Privacy policy

PRIVACY POLICY
Last updated April 20, 2024
This privacy notice for Curbar Lothian Ltd ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use
our services ('Services"), such as when you:
Visit our website at https://www.chorusbirds.com/,or any website of ours that links to this privacy notice
- Download and use our mobile application (Chorus), or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please
do not use our Services. If you still have any questions or concerns, please contact us at hello@chorusbirds.com.

SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key
point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us
and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid
legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of
third parties. Learn more about when and with whom we share vour personal information.
How do we keep your information safe? We have organisational and technical processes and procedures in place to protect our personal information. However, no
electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more
about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal
information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise vour riahts is by visiting hello@chorusbirds.com. or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
Want to learn more about what we do with an information we collect? Review the privacy notice in full.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In Short: We collect personal information that vou provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products
and Services, when vou participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- mailing addresses
- usernames
- passwords
- contact preferences
- contact or authentication data
- billing addresses
- debit/credit card numbers
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code
associated with your payment instrument. All payment data is stored by shopify.com/uk. You may find their privacy notice link(s) here:
https://www.shopify.com/uk/legal/privacy.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called 'HOW DO WE HANDLE YOUR SOCIAL
LOGINS? below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are
using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, vou may do so in vour device's
settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, camera,
microphone, sms messages, and other features. If you wish to change our access or permissions, vou may do so in vour device's settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from
receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information -
- such as vour Internet Protocol (IP) address and/or browser and device characteristics -
- is collected automaticallv when vou visit our
Services.
We automatically collect certain information when vou visit, use, or navigate the Services. This information does not reveal vour specific identity (like vour name or contact
information) but mav include device and usage information. such as vour IP address, browser and device characteristics, operatina svstem. language preferences.
referrina URLs, device name, country, location, information about how and when vou use our Services, and other technical information. This information is primarilv
needed to maintain the securitv and operation of our Services, and for our internal analvtics and reportina purposes.

The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or
use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser
type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches,
and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and
hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser
type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data
that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or
by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
We mav also process vour information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We mav process our information so vou can create and log in to
vour account, as well as keep our account in workina order.
, To deliver and facilitate deliver of services to the user. We mav process vour information to provide vou with the reguested service

- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might
have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and
policies, and other similar information.
- To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the
Services.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to
prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business
interests.
The General Data Protection Requlation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw
your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including
providing our Services or at our request prior to entering into a contract with you.

- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests
do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described
in order to:
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as
situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third
parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are
designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it.
They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the
period we instruct. The categories of third parties we may share personal information with are as follows:
User Account Registration & Authentication Services
We also may need to share our personal information in the following situations:
, Business Transfers. We may share or transfer our information in connection with, or during negotiations of, any merger, sale of company assets, financing, or

- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- Offer Wall. Our application(s) may display a third-party hosted 'offer wall'. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you
based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website
belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent
fraud and properly credit your account with the relevant reward.
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do
this. we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media
provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a
social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for, other uses of our personal information by your third-party social media provider. We recommend that you
review their privacy notice to understand how they collect, use, and share your personal information, and how you can set our privacy preferences on their sites and
apps.
6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the
period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible
(for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further
processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to
and from our Services is at your own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent

or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may
have collected from children under age 18, please contact us at info@curbarlothian.Itd.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and
control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and
obtain a copy of your personal information, (il) to request rectification or erasure; (ili) to restrict the processing of your personal information; (iv) if applicable, to data
portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal
information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'
below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State
data protection authority, or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or
updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary
for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements
If you have questions or comments about your privacy rights, you may email us at hello@chorusbirds.com
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing
DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to
be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy
notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon
as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you
a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Thomas Giles, by email at info@curbarlothian.Itd, contact us by post at:
Curbar Lothian Ltd
Thomas Giles
5 South Charlotte Street,
EDINBURGH. Mid Lothian EH24AN
United Kingdom
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete
it. To request to review, update, or delete your personal information, please visit: hello@chirple.co