Effective: April 9, 2020
2. TYPES OF INDIVIDUALS
- Site Visitors – those who visit the Sites or individuals who request us to contact them via our online web forms or email;
- Registered Users – those who are users of the Services via their employer’s (our customer) subscription to the Services or visit the App;
- Identifiable Individuals – those whose information is collected for the purpose of providing our data management services to our customers, which is described further, below; and,
- Attendees – those who attend or register to attend events sponsored by People.ai or in which People.ai participates.
Collectively, we refer to the individuals, above, as collectively as “Users.” An individual may fall into more than one category of individual. For example, an individual may attend one of our sponsored events and be classified as an Attendee, and then a Site Visitor when visiting the Sites.
The terms “People.ai,” “we,” “us,” and “our” refer to People.ai, Inc.
4. WHAT DATA WE COLLECT
4.1. Information you provide to us
When you visit our Sites or contact us, we might collect Personal Information that you voluntarily submit to us, such as through a web form, in an email, in a chat message, or other form of electronic communication. Personal Information collected in this way includes identifiers, such as your name, business address, email address, similar identifiers, commercial information, and professional or employment-related information relevant to you as an agent of your business.
4.2. Information from web technologies
When Site Visitors and Registered Users visit our Sites or use our Services various web technologies may collect information in relation to your use of the Sites. For example, we may collect browser information, device data, logs, IP addresses, the page of the Sites you request, the date and time of the request, and the time spent on the Sites or page.
Some of the pages on the Sites may contain “cookies.” A cookie is a small data file that may be sent to your web browser and stored on your computer. This allows our server to recognize a computer when it revisits the Sites. The cookies also help People.ai analyze trends, track user movement in the site, and gather demographic information about our users as a whole.
Most web browsers can be configured to not accept cookies, or to notify you if a cookie is sent to you. You may also consider visiting aboutcookies.org, which provides helpful information about cookies. You can choose to disable cookies for the Sites but, blocking cookies may prevent or reduce the extent to which the Sites or Services can be used or customized by you. Please note that opting out of receiving cookies may not exercise your other data rights.
Some pages of the Sites (and our e-mails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users that visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
4.3. Information from Services
People.ai collects information and data for the purpose of creating our graph database and providing the Services. We collect information and data to help us compile, organize, and verify this information. The collected information can include:
- Customer Activity Data – activity data (e.g., email, calendar, and phone data, address book data, customer relationship management (“CRM”) data, etc.) of Customer activity collected through access to the Customer’s third party services on behalf of the Customer. People.ai never receives or stores user credentials (i.e., passwords) for these third party services. People.ai relies on federated authentication protocols and tokens.
- Personal Information (“PI”) – any information which can reasonably be used to identify an individual, and may include, but is not limited to, name, email address, telephone number, postal or other physical address, title, or occupation. It may also include IP addresses or other telemetry data necessary to run the Website or App. Customer Activity Data may include Personal Information of Identifiable Individuals, Registered Users, and Attendees. We endeavor to limit our requests for and collection of Personal Information to information we believe is reasonably necessary to achieve our purposes, or is necessary for the providing the Services.
- Publicly Available PI – we may collect, directly or indirectly, Personal Information from publicly accessible online sources. Publically Available PI may be collected by a third party and then provided to People.ai.
- Licensed PI – we may collect Personal Information through licensing agreements directly with data brokers or other Companies, pursuant to their privacy policies and terms and conditions.
5. HOW WE USE YOUR INFORMATION
5.1. General use of your information
6. DATA SHARING & DISCLOSURE
We may disclose Customer Activity Data, which may include Personal Information, to other companies or third parties under any of the following circumstances:
6.1. Customers and Partners
We use Personal Information to provide the Services to our customers and partners.
6.2. Sub-processors (Third-Party Service Providers)
We may transfer information, including Personal Information, to our sub-processors, which we use to provide our services. These sub-processors may have access to or process your Personal Information for the purpose of providing these services for us (and in turn, you). We prohibit our sub-processors to use any Personal Information for their marketing purposes or for any other purpose than in connection with the services they provide to us.
6.3. As Required by Law
In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law. To enforce the terms of an EUSA, prevent fraud or abuse of People.ai or its users, or to protect People.ai’s rights.
6.4. To Market Our Services:
We may share information, including Personal Information, with our channel partners, solely for the purpose of enabling our channel partners to notify you about our Services. People.ai requires its channel partners to provide an opt-out option within its communications to you. By opting out, you are opting out of receiving future communication from our channel partner.
7. INTERNATIONAL TRANSFERS
8. CHILDREN’S PERSONAL INFORMATION
Our Services are not intended for or directed to persons under the age of 13. Accordingly, we do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, do not submit any Personal Information to us via email, the Sites, through our Services, or through other channels. Any person who provides information to us through registration or in any other manner on the Sites or through the Services represents to People.ai that they are 13 years of age or older. If you believe that we have mistakenly collected such information, please notify us at email@example.com so that we may immediately delete the information.
9. ADDITIONAL INFORMATION PER USER TYPE
9.1. Site Visitors
We may collect data on how you use the Sites, to improve the Sites and the Services. This may include the ability to reproduce your actions on the Sites, your IP address, your browser and device characteristics, and other such data, for the purpose of Sites and Service improvement.
We may collect Personal Information from you if you choose to contact us through the Sites.
9.2. Registered Users
Where we are the data controller of Personal Information (for example, for Site Visitors and Attendees), then we retain the Personal Information we collect where we have an ongoing legitimate business need or purpose to do so. (For example, providing you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements, is a legitimate purpose.)
We ask for and may collect personal information such as your name, address, phone number, commercial information, and email address when you register for or attend a sponsored event or other events at which any member of the People.ai participates. We collect this information to facilitate your registration or attendance of the event and to send you related or followup communications.
10. YOUR DATA RIGHTS
10.1. Cookies and Similar Technologies.
Your browser or device can allow you to opt-out of data collection from cookies or similar technologies by setting your browser to refuse all or some of the web technologies (e.g., cookies) employed on the Sites. Please note that your experience using the Sites or the Services might be degraded, or certain functionalities may not work, if you opt-out to such collection.
10.2. Marketing Communications
If you wish to opt-out of our use of your contact information for our direct marketing purposes, you can click the “Unsubscribe” button located within the most recent marketing email you received from us, or contact us at firstname.lastname@example.org. You may also use the DO NOT SELL MY INFO button on the bottom of each page.
10.3. Opt-Out Rights
Depending on where you are located, you may have additional rights to opt-out of certain uses of Personal Information, know what Personal Information we’ve collected, or request that we delete your Personal Information. Please review the JURISDICTION SPECIFIC NOTICES, below, to determine if these rights apply to you.
11. JURISDICTION SPECIFIC NOTICES
People.ai is based in the United States. The Sites and Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be collected, transferred to, stored and otherwise processed in any country where we have facilities or in which we engage service providers, and by using the Sites and/or Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
You may be entitled to additional privacy notices depending on where you are located. Please see the appropriate subsection below that may apply to you.
The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.
Under the CCPA, People.ai is both a “business” and a “service provider.” This subsection applies to information we collect in our role as a business. When we act as a service provider for our Customers (for example, by providing our services to another company that you interact with), we follow the processing instructions of our Customer with respect to how we process your personal information.
11.1.1. Information We May Collect
|Identifiers||Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.|
|California Customer Record Information||Identifiers such as name, address, telephone number, employment, employment history.|
|Internet or other electronic network activity information||Internet or other electronic network activity information, information regarding a consumer’s interaction with an internet website, application, or advertisement.|
|Geolocation data||City, state, country, time zone, or the city in which an employer’s company is located.|
|Professional or employment-related information||Job title, employer name, role, or industry.|
|Inferences||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer.|
Please note that under the CCPA, Personal Information does not include:
- publicly available information;
- deidentified or aggregated consumer information; or
- information otherwise excluded from the scope of the CCPA.
For each of the categories of information, above, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, from our Customers, and/or from third party providers.
11.1.2. Use of Personal Information
We collect this Personal Information to provide the Services; to protect the rights, privacy, and safety of the Users and Services; and to improve the Services. For example, in the last 12 months, People.ai used Personal Information for one or more of the following purposes:
- To provide our Services to our Customers;
- To build and maintain your network of contacts;
- To improve or modify the Services or develop new products;
- To send you administrative information about your account, such as upgrade notifications, billing notices, etc.;
- To communicate with you and provide you with any relevant customer service;
- To present products and offers, which we believe you would enhance your use of the Sites. (You may unsubscribe from these types of communications at any time;)
- To conduct research about People.ai or our products and services;
- For billing and account services;
- For data analysis such as audits and fraud prevention;
- As required by applicable law;
- To enforce our terms and conditions;
- To protect the rights, privacy, or safety of People.ai or others; or
- To otherwise operate and support the Sites.
11.1.2. Disclosure for a Business Purpose
People.ai may disclose your personal information to a third party for a business purpose. When we disclose Personal Information for a business purpose to a third party, the third party must keep the Personal Information confidential and not use the Personal Information for any other purpose except the purpose for which we provided the Personal information to the third party.
11.1.3. Disclosure for a Commercial Purpose
The CCPA broadly defines selling Personal Information as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party.” In light of this broad definition, many types of data transfers are considered a “sale” under the CCPA. In the past 12 months, we’ve disclosed Personal Information from the following categories in a manner that may be considered a sale under the CCPA: identifiers; record information; internet or other electronic network activity information; geolocation data; professional or employment-related information; and inferences. As described below, you can opt-out of our “sale” of your Personal Information.
11.1.4. Your Rights Under the CCPA
The CCPA provides individual California consumers with several individual rights with respect to Personal Information. Under the CCPA, a California consumer has the right to request:
- The disclosure of the categories of personal information we collected about you.
- The disclosure of the categories of sources for the personal information we collected about you.
- The disclosure of the specific pieces of personal information we collected about you.
- The disclosure of the personal information categories that each category of recipient received for valuable consideration;
- The disclosure of the personal information categories that each category of recipient obtained for a business purpose;
- The deletion of your Personal Information, subject to certain limitations under the CCPA; and
- The right not to be discriminated against for exercising certain rights under California law.
11.1.5. Right to Opt-Out of Sales of Personal Information
You have the right to direct us not to sell your Personal Information on a going-forward basis. Please click the DO NOT SELL MY INFO link, which can also be found in the footer of our homepage.
11.1.6. Exercising your rights
To exercise these rights, please submit a request to one of our contact options:
- Calling us at +1 (888) 997-3675;
- Filing out the request webform; or,
- Emailing email@example.com
Please be as specific as possible in relation to which right you would like to exercise. The requests can only be granted for a verifiable customer request. Please provide sufficient information about yourself so we can confirm that your request is a verifiable customer request, including at a minimum your name and email address. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We will respond to your request within 45 days of receipt, or notify you if we require additional time. We will not respond to requests that do not include at least your name and email address. We will provide you with the Personal Information in a usable format that allows you to transmit the Personal Information to another entity.
You may also designate an authorized agent to make a request on your behalf. In order for us to process a request from your authorized agent, we must (i) confirm that the agent is a natural person or business entity registered with the Secretary of State that you have authorized to act on your behalf, (ii) receive from you a copy of the written authorization that provides the authorized agent to act on your behalf, and (iii) verify your identity by asking you to provide us sufficient information in order to do so.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
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.
11.1.7. Non-Discrimination for exercising your rights
You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA, subject to certain limitations. Please note that we reserve the right to offer you certain financial incentives as permitted by the CCPA that may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by contacting us.
12. DATA SECURITY
13. CHANGES TO THIS PRIVACY NOTICE
14. CONTACT US
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Attn: General Counsel
475 Brannan St, Suite 320,
San Francisco, CA 94107
Last Updated Date: April 9, 2020