Privacy Policy

For purposes of this Privacy Policy, “Personal Information” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source.

What personal data we collect depends largely on the interaction that takes place between you and Conversant AI, most of which can be categorized under the following:

• When you use Conversant AI's Services. When you or your End Users use Conversant AI's Services, we store all User Content that you or your end users provide for use with the AI Functions or when using the AI Functions, account details and other personal data provided by you or your End Users, including content from third party integrations that you choose to link to the Services. We gather this information from you or your end users directly when provided or entered by you or your End Users, or from integrations linked to the Services.

In some cases, we can receive information from third parties, e.g. from a payment service provider on whether your payment was successful.

• When you use Conversant AI's Platform. When you use Conversant AI's Platform, we store all User Content that you provide for use with the AI Functions or when using the AI Functions, account details and other personal data provided by you, including content from third party integrations that you choose to link to the Platform. We gather this information from you directly when provided or entered by you, or from integrations linked to the Platform.
• When you send us emails or message us. When we receive emails or messages from you or your End Users, we can store the content of such emails, including attachments as well as your or your End User's contact details.
• When you submit forms on the Site or Platform. When you complete forms on the Site or Platform (contact us, subscription, demo request, etc.) we collect your contact details and information you complete in the form.
• When you use the Site or Platform. When you use the Site or Platform, we collect certain information via Google Analytics, as described in more detail below that may, alone or in combination with other information, constitute personal data (e.g. cookie files).

Information You Provide To Us

When you or your End Users use the Services, the Platform, or otherwise communicate with us, we collect information that you or your End Users provide to us directly. For example, we collect information in the following circumstances: you or your End Users (i) use our App or visit the Site, (ii) register for the Platform, the Services or create an account or profile or accept the creation of an account or profile on your behalf (an “Account”), (iii) access the Services or the Platform through third party services, (iv) purchase a product or service on the Site, on the Platform, or in our Apps; (v) request technical support; (vi) otherwise use our App, online Services, or Platform where Personal Information is required for such use and/or participation, and (vii) when you contact us via the Site or the Platform, or when you otherwise communicate with us. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services or the Platform.

The information you or any End Users provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:

• Customer account details. To create or update your account and provide the Services or the Platform we collect from you and third-party integrations information about you and your End Users. This includes name, email, phone number, products in use, location, account authentication information, and any other information you decide to provide.
• Personal data within User Content. As you use our Services or Platform, you may include in User Content that is uploaded or provided for use with the AI Functions personal data you have collected from yourself, your End Users, employees, customers, prospective customers or other individuals. We process this data only on your behalf as our customer. We have no direct relationship with any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission and legal basis for us to collect and process information about yourself and those individuals.
• Financial information. To process your payments for the Services subscription, if applicable, we need your credit card details (last four digits of the card number), account details and payment information.
• Contact details and business data. We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email or other contact details as may be necessary.
• Requests, messages and submitted forms details. We receive and process your or your End Users messages, support requests, emails and information you share with us via online forms, or other support channels. This includes the content of such communications as well as your contact details if any.

Moreover, if you contact us, a record of such correspondence may be kept.

Additionally, if another customer refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send such other customer's message unless you otherwise affirmatively provide your information to us.

We ask that you not provide or disclose to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Services, the Platform, or otherwise. You are responsible for making sure that you or your End Users do not provide or disclose to us any sensitive personal data on or through the Services, the Platform, within any User Content or otherwise.

Automatically Collected Information

Most of the data we collect in and through the Sites, the Services, and Platform is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies, and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation:

• Device data: including, but not limited to, data on device advertising ID's and similar hardware qualifiers, and precise location data.
• Usage data: including, but not limited to, search terms entered and pages viewed.
• Network and internet information: including, but not limited to, URLs, Internet Protocol addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click streams, location information and network/Wi-Fi access points.
• Information we collect on the use of the Sites and the Platform via cookies: please see the “How We Use Cookies and Other Technologies” section below for more information.

Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

The Platform may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.

We use the information you provide to us for the following purposes:

1. To operate the Services and the Platform: We use personal data to enter into the agreement with you as a customer and operate, maintain and administer your account in the Services or Platform, as well as to communicate with you regarding the Account (sending announcements, technical notices, updates, security alerts, and support and administrative messages) and to respond to Service or Platform-related requests, questions and feedback. We also use your data to perform our billing obligations, if applicable. To the extent any User Content contains personal data, we may process this data on your behalf to provide the Services and Platform.
2. To improve our Services and the Platform: We process your and your End Users' AI Content to understand how you use our Services, Sites, and Platform including to monitor usage or traffic patterns and to analyze trends and develop new products, services, features and functionality in reliance on our legitimate interests and to train, develop, improve and optimize the AI Functions and our Services, Platform, and Sites.
3. To Personalize the Services and the Platform. We use personal data and conversations within our App and on the Platform to personalize your and your End Users' experience, including to provide you with historical information regarding past purchases or interactions with products in the existing session.
4. To comply with law. We use your or your End Users' personal data as necessary to enforce our Terms of Service, and to comply with applicable laws, including sanction requirements, accounting and tax obligations, legal processes or audits, to respond to subpoenas or legally binding requests from government authorities. Before disclosing any information to an authority upon its request, we check the validity of such request carefully.
5. To communicate with you and inform you about the Services and Platform. We use personal data to provide to you Service or Platform announcements or inform you of new releases and features, to provide you with further information and offers from us that we believe you may find useful or interesting, to perform tasks on behalf of and according to instructions of a third party, such as payment processors, third party-service providers or our advertising partners, if applicable.
6. For compliance and safety. We use your or your End Users' personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Services and the Platform; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity to resolve any disputes between users of the Sites or between such users and us.

In addition to the purposes described above, we use the information collected automatically to (i) to further our legitimate interests in monitoring and analyzing the use of the Services and the Platform and for the technical administration of the Sites, (ii) train and improve the Sites, Platform, and the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of the Platform and the Services meet the criteria required to process their requests. We and or our advertising partners may use demographic, as well as information logged from your hardware or device, including data such as IP address, device model and ID, MAC address, operating system, application usage data, device time zone, region and language, and click ID, to ensure relevant advertising is presented within the Platform.

Some of the features on the Marketplace Site and the Platform require the use of “cookies” - small text files that are stored on your device's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Marketplace Site and Platform to meet the needs of our visitors.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Marketplace Site, Platform and HTML-formatted email messages to, among other things, track the actions of Marketplace Users, to determine the success of marketing campaigns and to compile aggregate statistics about the Marketplace Site or Platform usage and response rates.

We may disclose Personal Information you provide to us or that we collect automatically on the Sites and in and through the Services and the Platform with the following categories of third parties:

• Service providers, such as payment processors, web hosting and data storage service providers, and those helping us deliver and develop the Services and Platform, data storage service providers, marketing service providers, and communications service providers (e.g. Amazon Web Services and OpenAI, L.L.C.);
• Our advertising partners in compliance with applicable law;
• Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
• Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Sites, the Services and/or the Platform, and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

We frequently make content or services from other websites available to you from links located on the Marketplace Site. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your social media account or other accounts, such as Google, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Sites, the Platform, and the Services. We do not exercise control over third party services or other websites that provide information, or over banners, other advertisements or links from within the Sites, the Platform, or the Services. Your interactions with these third party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer's browser, collect data or solicit Personal Information from you. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit, and the collection and use of such information and access of any third party websites are subject to such third party's privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.

We understand the importance of privacy and security of Personal Information to our users and have made them a priority. Conversant AI uses a variety of industry-standard security technologies and procedures to help protect Personal Information about you from unauthorized access, use, or disclosure and trains Conversant AI employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that Personal Information about you or private communications will be protected from unauthorized disclosure or use.

Conversant AI does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

We keep your data on your behalf and for your benefit. You can correct or terminate and delete your Account information by following the instructions on the Services, the Platform, or by e-mail at privacy@conversant.ai, which you may also access for further assistance and questions regarding the Privacy Policy or for a copy of your Account data. If you cancel your Account or request us to delete your information, Conversant AI will limit its access to Personal Information to perform what is requested by you and will delete information accessible to Conversant AI within seven business days.

California Civil Code Section 1798.83 requires certain businesses that share customer Personal Information with third parties for the third parties' direct marketing purposes to respond to requests from California customers asking about the businesses' practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties' direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.

Furthermore, subject to certain exemptions, California residents have the following rights with respect to Personal Information we may have collected about them:

Requests to Know

You have the right to request that we disclose:

• The categories of Personal Information we have collected about you;
• The categories of Personal Information about you we have sold or disclosed for a business purpose;
• The categories of sources from which we have collected Personal Information about you;
• The business or commercial purposes for selling or collecting Personal Information about you;
• The categories of Personal Information sold or shared, if any, about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
• The specific pieces of Personal Information collected.

You may submit a request to know via post at Conversant AI, Inc., 220 State Street, Suite G, Los Altos, CA 94022. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

We do not sell, and have not in the prior 12 months sold, Personal Information about California residents. Therefore, we have not included a “Do Not Sell My Personal Info” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law. We do, however, disclose Personal Information for business purposes as described in the “Third Parties We Share Personal Information With” section above.

Requests to Delete

You have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required or authorized by law. You may submit a request to delete Personal Information via post at Conversant AI, Inc., 220 State Street, Suite G, Los Altos, CA 94022 or via email at privacy@conversant.ai.

Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request for access and requests to delete Personal Information about you via:

• via post at Conversant AI, Inc., 220 State Street, Suite G, Los Altos, CA 94022, or
• via email at privacy@conversant.ai.

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within 10 days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of Personal Information about you, we verify your request by email.

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.

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.

The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above. 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; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Conversant AI is based in the United States. As a result, Personal Information that we collect in and through the Services, the Platform and on the Sites may be transferred to our U.S. offices. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, Personal Information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Personal Information was initially collected. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Policy and in compliance with applicable laws.

We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.

We may need to change this Privacy Policy from time to time to reflect legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you before its entry into force, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by data protection laws applicable to us.

You can see when this Privacy Policy was last updated by checking the “EFFECTIVE DATE” displayed at the top of this Privacy Policy. The new Privacy Policy will apply to all current and past users of the website and will replace any prior notices that are inconsistent with it.

If you have any concerns or questions about this Privacy Policy, please contact us at privacy@conversant.ai.