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Website Privacy Policy

(last revised on November 24, 2020)

[24]7.ai, Inc., on behalf of itself and its affiliated companies (collectively, "[24]7.ai" or the “Company”), has adopted the following Privacy Policy in furtherance of respecting online privacy and recognizing the need for appropriate protection and management of the personally-identifiable information we may receive from visitors to this United States-based website ("Personal Information"). Specifically, Personal Information means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

General Framework

The Company is committed to compliance with all applicable laws, regulations and rules governing the privacy of information it collects and the attendant rights of the subjects of such information. This commitment includes full compliance with the General Data Protection Regulation of the European Union (GDPR) as well as with applicable federal and state requirements of the United States of America, and with applicable laws in the jurisdictions in which we operate. We also participate in and have certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. [24]7.ai is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list

[24]7.ai is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, [24]7.ai is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. Any complaints, or unresolved privacy or data use concerns can be directed to our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

APEC Participation

[24]7.ai’s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here

Collection of Personal Information

For those persons from the European Economic Area: Under most circumstances, we collect personal information from you only if you have provided consent, or such collection is required in order for us to perform our contractual obligations, or where it is in our or a third party’s legitimate interests, but only if such interests are not outweighed by your data protection interests or fundamental rights and freedoms. There may be certain circumstances where we have a legal obligation to collect personal data, or collecting your data would be to protect your vital interests or those of another person. If you have any questions about the legal basis on which we collect your personal information, please contact us.

This Privacy Policy applies to all information submitted by you (or passively collected from you) on this website, including Personal Information and any information you may have provided through an application for employment either through this website or through a third party (“Applicant data”). There are times, when we may need you to provide Personal Information (such as your name, phone number, email address and postal address) to be able to provide you with the information, service or product you have requested. You may be asked to provide such Personal Information through completing a form on this website. You are not obligated to provide this Personal Information, but you may not be able to get the products, services or information you requested without it.

We may use Personal Information we collect to support our clients in customer engagement and customer acquisition efforts, to contact you regarding a job position for which you have applied, and to optimize customer website experiences on client websites. We may also use your Personal Information to correspond with you or to provide you with information on-line, such as a newsletter. Also, if you provide us with your Personal Information, then we may attempt to contact you, either by phone or email, to see whether we can provide you with additional information or to share information about a product or service that we think you might find interesting. In addition, if you chose to have a business relationship with [24]7.ai, such as a contractual or other business relationship or partnership, we will naturally continue to contact you in connection with that business relationship.

We sometimes monitor who visits this website and for how long (using cookies and other tracking technologies, as described in the next section) and we may attempt to initiate a chat session with this website’s visitors. You may opt out of participating in the chat session by either closing the chat window or responding that you do not care to engage in a chat session.

We may also collect from you, personal information about your contacts such as name and email address in order to forward a job posting. When you provide us with personal information about your contacts, we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at [email protected].

If you desire to revoke your consent to our use of the data as set forth herein, you may do so by contacting us at [email protected]. Upon receipt of notification from you, we will no longer collect or use the personal data as set forth herein, but will retain personal information as long as needed to comply with our legal and business obligations.

International Transfer of Personal Information

[24]7.ai stores Personal Information in the United States. It is possible that we may transfer and access Personal Information from other countries where [24]7.ai has operations. If this is the case, [24]7.ai will transfer Personal Information in conformity with guidelines set forth in the Privacy Shield Framework. Use of our website constitutes agreement to the transfer of any Personal Information we collect from you to the United States and/or other countries in which we operate. [24]7.ai commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Cookies, IP Addresses and Other Tracking Technologies

Some parts of this website utilize "cookies" and other third party tracking technologies (such as beacons, tags, and scripts) to analyze trends, administer the site, track users’ movements around the site, to collect information about your activity on this and other websites, and gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you disable the use of cookies, it may limit your use of certain features or functions on our website or service. Some cookies and other technologies may serve to recall Personal Information previously supplied or collected by you.

Another method through which we collect aggregate information is the collection of IP addresses. An IP address is a unique number that is automatically assigned to your computer when you access the Internet. Web servers automatically identify your computer by its IP address. When you access this website, our, and our third party analytics as well as other partners, web servers log your IP address. Other tracking technologies may record information such as Internet domain and host names you visit before and after visiting this website; browser software and operating system types; button click patterns; and dates and times that this website is accessed. Our use of cookies and other tracking technologies allows us to improve this website. We may also analyze information that does not contain Personal Information for trends and statistics.

We and our third party tracking-utility partners utilize (i) a 1x1 image tracking pixel placed on certain webpages of the website to collect relevant information from this website and to set a Cookie on your web browser, (ii) your browser stream data to the this website, or (iii) other information collected from you (collectively, the “Targeting Data”). Such Targeting Data may include, among other things, IP address, date and time of your visit to this website, and website pages visited by you. We tie the information gathered by clear gifs to our customers’ personally identifiable information. The Targeting Data is used to provide our targeted advertisements to you while you are on third-party websites with whom we have purchased advertising inventory and may be combined or matched to third party data to identify you and display a targeted advertisement to you.

Personal Preference

You may request information on how your Personal Information is being retained or processed by us or a third party, how to access, request deletion, and review your Personal Information, or request to obtain a copy of the Personal Information we hold, by sending an inquiry to [email protected]. In responding to requests for a copy of the Personal Information we hold, we will provide such information in a commonly used format that is machine-readable, such as a PDF file.

In some cases you have a right to erasure of Personal Information we hold. However, we may need to retain certain information to comply with our legal or business obligations.

If you tell us that you do not wish to have your Personal Information used as a basis for further contact with you, we will respect your wishes. You may choose to opt-out of receiving future e-mail or mailings by following the unsubscribe procedures generally provided with our communications, or by sending an email to [email protected] specifying "Unsubscribe" in the subject line.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here (or if located in the European Union click here). Please note you will continue to receive generic ads. If you clear your web browser's cookies and then visit this website again, or visit this website from a different web browser, you will need to re-enter your opt-out choices.

Data Security

We utilize a combination of reasonable and appropriate physical, technical, and administrative safeguards to prevent unauthorized access or disclosure, to maintain data accuracy of your Personal Information, and to ensure the appropriate use of Personal Information we collect and process via this website. [24]7.ai retains Personal Information only as required or permitted by local law and while it has a legitimate business purpose to do so. When you enter non-sensitive Personal Information (such as your name, email address, company and geography), as requested by forms on our website, it is not encrypted.

Accuracy of Personal Information

[24]7.ai intends to maintain accurate Personal Information at all times. If you require the Personal Information you have provided [24]7.ai to be updated, or that we delete inaccuracies you may send updates and corrections to [24]7.ai via email to [email protected] specifying in the Subject line that you wish to provide an update and we will make reasonable efforts to incorporate the changes in our records as soon as practicable, if you provide the information we require to locate your Personal Information in our records (e.g. old name, email address, etc.). Once we make the requested update, we will send you an e-mail confirmation so that you are aware the update or correction has been made. If you requested to update your e-mail address or mailing address, we will send the confirmation notice to both the old and new addresses. If you wish to cancel your account or request that we no longer use your information to provide you services contact us via the information above. We will respond to your requests for access within a reasonable amount of time.

Third Parties

Occasionally, we may share aggregate, non-personally identifiable information about our users with our business and alliance partners. We also use third party service providers such as an email service provider to send emails on our behalf and an employment partner to process job applications. Other than our business and alliance partners, we do not provide Personal Information to any third party for any purpose whatsoever other than as outlined in this Privacy Policy, and we will not do so unless we are legally required to do so and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website. Similarly, it is against our policy to sell Personal Information collected online without consent. We will take reasonable steps to ensure that third-parties who receive any of your Personal Information from us protect such information on [24]7.ai's behalf.

In the event [24]7.ai goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or a prominent notice will be displayed on our website for 30 days of any such change in ownership or control of your personal information.

Links to Other Websites

When you are on this website, you could be directed to other websites that are beyond our control. There may be links to other websites that take you outside our service; for example, links to business/alliance partners and trade show companies. These other websites may send their own cookies to users, or otherwise collect data or solicit personal information. If you are directed to any third-party website, we make no representation as to the existence, sufficiency, accuracy or completeness of the privacy policy of the companies associated with such websites.

Social Media Features

Our website may include links to Social Media websites, such as Facebook, LinkedIn or Twitter. These Social Media websites may collect your IP address, which page you are visiting on our site, and may set a cookie. Social Media websites are hosted by a third party. Your interactions with these Social Media websites are governed by the privacy policy of the company providing it.

Blogs

Our website offers blogs where visitors may submit comments that may be published when approved by [24]7.ai. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at [email protected] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Children's Privacy

This website is not designed to attract children. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age.

STATEMENT OF CONSENT

BY USING THIS WEBSITE OR BY SUBMITTING AN APPLICATION FOR EMPLOYMENT, YOU CONSENT TO THE TERMS OF THIS PRIVACY POLICY AND TO [24]7.AI PROCESSING AND USING PERSONAL INFORMATION FOR THE PURPOSES DESCRIBED HEREIN.

Changes

Should this Privacy Policy change, we intend to take reasonable steps to ensure that these changes are brought to your attention by posting a revised Privacy Policy on this website. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a prominent notice on this Site prior to the change becoming effective.

Contact Information

For questions about this Privacy Policy, please write to [email protected] or to:

[24]7.ai, Inc
Attn: Legal Department
2001 Logic Drive, Suite 200
San Jose, CA 95124 USA

Platform Privacy Policy

(last revised on November 24, 2020)

[24]7.ai, Inc and its affiliates (collectively, “[24]7.ai”) provide software platforms, applications, and data analysis systems (collectively, the “[24]7.ai Platform”) which enable [24]7.ai’s clients (DEFINE as “Client”) to better service their current and prospective customers (each an “End User”) via the Internet and telephony networks. This [24]7.ai Platform Privacy Policy is applicable to those Clients and End Users who are either directly or indirectly using the [24]7.ai Platform.

At the contractual direction of [24]7.ai’s clients, [24]7.ai collects and processes End User’s information which may include Personal Information, where “Personal Information” means information that can be used to specifically identify an End User, including, but not limited to, a first and last name, organization name, email address, phone number, postal/zip or other physical address, date of birth, gender, professional title, account information, credit/debit card number, and any other such information needed by the [24]7.ai Platform to provide client-specified services to an End User. [24]7.ai respects the privacy of End Users and is committed to protecting the Personal Information that we receive through their direct and indirect use of the [24]7.ai Platform. Notwithstanding the foregoing, End Users’ use of our clients' Internet- and telephony- based services (and, ultimately, the [24]7.ai Platform) is solely governed by the terms and conditions agreed to directly between End Users and [24]7.ai’s clients (usually via a signed written agreement, “Terms of Use” and/or a “Privacy Policy” on such clients’ websites).

Collection and Use of Information

Certain information about End Users is passively collected through the [24]7.ai Platform without those End Users actively providing that information to [24]7.ai (“Interaction Data”). Collection of Interaction Data is done using various technologies, such as website cookies (see section on cookies below), Internet/web tags, and navigational data collection (e.g. website log files, server logs, etc.). We do not consider Interaction Data to be Personal Information.

Some Interaction Data is automatically transmitted by End Users' Internet web browsers and telephony networks to the [24]7.ai Platform, with examples including: the URL of the website an End User browsed before accessing the [24]7.ai Platform; the Internet Protocol (“IP”) address of the End User's computer (a unique number automatically assigned to an End User's computer when connecting to the Internet, which may vary from session to session); the web browser version that the End User’s computer or mobile device is currently using; the date and time the End User accessed the website or online service; and the specific webpages that an End User accessed while visiting the website. Interaction Data is used by [24]7.ai for internal purposes, to analyze trends, and to improve the [24]7.ai Platform. [24]7.ai also uses Interaction Data to improve our clients’ web, mobile and telephony systems. For example, Interaction Data is collected and used to personalize websites so that their content, layout, functionality, navigation, recommendations, offers and promotions will be more relevant to End Users based on their collective or individual context.

Before using the [24]7.ai Platform, we agree in written contracts with our clients that they have sufficient rights, including their End Users' consent, to allow us to collect both Personal Information and Interaction Data. If you have any concerns about one of our client’s right to collect such data from you and to pass it on to [24]7.ai, please contact that client directly.

We collect the following kinds of personal information from our Clients:

  • Contact Information such as name, email address, mailing address, phone number
  • Billing Information such as billing address
  • Unique Identifiers such as user name and account number

We use this information to provide Clients:

  • Relevant account or product information
  • Assistance in completing transactions
  • Resolution to customer service issues

[24]7.ai collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes.

Cookies

[24]7.ai uses “cookies” or similar technologies to track and collect End Users' Personal Information and Interaction Data. A “cookie” is a small data file that [24]7.ai transfers to an End User’s computer or mobile device for various tracking purposes. [24]7.ai uses these cookies to save relevant data to enhance End Users' experiences while on our clients' websites. End Users may set their web browser to notify them when a cookie is sent, or to refuse cookies altogether, but certain features of the [24]7.ai Platform (and of our clients’ websites) might not work well or at all if cookies are blocked or deleted. Before using the [24]7.ai Platform, our clients promise us that they have their End Users' consent to set/collect cookies (or for [24]7.ai to set/collect the cookies on their behalf) and that they have the right to give such information to [24]7.ai to process on their behalf. If you have any concerns about one of our client’s right to set/collect cookies or to give us the right to do so on their behalf, please contact that client directly.

Opt-Out

Before using the [24]7.ai Platform, we agree in written agreements with our clients that they have sufficient rights, including their End Users' consent, to allow us to collect both Personal Information and Interaction Data. End Users who do not wish to have their Personal Information or Interaction Data collected should contact our client directly or visit our client’s privacy policy for guidance on opting out. Please note that End Users who clear their web browser’s cookies and then visit our client’s website again, or visit our client’s website from a different web browser, may need to re-enter their opt-out choices with our client. If you are a client and would like to update your account please contact us via your client account representative.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Security

The [24]7.ai Platform follows industry standards to protect the security of End Users’ Personal Information and [24]7.ai respects End Users’ choices for such information’s intended use (to the extent those choices are communicated to our clients by End Users and then onward-communicated by our clients to us). We utilize a combination of reasonable and appropriate physical, technical, and administrative safeguards to prevent unauthorized access or disclosure of End Users’ Personal Information, to maintain data accuracy of End Users’ Personal Information, and to ensure the appropriate use of End Users’ Personal Information we collect and process. [24]7.ai retains Personal Information and Interaction Data only as required or permitted by local law and while it has a legitimate business purpose. In addition, [24]7.ai uses standard security protocols, and mechanisms to exchange the transmission of sensitive Personal Information such as credit card details and login credentials. End Users submit sensitive Personal Information such as their credit card number in the [24]7.ai Platform via functionality which limits the sensitive data from being persisted by [24]7.ai and is encrypted using transport layer security (“TLS”) technology.

Privacy Shield Principles

End Users' information may be stored, processed and/or accessed in the United States or in any other country in which [24]7.ai or its affiliates, subsidiaries or agents maintain facilities. By using the [24]7.ai Platform, our clients have promised us that such End Users have consented to any such transfer of information outside of the End Users' home country.

We and our wholly owned subsidiaries, 24/7 Customer Private Limited, Voxify, LLC, Tellme Networks, Inc., and 24/7 Inc., participate in and have certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. [24]7.ai is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list

[24]7.ai commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

[24]7.ai is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, [24]7.ai is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Accuracy of Personal Information

[24]7.ai has no direct relationship with the individuals whose personal data it processes. [24]7.ai endeavors to maintain accurate Personal Information at all times but ultimately is reliant on its clients for the accuracy of Personal Information. If an End User requires updates to her/his Personal Information or requests their data be deleted/deactivated in the [24]7.ai Platform, the End User should request such changes directly through our applicable client, and [24]7.ai will make reasonable efforts to incorporate such changes, or respond to requests for access, deletion, correction, amendment, restriction in the [24]7.ai Platform within 30 days.

Onward Transfer

The [24]7.ai Platform operates globally. Therefore, [24]7.ai may transfer End Users’ Personal Information and Interaction Data on to its affiliates and/or subcontractors worldwide for the purpose of further processing or storage, and/or may transfer data within its control to various geographies as part of its own processing efforts. [24]7.ai will not sell, rent, transfer or lease an End User's Personal Information to any third party except with the End User's direct consent, whether provided directly or relayed to us by our clients Transfers to any third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients; the transfer is to other [24]7.ai entities and/or business partners who are acting on behalf of [24]7.ai for the uses described in this policy; or the transfer is required by law or court order, and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

In the event [24]7.ai goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via prominent notice on our website for 30 days of any such change in ownership or control of your personal information.

Children's Privacy

[24]7.ai Customer Engagement Platform does not intend to target, and is not intended to attract, children under the age of 13. [24]7.ai does not knowingly collect personal data from children under the age of 13 or send requests to children for personal data.

Changes to this Privacy Policy

[24]7.ai may amend this policy from time to time. If we make any material changes in the way we use End Users' Personal Information we will make that information available by posting a notice on our website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

For questions about this [24]7.ai policy, End Users are encouraged to contact our client who has retained us to provide the [24]7 Customer Engagement Platform on their behalf. Such End Users may also write to [email protected] or to:

[24]7.ai, Inc
Attn: Legal Department
2001 Logic Drive, Suite 200
San Jose, CA 95124 USA

Privacy Notice for California Residents

(Last updated on December 15, 2019)

This Privacy Notice for California Residents supplements the information contained in [24]7’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

1. Information We Collect

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category
Examples
Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Tick

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Tick

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Tick

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Tick

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Cross

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Tick

G. Geolocation data.

Physical location or movements.

Tick

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Cross

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Tick

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Cross

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Cross

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like certain health or medical information and other categories of information protected by different laws.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our website.

2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates’ assets in which personal information held by us or our affiliates about our website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

3. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Data Aggregators.

4. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we’ve collected about you.
  • The categories of sources for the personal information we’ve collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we’ve collected about you (also called a data portability request).
  • If we sold or 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.
Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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, 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.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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.
Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by: Emailing us at [email protected].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we’ve collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

7. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

8. Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.247.ai
Email: [email protected]

GDPR Compliance

(last revised on May 30, 2018)

[24]7.ai is committed to respecting all applicable individual rights to privacy including but not limited to rights set forth under the General Data Protection Regulation of the European Union (the “GDPR”). Accordingly, information security, protection of all confidential material entrusted to us, and transparency with respect to individuals who may elect to entrust information to us, are all of the utmost importance to our organization. The following summary sets forth some of the key measures we have set in place to effectuate that commitment, and to meet the enhanced standards for transparency and accountability for personal data uses under the GDPR.

We use personal information in a variety of ways across our products and organization. Specific uses are identified for users of particular products and/or those who elect to use our services, but in general our products and policies limit our collection and use of personal data to online identifiers such as IP address, cookie and device identifiers. We use this information to support our clients in customer engagement and customer acquisition efforts, and to optimize customer website experiences on client websites.

To support all such uses, we have implemented a comprehensive cross-functional effort calculated to ensure full compliance with the GDPR with respect to any role in which we handle sensitive data, whether as controller or processor. Our program includes detailed administrative, technical and operational controls designed to effectuate GDPR principles in all our relevant processes. We have further set in place measures designed to safeguard the data under our care using secure encryption technologies. We also take steps to independently test our security against international standards using third-party auditors. Additional actions we are taking include:

  • Implementing new internal controls calculated to enable full compliance with the GDPR and to strengthen the Company’s commitment to respecting all lawful privacy rights;
  • Setting in place consent mechanisms to facilitate user consent and withdrawal of consent as appropriate;
  • Implementing Privacy by Design in our internal systems and products on an ongoing basis;
  • Implementing processes to enable data subjects to exercise their lawful privacy rights with respect to their data;
  • Reviewing contracts and contacts with partners to confirm satisfaction of all applicable privacy requirements, including the GDPR;
  • In circumstances where we operate as a processor, supporting the controller with respect to all requirements, including data subject rights, incident response, and other matters, in accordance with GDPR Article 28;
  • Ensuring that controllers for whom we operate as processors confirm that their instructions are proper and in accord with consents they have secured for the use of data;
  • In circumstances where we operate as a controller, ensuring that appropriate consents and/or contractual rights are secured for all uses of personal data;
  • Enhancing policies across the organization to ensure compliance and readiness to address any issues, including data subject requests and/or data incidents.

In addition to the measures already set in place, we strive for continuous improvement and therefore review and improve our systems on an ongoing basis. Questions concerning the Company’s GDPR compliance efforts and/or any related matters may be directed to [email protected]