FRESHPAINT PRIVACY POLICY

Last Update: August 6, 2026

This Website Privacy Policy (“Privacy Policy”) provides information regarding how Perfalytics, Inc. doing business as Freshpaint (“Freshpaint” or “We”) collects, uses and transfers personally identifiable information (“Personal Data”) from you through Freshpaint’s publicly accessible Website (http://www.Freshpaint.io) (the “Website” or “Site”). For convenience, the Site and our services are collectively referred to as the “Service.” Consent is implied when users start using this site. You may update your preferences and privacy choices using the red cookie icon on the bottom right corner of the Site at any time. If Freshpaint decides to make changes to this Privacy Policy, Freshpaint will post the changes on this Website so that you will know what Personal Data We collect, and how We use it. We therefore encourage you to periodically look for updates to this Privacy Policy. This Privacy Policy describes how Freshpaint makes use of your Personal Data and your rights regarding the same. 


1. THE FRESHPAINT SERVICE
Registered customers of the Service (“Clients“) use it to collect information about how their own users use Client websites, applications, services (“Client Services”) and related third-party applications (“Client Services Data”). Clients also use the Service to more efficiently route Client Services Data to their own third party applications/services and control how their own third party applications/services exchange Client Services Data. Freshpaint does this by collecting data on what users are doing, including but not limited to what webpages they visit, what users click on, where those users are located, what browser or platform those users are using, and many other forms of behavioral or personal data. Client Services Data may include, without limitation, information about the identity of Client users (such as name, postal address, e-mail address, IP address, and phone number), as well as information about the pages users visit, the features they use, and the actions they take while using the Client Services. 

This Privacy Policy applies to our marketing Website; it does not apply to Client Services Data or to Client Services, and We are not responsible for our Clients’ handling of Client Services Data. Our Clients have their own policies regarding the collection, use, and disclosure of your personal information. To learn about how a particular Client handles your personal information, We encourage you to read the Client’s privacy statement. Our use of Client Services Data provided by our Clients in connection with our Service is subject to the written agreement between Freshpaint and Client.

2. COLLECTION OF PERSONAL DATA
When you request information on the Website, subscribe to a mailing list or for a service, respond to an online survey or otherwise actively send us data, We usually collect data such as:

  • your name
  • e-mail address
  • mailing address
  • telephone number, and
  • certain information related to the business you represent such as number of employees and industry type.

If you receive services from us and inadvertently disclose personal health information to us, We may collect and store such personal health information also. This is limited only to customers who work with personal health information and collect personal health information. It is your responsibility to not disclose personal health information to Freshpaint. You may opt out of providing information by not entering it when asked and, if such information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this.

When you visit the Website, We also track information on your computer and your internet connection, such as but not limited to: IP address and internet service provider, when you access the site, the IP address of websites from which you connect to our Website, and the computer systems you are using and your use or preferences on our Site. We may also automatically record certain information from your device by using various types of technology, including:

  • clear gifs or web beacons,
  • information from your device by using various types of technology, including clear gifs or web beacons,
  • your IP address or other device address or ID,
  • web browser and/or device type,
  • the web pages or sites that you visit just before or just after you use our Website,
  • the pages or other content you view or otherwise interact with through our Websites, and
  • the dates and times that you visit, access, or use our Website.

We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users and may be connected with other information about you.When you use our Website, We may send one or more cookies (small text files containing a string of alphanumeric characters) to your device. 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 Sites. Your web browser may provide you with some options regarding cookies. Please note that if you delete, or choose not to accept, cookies from our Websites, you may not be able to utilize the features to their fullest potential. We may use third party cookies in connection with our Website.

3. USE AND PURPOSE OF COLLECTED PERSONAL DATA
We use the information that We collect on or through our Website to:

  • operate, maintain, enhance, and provide all features of our Website,
  • provide services and information that you request,
  • respond to comments and questions and otherwise to provide support to users,
  • to process and deliver entries and rewards in connection with promotions that We may offer from time to time,
  • measure advertising effectiveness and to conduct personalized advertising, 
  • understand and analyze the usage trends and preferences of our users, to improve our Website, and to develop new products, services, features, and functionality, and
  • contact you for administrative purposes such as customer service or to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties.

4. GLOBAL PRIVACY CONTROL AND PREFERENCE MANAGEMENT

We honor Global Privacy Control (GPC) signals. When We detect a valid GPC signal from your browser or device, We will treat that signal as a request to opt out of cookie-based processing and similar technologies for purposes that are subject to such opt-out rights. Please note that your browser-based GPC signal and the preferences you select in our Preference Center may apply differently depending on your browser, device, and the scope of the signal or setting. We may still use cookies or similar technologies that are necessary for the operation, security, and functionality of our website.

You can manage your cookie preferences at any time through our Preference Center. To access the Preference Center, click the red cookie icon in the bottom right corner of the Site.Through the Preference Center, you can review and adjust your choices regarding cookies and similar tracking technologies used on our site.

5. LEGAL BASIS OF PROCESSING PERSONAL DATA
We typically collect and/or process your Personal Data when We have a legitimate business interest or your specific consent. 

6. KEEPING YOUR PERSONAL DATA SECURE
To protect your Personal Data We use appropriate technical measures corresponding to the type of Personal Data and the risks associated with processing such Personal Data. In the event of a data breach, We will contact those affected and to the extent as required by applicable law.

7. PERSONAL DATA SHARED WITH THIRD PARTIES
Unless you have opted out from receiving commercial communications from Freshpaint, We also may share contact information (that We collect through various marketing efforts) with trusted business partners, such as system integrators, distributors, and referral partners. We may share personal information for legal, protection, and safety purposes; to comply with laws; to respond to lawful requests and legal processes; to protect our rights and property including but not limited to enforcing our agreements, policies, and terms of service. We may also share information in an emergency. We may share or transfer your information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. We may share your information for advertising purposes. Also, We reserve the right to fully use and disclose any information that is not in personally identifiable form (such as statistics and survey results that do not identify you individually by name). We may also share aggregated and/or anonymized data with others for their own uses. We may also share any information that you voluntarily choose to include in a publicly accessible area of the Sites will be available to anyone who has access to that content, including other users.

8. PAYMENT INFORMATION
Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe and We never receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/us/checkout/legal.

9. RETENTION OF PERSONAL DATA
We may retain your Personal Data in connection with our ongoing legitimate business interest. When an ongoing legitimate business interest with respect to your Personal Data no longer exists We will delete such Personal Data.

10. YOUR RIGHTS WITH RESPECT TO PERSONAL DATA
Object to processing and opt-out.
In connection with promotions or other projects, We may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt-out under such circumstances, We will respect your decision. To opt out of receiving commercial communications from Freshpaint please click on the “opt-out” link in the communication or, please contact us at privacy@Freshpaint.io. Please note that our affiliates and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests. In connection with promotions or other projects, We may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt out, We may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. 

You may also update your cookie preferences at any time using the red cookie icon in the bottom corner of the Site.

Correct or Update. You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.If personal information you have submitted through the site is no longer accurate, current, or complete, and you wish to update it, please send an e-mail to privacy@freshpaint.io. Upon appropriate request We will usually update or amend your information, but We reserve the right to use information obtained previously to verify your identity or take other actions that We believe are appropriate.You may request that We delete your personal information as well as request that We make your personal information available for porting.Withdraw consent.You may withdraw your consent at any time, but such withdrawal shall only apply with respect to any processing after such withdrawal and you may request that Freshpaint make your Personal Data portable and make such Personal Data available to you. Right to complain.You may complain to a data protection authority regarding the use or collection of your personal information. Please contact your local data protection authority for more information regarding how to file such a complaint.

11. IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
If a visitor is a California resident, certain Personal Information that We collect about visitors is subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

Collection of Personal Information: 

Section 2 above describes the personal data We may collect, use and share. The information referenced in Section 2 may fall into certain categories defined by CCPA and CPRA. As such, Freshpaint may collect:

  • Identifiers
  • Personal information categories listed in California Customer Records Statute (California Civil Code § 1798.140(o))
  • Professional or employment-related information
  • Geolocation data
  • Business or commercial information 
  • Financial information
  • Internet or other similar network activity
  • Sensory information
  • Inferences

Like many companies online, Freshpaint uses services provided by Google, Meta, and other advertising companies that track website visitor activity to deliver interest-based advertising. California laws define a “sale” broadly to include the sharing of information in exchange for anything of value. As such, this activity may constitute a "sale" or "share" of personal information under specific state consumer privacy law, including in California. 

We may further disclose each category of Personal Information to our affiliates, to our professional advisors, in connection with our compliance and protection activities and in connection with business transfers as described in Section 7. 

Your California privacy rights include:

  • Right to know what personal information We collect
  • Right to delete personal information
  • Right to opt-out of sale or sharing
  • Right to correct inaccurate information
  • Right to limit use of sensitive personal information
  • Right to data portability
  • Non-discrimination for exercising your rights

‍How to exercise your information, access, and deletion rights. You may submit a request to exercise your information, access or deletion rights by visiting emailing privacy@freshpaint.io. We will need to verify your identity to process your information, access and deletion requests and We reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, We will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, We may be required or permitted by law to deny your request.

12. INTERNATIONAL USERS

Freshpaint does not service international users. Our website is operated by Freshpaint from the United States and is not intended to subject Freshpaint to the laws or jurisdictions of any state, country, or territory outside of the United States. 

13. HOW TO CONTACT FRESHPAINT REGARDING PERSONAL DATA
We welcome your comments or questions about this privacy policy. You may also contact us as follows: Email address: privacy@Freshpaint.io. Mailing Address: Perfalytics, Inc. (dba Freshpaint) 584 Castro St#2409, San Francisco, CA 9411