Privacy Policy

1. Personal Information We Collect

2. How We Use Personal Information

We may use Personal Information for the following purposes:

• To provide, operate, and improve the Service and our business;
• To respond to your inquiries, comments, feedback, or questions;
• To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To verify your identity and location;
• To process payments and transactions;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks;
• To deidentify and/or aggregate and anonymize your Personal Information for our own business purposes; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Research and Development: We may aggregate Personal Information and use the aggregated and deidentified information to analyze the effectiveness of the Service, to improve and add features to the Service, gain anonymous insights into product and performance on the Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of Users and share aggregated information like general user statistics with prospective business partners. We will maintain and use the information in deidentified form and will not attempt to identify the information, except for the purpose of determining whether our deidentification process satisfies the requirements of the CCPA, and any other uses allowed under applicable law.

Communications and Marketing: We may use your Personal Information, such as your email address, to contact you to provide the Service and communicate Personal Information, such as your email address, to contact you to provide the Service and communicate related information. If you provide your telephone number, you acknowledge and agree that we may contact you, including but not limited to for promotional, informational and other purposes, using SMS text messages, cellular or telephone calls, and push notifications (if applicable) even if you have opted in to the US National Do Not Call List, any state equivalent Do Not Call List or the internal Do Not Call List of any business, and that such messages and calls may be sent using automatic dialing systems or artificial or prerecorded voice messages.

How Long We Keep Your Information: We will only keep your Personal Information for as long as it is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize 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.

If you would like to opt-out of receiving certain communications, see the Your Choices section below.

3. Sharing and Disclosure of Personal Information

In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively and each a "Transaction"), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with a Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, including to meet national security or law enforcement requirements, (b) protect and defend our rights or property, (c) prevent fraud, (d) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (e) protect against legal liability.
• Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Palm. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Notice. Affiliates may be located outside the United States of America.
• Other Users: The Service may contain a community forum and message board where Users are able to create profiles, writings, reviews, photographs, ideas, videos, audio recordings, computer graphics, pictures, data, or other content, including Personal Information (collectively, "User Content"). The Service may display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it.
• Discretion/Consent: We may share your Personal Information at your discretion, including when you submit a product review using a third-party service or otherwise direct us to disclose your Personal Information to a third party. We may also share your Personal Information with your consent.

4. Users Outside of the United States

For the purposes described in this Privacy Notice, we may transfer your Personal Information from the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) and/or the United Kingdom to our U.S. office or a third party outside of the EEA or the UK and in a jurisdiction not subject to an adequacy decision of the European Commission or the UK Government, as applicable.
When we transfer your Personal Information to other third parties outside of the EEA or the UK, for example service providers, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure the integrity and protection of your Personal Information wherever processed. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country.
However, we will take all necessary measures to protect your Personal Information in accordance with this Privacy Notice and applicable law. By providing your Personal Information, you consent to such transfer.

Your Rights in Relation to Your Personal Data Under GDPR and/or UK GDPR: Subject to the applicable provision of the GDPR and/or UK GDPR, you have the following rights with respect to your Personal Information:

• Right of access (commonly known as a "data subject access request"): If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Information is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
• Right to erasure: You may ask us to erase your Personal Information in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and there is no other legal basis for processing.
• Right to restrict processing: You may ask us to restrict or 'block' the processing of your Personal Information in certain circumstances, such as if you contest its accuracy or object to us processing it.
• Right to data portability: You have the right to obtain your Personal Information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
• Right to object: You may ask us at any time to stop processing your Personal Information, and we will do so: (a) if we are relying on a legitimate interest (described above) to process your Personal Information, unless we demonstrate compelling legitimate grounds for the processing or your information is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
• Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time, but this will not affect any processing of your information that has already taken place.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns (in the United Kingdom, the Information Commissioner's Office (ICO) at https://ico.org.uk/concerns.

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
• For investigations and fraud detection and prevention;
• For business transactions provided certain conditions are met;
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
• For identifying injured, ill, or deceased persons and communicating with next of kin;
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
• If the collection is solely for journalistic, artistic, or literary purposes; or
• If the information is publicly available and is specified by the regulations.

5. State Privacy Rights

Where provided for by law and subject to any applicable exceptions, residents of certain states may have additional rights. If you are a California resident, please see our California Privacy Notice[NW1]. If you live in the state of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Utah, Virginia, and effective in 2025 in Delaware, Iowa, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Tennessee, or in locations with similar laws, you may have such rights. These rights are not absolute, and in some cases, they may not apply, including if a legal exception applies. If this is the case, we will not be able to process your request.
The rights include:

• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out of Targeted Advertising: The right to opt out of the processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
• Right to Limit Use and Disclosure of Sensitive Information: In some cases, you may have the right to ask that we limit the way we use your Personal Information. In some cases, you can exercise this right by asking that we delete your Personal Information. You may also have the right to object to how we process Personal Information, or to withdraw your consent if our use is based on consent.

6. Children

We do not intentionally collect Personal Information from individuals in the U.S. who are under the age of 13. If a child under 13 submits Personal Information to Palm and we learn that the Personal Information is the information of a child under the age of 13, we will attempt to delete the information as soon as possible.
If you believe that we might have any Personal Information from a child under the age of 13, please contact us as set forth in the "Contact Us" section below.

7. Links To Other Websites

The Service may contain links to other websites and services not operated or controlled by Palm, including social media services ("Third Party Services"). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Notice.
By providing these links we do not imply that we endorse or have reviewed these Third Party Services. Please contact the Third Party Services directly for information on their privacy practices and policies.

8. Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free.
In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Palm via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or Third Party Services.

9. Your Choices

In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to request updates or corrections to your Personal Information.
If you have questions or concerns about other Personal Information collected by us, or are unable to use your Palm account and would like assistance accessing that information, please contact us as set forth in the "Contact Us" section below.

You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you, or by updating your you, or by updating your settings through your account. If you unsubscribe from our marketing lists, you will no longer receive marketing communications from us but we will continue to contact you to provide the Service, regarding management of your account, other administrative matters, and to respond to your requests.

10. Changes To the Privacy Notice

The Service and our business may change from time to time. As a result, we may change this Privacy Notice at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Notice, you consent to the revised Privacy Notice and practices described in it.

11. Contact Us