiable Information described in this section, including IP address, device identifiers, and information about your interactions with the Services. Certain features, including posting, messaging, commerce, and interactions with other users, require account creation.

Content you Share. We collect any information you choose to provide on our Services, such as posts, follows, photos, videos, gifs, comments, votes, and shares.

Payment Information. If you make a purchase through our Services, your payment-related Personal Information, such as your credit or debit card information, is collected and processed by third-party payment processors on our behalf (such as Stripe). We receive limited information from these providers, such as the last four digits of your card, card type, and transaction status, but we do not receive or store your full payment card details. Your use of payment processing services is governed by the terms and privacy policies of the applicable payment processor.

Communications. If you contact us directly, we receive additional Personal Information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of any message or attachments you may send to us, and any other information you choose to provide.

Your Contacts. If you permit us to access the address book on your device or give us permission to import your contacts from an email account associated with your account, we may access and store names and contact information, including Personal Information, from your address book, to help you follow your contacts, and your contacts to follow you.

Information We Collect When You Use Our Services

We may collect information that may not reasonably identify you or your household personally but is linked to your computer or device ("Device Identifiable Information"). We collect Device Identifiable Information from you in the normal course of providing the Services. When you visit our Services to browse, read, or download information, we automatically collect information about your computer that your browser sends, such as your IP address, browser type and language, access times, pages visited, and referring website addresses. We may use Device Identifiable Information to analyze trends, help administer and improve the Services, to learn about and determine which pages of the Websites visitors view and for how long, how visitors navigate throughout the Services, and to gather broad demographic information for aggregate use. We may also collect Device Identifiable Information through "cookies" or "web beacons" as explained below.

Device and Location Information. We receive Device Identifiable Information about the device and software you use to access our Services, including IP address (from which approximate or "coarse" location may be inferred), device type, web browser type, operating system version, phone carrier and manufacturer, user agents, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. We automatically receive Device Identifiable Information about your interactions with our Services, such as the posts or other content you view, the searches you conduct, the people you follow, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We may collect information using cookies, pixel tags, and similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Cookies operate in the background, and you can turn them off by adjusting your Web browser settings, but doing so may make it difficult to use some of the features on the Websites or the features may not be available to you. We may use cookies to make your Service experience easier by, for example, remembering your preferences and maintaining your authenticated session. For more information on your choices regarding cookies, you can review the FTC's guide to opting out of online tracking for computers and mobile devices. Your browser and our Services may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities.

How We Use the Information We Collect

We may use the Personal Information we collect for the following purposes:

• To provide, operate, maintain, and improve our Services, including account creation, authentication, and functionality;
• To fulfill or meet requirements inherent in the reason you provided the information. For example, we use information about who you follow on Parler to deliver a feed of posts from those accounts; we use information you include in a post to display it to users who follow you, users who share your post, or users who visit your profile on Parler;
• To create, customize, and secure your account for use of the Services;
• To provide, maintain, and improve our Services, including for testing, research, analysis and product development;
• To personalize your experience on our Services, such as by providing tailored content and recommendations;
• To understand and analyze how you use our Services and develop new products, services, features, and/or functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• Certain features of our Services involve blockchain technology, including features that allow you to send tips, boost posts, or engage in transactions using digital assets. When you use a blockchain-enabled feature, certain transaction data, including wallet addresses and transaction details, may be recorded on a public blockchain or distributed ledger. Information recorded on a public blockchain is generally immutable and may be publicly accessible. We do not store, manage, or control your wallet, private keys, seed phrases, or other digital asset credentials. You are solely responsible for the security and management of your digital assets and credentials. You should not include sensitive Personal Information in any content or message associated with a blockchain transaction. Additional terms and risk disclosures applicable to blockchain-enabled features are set forth in our Terms of Service;
• 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, including providing you with targeted offers and ads through our Website, and via email or text message (with your consent);
• To send you text messages and push notifications;
• To facilitate transactions, redemptions, purchases, payments, and other commerce-related features;
• To verify your identity and determine your eligibility to participate in creator, influencer, monetization, or other platform programs;
• To find and prevent fraud and respond to trust and safety issues;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred;
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process, law enforcement or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without updating this Privacy Policy to provide you with notice as set out in Section 11 "Changes to the Privacy Policy" below.

How We Share the Information We Collect

Vendors and Service Providers. We share Personal Information with vendors and service providers retained in connection with the provision of our Services. These include providers of payment processing (Stripe), SMS delivery, push notification delivery (Firebase Cloud Messaging), authentication (Apple Sign-In, Google Sign-In), content moderation (including Hive Moderation for CSAE detection and other safety tools), cloud hosting and storage, analytics, customer support, and email delivery. Service providers are authorized to use Personal Information only as necessary to provide services to us and are required to maintain the confidentiality and security of that information.

Content you Share. Our Services are social services which allow you to find, enjoy, and share content. Your name, display name, profile photo, about me section, and contacts (i.e., users you are following) will always be viewable and/or searchable by other users. The content you post to our Services will be displayed and viewable by other users by default. Although this content is public by default, in the "Your Choices" section below, we describe the account settings and controls you can use to limit the sharing of certain information. We are not responsible for other Members' use of available information, so you should carefully consider whether and what to post and how you identify yourself on our Services.

Marketing. We do not share your Personal Information with nonaffiliated third parties for their own direct marketing purposes without your consent. We may use your information to provide marketing and advertising within our Services or through service providers acting on our behalf. Where required by applicable law, we will provide you with choices regarding such use.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal 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 Personal Information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers. We may transfer your Personal 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 Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time of the acquisition or merger.

Consent. We may also disclose your Personal Information with your permission.

Your Choices

Sharing Preferences. We provide you with settings to allow you to set your sharing preferences for content you post to our Services. Certain Personal Information, such as your display name, may always be publicly available to others, and other Personal Information is made publicly available to others by default. To change whether certain information is publicly viewable, you can adjust the settings in your account.

SMS Messaging Preferences. If you opt to send SMS invitations via Parler, you can manage your preferences for these communications within your account settings. Additionally, you can choose not to send SMS invitations or revoke permissions for such features at any time.

Marketing Communications. We send you marketing communications consistent with your choices. You can unsubscribe from our promotional emails by adjusting your account settings or via the link provided in the emails. Similarly, if you change your mind about receiving promotional text messages after having opted-in, you may follow the opt-out directions sent with each text. Note: Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Notifications. You can opt-out of receiving notifications for posts, shares, comments, and followers by adjusting your profile and/or operating system (i.e., iOS or Android) settings.

Correction. You may correct your Personal Information at any time by logging in to your account and updating any inaccurate information.

Additional Privacy Rights. In addition, State and European Economic Area consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Please see the additional rights sections below for more information.

Third Party Links and Sites

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

For example, interactions with third-party services such as Google or YouTube through our Services are governed by the privacy policies of those third parties. We encourage you to review the privacy policies of any third-party services before interacting with them or providing your information. You may have options to manage or revoke access to your data through the settings provided by those third parties.

Security

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.

Children's Data

Our Services are not directed to children under 13 years of age, and we do not knowingly collect, maintain, or use Personal Information from children under 13. If we become aware that a child under 13 has provided Personal Information in violation of this Privacy Policy, we will take steps to delete such information.

Users must be at least 18 years of age to create an account and use our Services. If we learn that an individual under 18 has created an account or provided Personal Information in violation of our Terms of Service, we may take steps to suspend or remove the account and delete such information, as appropriate.

If you believe that a minor has provided us with Personal Information in violation of this Privacy Policy, please contact us at privacy@parler.com so that we can take appropriate action.

For purposes of applicable data privacy laws, including rights related to the sale or sharing of Personal Information, we do not knowingly sell or share the Personal Information of consumers under 16 years of age.

International Transfers of Data

Our Services are hosted in the United States. If you access our Services from outside the United States, including from the European Economic Area ("EEA"), your Personal Information will be transferred to, stored, and processed in the United States and other jurisdictions where our service providers operate.

Where required by applicable law, we rely on appropriate safeguards to transfer Personal Information outside of the EEA, including the European Commission's Standard Contractual Clauses ("SCCs"), or other lawful transfer mechanisms as recognized under applicable data protection laws.

We take steps designed to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which it is processed, including through contractual, technical, and organizational measures.

You may request additional information about the safeguards we use for international transfers by contacting us at privacy@parler.com.

If you are located in the European Economic Area, you may have additional rights as described in the "Additional Rights in the European Economic Area" section below.

Update or Delete Your Information

You can update your account and profile information through your account settings. You can delete your account by selecting that option via your account settings.

Data Retention

We retain your Personal Information for as long as your account is active and as needed to provide the Services, comply with our legal obligations, resolve disputes, prevent fraud, and enforce your agreements and policies. When you delete your account, we delete or de-identify your Personal Information within a reasonable period, except for information we are required or permitted to retain, including:

• Records required for tax, accounting, or other regulatory purposes;
• Information necessary to enforce our Terms of Service or resolve disputes;
• Information necessary to detect, investigate, or prevent fraud, abuse, or illegal activity;
• Direct messages received by other users, content reposted or saved by other users, and other content shared with the Parler community, which may persist after your account is deleted;
• Transaction data recorded on a public blockchain, which is generally immutable and cannot be deleted.

Usage and analytics data may be retained in aggregated or de-identified form for longer periods to support security, analytics, and service improvement.

Changes to the Privacy 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 share Personal Information previously collected from you through our Services, we will notify you through our Services, by email, or other communication. Your continued use of our Services following our posting or notifying you of changes constitutes your acceptance of such changes.

Additional Rights in Your State

State consumer privacy laws may provide you with additional rights regarding our use of your Personal Information. Residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have additional rights, which may include:

• The right to know what personal data is collected;
• The right to access and obtain a copy of personal data;
• The right to correct inaccuracies in personal data;
• The right to delete personal data;
• The right to opt out of the sale or sharing of personal data;
• The right to opt out of targeted advertising and profiling;
• The right to appeal decisions related to these rights.

Note that Personal Information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the scope of consumer privacy laws. Certain state legislation, including the California Consumer Privacy Act of 2018 ("CCPA") protects various categories of Personal Information.

Your Rights and Choices

Data privacy legislation provides consumers in certain states with specific rights regarding their Personal Information. This section describes your data privacy rights if you are a California resident and explains how to exercise those rights.

Right to Know and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• If we disclosed your Personal Information for a business purpose, two separate lists disclosing: sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
• The specific pieces of Personal Information we collected about you (also called a "data portability request").

Right to Delete. You have the right to request that we delete any of your Personal Information that we have collected and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an applicable exception allows us to retain the information. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete. To exercise your rights to know or delete described above, please submit a request by emailing privacy@parler.com or by using the in-app feedback form. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information by submitting proof of identity and, in the case of someone legally authorized to act on your behalf, proof of their authority to act. You may also make a request to know or delete on behalf of your child by providing proof of identity.

Response Timing and Format. We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will cover the 12-month period preceding our receipt of your request.

Personal Information Sales Opt-Out and Opt-In Rights

Applicable data privacy laws may define "sale" or "sharing" of Personal Information broadly. While we do not sell your Personal Information in the traditional sense or share your Personal Information with third parties for their own direct marketing purposes without your consent, certain data practices, such as the use of analytics providers, advertising partners, or similar technologies, may be considered a "sale" or "sharing" under applicable law.

Where required by law, we provide you with the right to opt out of the sale or sharing of your Personal Information. You may exercise this right by contacting us at privacy@parler.com or through available in-app controls.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

Non-Discrimination

We will not discriminate against you for exercising any of your data privacy rights. Unless permitted by state legislation, we will not deny you goods or services, charge you different prices or rates, provide you a different level or quality of goods or services, or suggest that you may receive a different price, rate, level, or quality of goods or services.

However, we may offer you certain financial incentives permitted by data privacy legislation that can result in different prices, rates, or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

SMS Legal Requirements

Consent: By providing your phone number and opting in to receive SMS messages from us, you consent to the receipt of such messages. You may withdraw your consent at any time by following the instructions provided in our SMS messages or by contacting us directly.

Message Frequency: You may receive SMS messages from us with varying frequencies, including promotional offers, transactional updates, or account notifications. Message frequency may vary based on your interaction with our services.

Opt-Out Mechanism: To stop receiving SMS messages from us, you can reply with the word "STOP" to any message you receive. Alternatively, you may contact us directly to request removal from our SMS messaging list.

Data Usage: We will only use your phone number and other personal information collected for SMS messaging purposes in accordance with our Privacy Policy. Your data will be handled securely and in compliance with applicable laws and regulations.

Data Sharing: We do not sell, rent, or lease your phone number or other personal information to third parties for SMS marketing purposes. Your information may be shared with service providers who assist us in delivering SMS messages or managing our SMS messaging platform.

Legal Compliance: Our SMS messaging activities are conducted in compliance with relevant laws and regulations, including but not limited to the Telephone Consumer Protection Act (TCPA) in the United States and the General Data Protection Regulation (GDPR) in the European Union.

Additional Rights in the European Economic Area

If your personal data has been collected in connection with our activities in the European Economic Area ("EEA"), you have the following rights:

• Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data.
• Access: You have the right to access your personal data.
• Rectification: You have the right to rectify inaccurate personal data.
• Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent, or you object to its processing.
• Restriction: You have the right to have the processing of your personal data restricted under certain circumstances.
• Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format.
• Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes.

In order to exercise any of these rights, or for more information, please use the contact details specified in the Contact Information section below. Please note that these rights are subject to certain preconditions and qualifications under applicable law. The right to erasure is not absolute and it may not always be possible to erase personal data on request, including for example where the Personal Information must be retained to comply with a legal obligation.

If you are in the EEA, you may lodge a complaint with a supervisory authority in your country or region. Parler is the data controller with respect to processing of your Personal Information in connection with the Services.

Contact Information

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at privacy@parler.com or write to us at Sovren Technologies, Inc., Attn: Privacy Request, 2801 Network Boulevard, Suite 300, Frisco, TX 75034. To exercise your privacy rights, please email privacy@parler.com or use the in-app feedback form.