First Chair Privacy Policy

Last modified: August 5, 2026

Introduction

This Privacy Policy outlines Kassa Labs, Inc.'s (doing business as First Chair) ("we", "our" or "the Company") practices with respect to information collected from users who access our website (the "Site") or communicate with us in any other way (collectively: "Users").

We encourage Users to carefully read the Privacy Policy and use it to make informed decisions.

In this Privacy Policy you can read about:

What type of information we collect
How we use and with whom we share the information
User rights
For how long we retain the information
How we safeguard the information
How to contact us

What Information we collect?

We may collect individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information includes:

Contact information: your name, email address, phone number, delivery address, and other information you provide when contacting us or using the Services.
Purchase and payment information: products, quantities, Retailers, order and payment status, processor identifiers, delivery details, refunds, and disputes. Payment providers process full payment credentials on our behalf.
Quote and calculation information: Retailer-Stated Reference Prices, validation sources and timestamps, First Chair savings, Credit, fees, delivery, taxes, and Total Due Today.
Credit Program information: Credit type, balance, issuance, expiration, redemption, reversal, restoration, promotion, and manual-adjustment records.
Fulfillment and post-purchase information: shipment, delivery, cancellation, return, damage, incorrect-item, refund, chargeback, complaint, and dispute information.
Communications information: quote and order messages, acceptance records, email preferences, SMS consent and opt-out records, message history, delivery records, phone number, source, timestamp, and the disclosure version presented.
Device information: geolocation data, IP address, unique identifiers, and information concerning your activity through the Site or Platform.

If we associate Non-personal Information (information that cannot lead to the identification of an individual) with Personal Information, we will treat it as Personal Information while the information remains combined.

How is the information used? With whom do we share the information?

We do not rent or sell Users' Personal Information. We use Personal Information to provide and support the Services; communicate about Accounts, designs, projects, quotes, orders, delivery, billing, returns, and disputes; validate prices and savings; calculate fees and Credit; process payments; coordinate with Retailers and delivery providers; prevent fraud and abuse; substantiate price and savings statements; comply with tax, accounting, recordkeeping, and legal duties; enforce our policies; and analyze and improve the Site and Services.

We may send service-related communications by email or, subject to any required consent, SMS. Separately, we may send marketing email or recurring automated marketing SMS in accordance with applicable law and the choices you make. You may unsubscribe from marketing email through the email link. You may revoke marketing SMS consent by replying STOP or another supported opt-out keyword, or by contacting us. We maintain suppression records to honor your choice.

We may share the Personal Information reasonably needed for these purposes with our affiliates and service providers, including Retailers and suppliers; payment and fraud-prevention providers; shipping and delivery providers; cloud hosting, analytics, accounting, tax, customer-support, and recordkeeping providers; and email, SMS, and telecommunications providers. These parties may use the information only for the permitted purpose and under applicable agreements.

We do not sell or share mobile phone numbers, SMS consent, or SMS opt-in or opt-out data with third parties or affiliates for their own marketing or promotional purposes. We may provide this information to service providers that help us deliver our messaging program, or when required by law. We do not permit Retailers to use information received from us for unrelated marketing unless you separately consent.

We may also disclose the minimum Personal Information reasonably necessary to comply with law or legal process; enforce our policies; investigate fraud, security issues, or wrongdoing; establish or defend legal claims; protect rights, property, or safety; or cooperate with law enforcement.

User Rights

Depending on your jurisdiction you may have the following rights - (1) Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information; (2) Receive a copy of Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your Personal Information that is in our control; (4) Request erasure of your Personal Information; (5) Object to the processing of Personal Information by us; (6) Request to restrict processing of your Personal Information by us.

If you feel that your Personal Information was not handled properly, you may lodge a complaint with the applicable regulator.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us at support@firstchair.app.

Retention

We retain Personal Information only as long as reasonably necessary for the purpose collected and to provide Services, comply with legal, tax, accounting, warranty, and unclaimed-property duties, resolve disputes, prevent fraud, and enforce our policies.

Record	Retention Approach
Orders, quotes, payments, taxes, delivery, returns, and disputes	For the applicable transaction, accounting, tax, warranty, dispute, and legal periods
Credit ledger and adjustments	For the life of the balance plus applicable accounting, dispute, tax, and unclaimed-property periods
Retailer reference-price evidence	Through applicable advertising, dispute, and legal limitation periods
SMS consent, disclosure, message, delivery, complaint, and opt-out records	At least 4 years after the last SMS message to the User, or longer where required
Marketing email suppression records	As long as needed to honor the opt-out

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We may retain information longer for a legal hold, investigation, dispute, fraud prevention, or other legal obligation. When retention is no longer necessary, we delete, deidentify, or securely isolate the information in accordance with our practices and applicable law.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Access to commerce and Credit information is limited based on job need, and material manual Credit adjustments should be logged with the actor, time, reason, and before-and-after values.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

The Site is intended for the use of individuals over the age of 18. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a child under 18 has shared any information with us, please contact us at support@firstchair.app.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Site or services, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at support@firstchair.app.