NumberAI Privacy Policy

Last updated: June 1, 2018
Version 1.1

NumberAI takes your privacy very seriously and so we have created this Privacy Policy to explain how information about you is collected, used, and disclosed by Number AI, Inc. and its subsidiaries, affiliates, successors or assigns (collectively, "NumberAI"). NumberAI makes communication tools used by our business customers (“Business Customer”) to communicate with their customers (“BC End User”), and so this Privacy Policy applies to information we collect when BC End Users use products, services, website, apps that our Business Customers make available when using our services (“BC Services”). Additionally, it applies to information we collect from individuals and Business Customers when they access or use our websites (collectively, “Sites”) and it also applies to Business Customers that use and access our mobile applications, cloud services, and/or any other NumberAI products and services (collectively, the "Services").

We may change this Privacy Policy from time-to-time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide additional notice (such as adding a statement to our homepage or sending Business Customers an email notification). Please review the Privacy Policy from time to time so that you can stay informed about the information we collect and how we use it.

OUR SERVICES

Business Customers subscribing to our Services can, among using other features, send/receive SMS, Facebook Messages, and other types of messages to and from their customers, potential customers, vendors, and/or other persons. NumberAI also provides enhanced voicemail services. NumberAI can record and transcribe voicemail messages and then respond by sending the caller a text message. Additionally, NumberAI uses artificial intelligence to process content in messages so that we, for example, can automatically handle a take-out order from a restaurant, or route messages to the correct employee at a hardware store, or otherwise automatically respond to messages sent to our Business Customers.

When you interact with a Business Customer – by sending a text, leaving a voice mail, submitting a request in-person or via their website or app, for example - you may provide information, including personally identifiable information, and they will provide some or all such information to us so that a message can be sent to you. Without access to the information you provide to our Business Customers, we cannot provide our Services, which in turn allows our Business Customers to provide the BC Services to you. Both the Business Customer’s privacy policy and NumberAI’s Privacy Policy will apply since we both have access to the information that you shared.

Additionally, NumberAI’s Privacy Policy also covers any information that we may collect from Business Customers, including but not limited to their respective employees, agents, independent contractors and/or anyone else that they authorize to use the Services (“BC Personnel”).

Our Services are not targeted or directed at children under the age of 13 and we do not knowingly collect or store any personal information from children under the age of 13.

NOTICE

Through this Privacy Policy, we provide information about the information we collect, how we collect it, the purposes for which it is used, and we provide notice of how you can contact NumberAI with any inquiries or complaints, the types of third parties to which we disclose the information, and the ways, if any, we offer for limiting how personal information that we collect or receive is used and disclosed.

COLLECTION OF INFORMATION

Information We Collect or Receive

Individual User Data. If you are a BC End User, we collect information in a variety of ways, including when you provide information directly to us and/or when we receive information that you provide to Business Customers. As an example, when you use and/or interact with BC Services, you may provide information, such as your name, company name, email address, and phone number, as well as other information that you otherwise choose to provide. You may, for example, send and/or receive text messages, other types of messages and/or voicemails , and when you do, we collect your telephone number and the content in any messages you send/receive. For clarity, when we provide our Services to a Business Customer, we will receive the same or similar type of personal information that the Business Customer receives and which we need to provide our Services to the Business Customer.

If you are a Business Customer, you will need to provide contact information for your BC Personnel who you authorize to access and use our Services. That information may include and is not limited to name, company name, titles, job-related information, address, email address, telephone number(s) and passwords used to log into our Services. We also collect the texts, other types of messages and/or voice mail messages that Business Customers/BC Personnel send/receive using our Services.

Device and Usage Data. For BC End Users and Business Customers, we may collect and/or receive information about the computer and/or mobile device you use when you access BC Services and our Services, respectively. This information may include (and is not limited to) hardware model, operating system and version, unique device identifiers and network information, device type, model and manufacturer, and mobile device operating system brand and model. For BC End Users, we will collect/receive information related to your telephone calls, text messages, other types of messages and voice mails sent to and from the Business Customer. Similarly, we collect the same type of information from Business Customers using our Services. For BC End Users and Business Customers, we collect log information about your use of the BC Services/our Services, respectively, including the type of browser you use, when you access such services, pages viewed, your IP address and the webpages you visit before and after navigating to a different webpage.

Cookies are required for us to provide our Services. A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a web site’s computers and stored on your computer’s hard drive. We use cookies to record session information, and we use permanent cookies.

We use analytics software so that we can improve the functionality of our Services. This software allows us to collect and record data about how our apps and Sites are used, how often webpages are accessed, other usage data, and performance data, among other data. Standing alone, this information is not personal information and we do not link it to any personal information.

For BC End Users contacting a Business Customer and/or using the BC Services, you are not required to, but you may voluntarily choose to send a message that includes sensitive information, such as health, genetic information, racial and ethnic origin, political, religious, trade union membership, genetic data, biometric data and/or and sexual orientation, (“Self-Reported Information”). NumberAI does not require any Self-Reported Information to provide its Services and we will not know when you may send such data/information to the Business Customer, and thereby to NumberAI. Similarly, Business Customers/BC Personnel are not allowed to provide Self-Reported Information to NumberAI. To the extent BC End User or BC Personnel voluntarily provide such information, you are making such data or information public, and Business Customers and NumberAI will have access to, use, transport, and store such information to provision and maintain their respective services.

Information We Receive from Other Sources

For BC End Users, we may provide various features or services that require us to interact with third party service providers so that the Business Customer can respond to your requests. For example, to fulfill a scheduling request that you make, or to process a modification of a pending appointment with a Business Customer – we will interact with and receive information from third party apps and/or services to the extent necessary to respond to your request.

We may also obtain information from our Business Customers and third parties, including but not limited to identity verification services and publicly-available sources. We may combine that information with personal information we collect through our Services. In such cases, this Policy governs our use and disclosure of such information.

For BC End Users, if you create or log into your account through a social media site to access/use a BC Service, then we will have access to certain information from that site, including but not limited to your name, and other account information, in accordance with the authorization procedures determined by that social media site.

USE OF PERSONAL INFORMATION

We use personal information that we collect for various purposes, including to:

  • Provide, maintain, analyze and improve our Services;
  • Process transactions and send related information, including confirmations;
  • Send notices, updates, security alerts and support and administrative messages;
  • Send information about special events or offers and for other marketing, informational, product development and promotional purposes;
  • Respond to emails, comments, questions and requests and provide customer service;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Personalize and improve the Services and provide content or features; and
  • Carry out any other purpose for which the information is collected.

SHARING AND TRANSFER OF INFORMATION (Onward Transfer)

We share personal information that we collect about those that use BC Services and/or Services as follows, and as otherwise described in this Privacy Policy:

  • Service providers. With vendors, consultants, other service providers and telecom carriers who need access to such information to carry out work on our behalf and/or in order to provide ours Services to Business Customers.
  • Certain Requests. In response to a request for information, if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation. Similarly, if we believe it is reasonable to do so to protect the rights, property and safety of NumberAI or others;
  • Business Transactions. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
  • Your Consent. With your consent or at your direction, including if notice is provided through either the BC Services and/or our Services that the information you provide will be shared in a particular manner and you provide such information.

We do not sell, share, or rent any personal information to third parties in any ways different from what is disclosed in this Privacy Policy. However, we may share with third parties non-personal information, aggregated information or other anonymized data which cannot reasonably be used to identify you.

NumberAI will be responsible for the processing of personal data it receives under the Privacy Shield Framework (see https://www.privacyshield.gov/) and that which it subsequently transfers to a third party acting as an agent on its behalf. NumberAI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.

YOUR CHOICES

Account Information

For Business Customers that maintain an account with us, you may update certain account information, including making corrections and deleting certain information by sending those updates to us at support@numberai.com.

Please note that we reserve the right to send certain important communications relating to the Services, such as Welcome notice, service announcements, security notices and Legal Notices, without offering the opportunity to opt-out of receiving them.

Individuals in the EU and Switzerland have the right to access personal data about them that we maintain, and in some cases to limit use and disclosure of their Personal Data. If you would like to request access to, deletions of, alterations to your personal data, or you have questions about your personal information that we maintain and/or have processed on behalf of a Business Customer and have under our custody and control, please contact us at support@number.com and provide us your name and contact information.

Promotional Communications

You may opt out of receiving communications from NumberAI that are identified as promotional materials by following the instructions in those emails or by sending a request to support@numberai.com. If you opt out, we may still send you non-promotional communications as indicated above.

SECURITY

To safeguard personal information, NumberAI takes reasonable, physical, technical and organizational measures to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction, or damage to your personal information. NumberAI uses industry-standard efforts to safeguard the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). However, we do want you to be aware that despite our efforts, no security measures are perfect or impenetrable, and that we cannot guarantee that the Services will be free of any defects or flaws that affect your use of it or the security of your information. Also, to assist in the protection of your personal information, we urge you to take reasonable precautions to protect your personal information while using the Services or the BC Services. For example, you should change your passwords often, use “strong” passwords, use a secure internet browser and update software and applications when available.

DATA RETENTION

The data that we collect from you may be transferred to, and stored, at a destination outside the European Economic Area ("EEA"), including in the United States. It may also be processed by staff operating outside the EEA who work for us (e.g., provide support services to Business Customers). By submitting your personal data, you agree to this transfer, storing or processing.

If you are a Business Customer and wish to cancel your account, change information within your account or request that we no longer use your information to provide you services, contact us at support@numberai.com.  If you are an end user of a Business Customer, please contact the Business Customer directly with service requests and changes to your information.

We will retain in our files and databases that include personally identifiable information (even after you cancel your account) for as long as necessary to comply with our legal obligations, for our business purposes, including but not limited to resolving disputes, troubleshooting service problems, as required by law, and/or to enforce the terms of service (including those of the BC), other applicable agreements and/or this Privacy Policy. We may retain non-personally identifiable information without any specific term limitation.

DO NOT TRACK

Do Not Track (or DNT) is an optional browser setting that you may set in your browser to relay to website you visit your preferences regarding tracking across websites. NumberAI does not have a mechanism in place to respond Do Not Track requests. For clarity, we continue to collect information in the manner described in this Privacy Notice from web browsers that have enabled DNT signals or similar mechanisms.

PRIVACY SHIELD NOTICE

With respect to the Personal Data that NumberAI receives in the United States from the EU and Switzerland, NumberAI complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data (collectively “Privacy Shield”). You can read more about Privacy Shield at https://www.privacyshield.gov/.

NumberAI has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the “Privacy Shield Principles”). If there is any conflict between the principles set forth in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

For personal data received or transferred as part of the Privacy Shield Framework, NumberAI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, NumberAI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

DISPUTE RESOLUTION

NumberAI is committed to resolve complaints about our collection or use of your personal information.  If you have questions or complaints regarding our privacy policy, practices and our compliance with Privacy Shield, please contact us at support@numberAI.com.

NumberAI has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS website at: https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services will be provided at no cost to you.

With regard to human resources data which includes individually identified or identifiable records that are transferred from the EU and/or Switzerland, as applicable, in the context of the employment relationship, NumberAI commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by the panel and/or Commissioner, as applicable.

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

In the event that NumberAI transfers personal information it receives to a third party acting as an agent on its behalf, then NumberAI will remain liable in the event that the third party processes such personal information in a manner inconsistent with this Privacy Policy, unless NumberAI proves that it is not responsible for the event giving rise to the damage.

YOUR CALIFORNIA PRIVACY RIGHTS

Under California Civil Code sections 1798.83, California residents may request a notice describing what categories of personal customer information NumberAI shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. To the extent applicable to NumberAI, such notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: NumberAI, Inc., Attn: Privacy Policy, 456 8th St, Oakland, CA 94607. Please specify that you are requesting the California Privacy Rights Notice and allow at least 30 days for a response.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: support@numberai.com.