Privacy Policy
This
Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about
Your privacy rights and how the law protects You.
We use
Your Personal data to provide and improve the Service. By using the Service,
You agree to the collection and use of information in accordance with this
Privacy Policy.
The
words of which the initial letter is capitalized have meanings defined under
the following conditions. The following definitions shall have the same meaning
regardless of whether they appear in singular or in plural.
1. Definitions.
For the purposes of this Privacy Policy:
(a)
“Account” means a unique account created for You to
access our Service or parts of our Service.
(b)
“Business”, for the purpose of the CCPA (California Consumer
Privacy Act), means the Company as the legal entity that collects Consumers'
personal information and determines the purposes and means of the processing of
Consumers' personal information, or on behalf of which such information is
collected and that alone, or jointly with others, determines the purposes and
means of the processing of consumers' personal information, that does business
in the State of California.
(c)
“Company” (referred to herein as either the
"Company", "We", "Us" or "Our") means Mindwrite
AI, Inc., with offices at 106 langtree village drive, Ste. 301, Mooresville, NC
28117. For the purpose of the GDPR, the Company is the Data Controller.
(d)
“Consumer”, for the purpose of the CCPA (California Consumer
Privacy Act), means a natural person who is a California resident. A resident,
as defined in the law, includes (1) every individual who is in the USA for
other than a temporary or transitory purpose, and (2) every individual who is
domiciled in the USA who is outside the USA for a temporary or transitory
purpose.
(e)
“Cookies” means small files that are placed on Your
computer, mobile device or any other device by a website, containing the
details of Your browsing history on that website among its many uses.
(f) “Data
Controller”, for the purposes of the GDPR (General Data Protection
Regulation), means the Company as the legal person which alone or jointly with
others determines the purposes and means of the processing of Personal Data.
(g)
“Device” means any electronic device that can access the
Service such as a computer, a cellphone or a digital tablet.
(h)
“Do Not Track (DNT)” means a concept that has been
promoted by US regulatory authorities, in particular the U.S. Federal Trade
Commission (FTC), for the Internet industry to develop and implement a
mechanism for allowing internet users to control the tracking of their online
activities across websites.
(i) “Personal
Data” means any information that relates to an identified or
identifiable individual. For the purposes for GDPR, Personal Data means any
information relating to You such as a name, an identification number, location
data, online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity. For the
purposes of the CCPA, Personal Data means any information that identifies,
relates to, describes or is capable of being associated with, or could
reasonably be linked, directly or indirectly, with You.
(j) “Sale”,
for the purpose of the CCPA (California Consumer Privacy Act), means 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 to another business or a third party for
monetary or other valuable consideration.
(k)
“Service” means the online and/or mobile services, web
site, and software provided on or in connection with the service provided by Mindwrite
AI under this Agreement and as detailed on Mindwrite AI’s website at www.mindwrite.ai.
(l) “Service
Provider” means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals
employed by the Company to facilitate the Service, to provide the Service on
behalf of the Company, to perform services related to the Service or to assist
the Company in analyzing how the Service is used. For the purpose of the GDPR,
Service Providers are considered Data Processors.
(m) “Third-party
Social Media Service” means any website or any social network website
through which a User can log in or create an account to use the Service.
(n)
“Usage Data” means data collected automatically, either
generated by the use of the Service or from the Service infrastructure itself
(for example, the duration of a page visit).
(p)
“You” means the individual accessing or using the Service,
or the company, or other legal entity on behalf of which such individual is
accessing or using the Service, as applicable. Under GDPR (General Data
Protection Regulation), You can be referred to as the Data Subject or as the
User as you are the individual using the Service.
2. Collecting and Using
Your Personal Data
(a)
Personal Data
While
using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:
·
Email address
·
First name and last name
·
Phone number
·
Address, State, Province, ZIP/Postal code, City
·
Usage Data
(b)
Usage Data
Usage
Data is collected automatically when using the Service.
Usage
Data may include information such as Your Device's Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that
You visit, the time and date of Your visit, the time spent on those pages,
unique device identifiers and other diagnostic data.
When
You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile
device You use, Your mobile device unique ID, the IP address of Your mobile
device, Your mobile operating system, the type of mobile Internet browser You
use, unique device identifiers and other diagnostic data.
We may
also collect information that Your browser sends whenever You visit our Service
or when You access the Service by or through a mobile device.
(c)
Information from Third-Party Social Media Services
The
Company allows You to create an account and log in to use the Service through
the following Third-party Social Media Services:
·
Google
·
Facebook
·
Twitter
If You
decide to register through or otherwise grant us access to a Third-Party Social
Media Service, We may collect Personal data that is already associated with
Your Third-Party Social Media Service's account, such as Your name, Your email
address, Your activities or Your contact list associated with that account.
You
may also have the option of sharing additional information with the Company
through Your Third-Party Social Media Service's account. If You choose to
provide such information and Personal Data, during registration or otherwise,
You are giving the Company permission to use, share, and store it in a manner
consistent with this Privacy Policy.
(d)
Tracking Technologies and Cookies
We use
Cookies and similar tracking technologies to track the activity on Our Service
and store certain information. Tracking technologies used are beacons, tags,
and scripts to collect and track information and to improve and analyze Our
Service. The technologies We use may include:
·
Cookies or Browser Cookies. A cookie is a small file placed on Your
Device. You can instruct Your browser to refuse all Cookies or to indicate when
a Cookie is being sent. However, if You do not accept Cookies, You may not be
able to use some parts of our Service. Unless you have adjusted Your browser
setting so that it will refuse Cookies, our Service may use Cookies.
·
Flash Cookies. Certain features of our Service may use local stored
objects (or Flash Cookies) to collect and store information about Your
preferences or Your activity on our Service. Flash Cookies are not managed by
the same browser settings as those used for Browser Cookies. For more
information on how You can delete Flash Cookies, please read "Where can I
change the settings for disabling, or deleting local shared objects?"
available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
·
Web Beacons. Certain sections of our Service and our emails may contain
small electronic files known as web beacons (also referred to as clear gifs,
pixel tags, and single-pixel gifs) that permit the Company, for example, to
count users who have visited those pages or opened an email and for other
related website statistics (for example, recording the popularity of a certain
section and verifying system and server integrity).
Cookies
can be "Persistent" or "Session" Cookies. Persistent
Cookies remain on Your personal computer or mobile device when You go offline,
while Session Cookies are deleted as soon as You close Your web browser. Learn
more about cookies: What Are Cookies?.
We use
both Session and Persistent Cookies for the purposes set out below:
i. Necessary / Essential Cookies
·
Type: Session Cookies
·
Administered by: Us
·
Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its features.
They help to authenticate users and prevent fraudulent use of user accounts.
Without these Cookies, the services that You have asked for cannot be provided,
and We only use these Cookies to provide You with those services.
ii. Cookies Policy / Notice Acceptance Cookies
·
Type: Persistent Cookies
·
Administered by: Us
·
Purpose: These Cookies identify if users have accepted the use of
cookies on the Website.
iii. Functionality Cookies
·
Type: Persistent Cookies
·
Administered by: Us
·
Purpose: These Cookies allow us to remember choices You make when You
use the Website, such as remembering your login details or language preference.
The purpose of these Cookies is to provide You with a more personal experience
and to avoid You having to re-enter your preferences every time You use the
Website.
iv. Tracking and Performance Cookies
·
Type: Persistent Cookies
·
Administered by: Third-Parties
·
Purpose: These Cookies are used to track information about traffic to
the Website and how users use the Website. The information gathered via these
Cookies may directly or indirectly identify you as an individual visitor. This
is because the information collected is typically linked to a pseudonymous
identifier associated with the device you use to access the Website. We may
also use these Cookies to test new pages, features or new functionality of the
Website to see how our users react to them.
v. Targeting and Advertising Cookies
·
Type: Persistent Cookies
·
Administered by: Third-Parties
·
Purpose: These Cookies track your browsing habits to enable Us to show
advertising which is more likely to be of interest to You. These Cookies use
information about your browsing history to group You with other users who have
similar interests. Based on that information, and with Our permission, third
party advertisers can place Cookies to enable them to show adverts which We
think will be relevant to your interests while You are on third party websites.
For
more information about the cookies we use and your choices regarding cookies,
please visit our Cookies Policy or the Cookies section of our Privacy Policy.
(e)
Use of Your Personal Data
The
Company may use Personal Data for the following purposes:
i. To provide and maintain our Service, including to monitor the
usage of our Service.
ii. To manage Your Account: to manage Your registration as a user
of the Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered user.
iii. For the performance of a contract: the development, compliance
and undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.
iv. To contact You: To contact You by email, telephone calls,
SMS, or other equivalent forms of electronic communication, such as a mobile
application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted services,
including the security updates, when necessary or reasonable for their
implementation.
v. To provide You with news, special offers and general
information about other goods, services and events which we offer that are
similar to those that you have already purchased or enquired about unless You
have opted not to receive such information.
vi. To manage Your requests: To attend and manage Your requests
to Us.
vii. To deliver targeted advertising to You: We may use Your
information to develop and display content and advertising (and work with
third-party vendors who do so) tailored to Your interests and/or location and
to measure its effectiveness.
viii. For business transfers: We may use Your information to
evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of Our assets, whether as
a going concern or as part of bankruptcy, liquidation, or similar proceeding,
in which Personal Data held by Us about our Service users is among the assets
transferred.
ix. For other purposes: We may use Your information for other
purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our
Service, products, services, marketing and your experience.
We may
share Your personal information in the following situations:
i. With Service Providers: We may share Your personal information
with Service Providers to monitor and analyze the use of our Service, to show
advertisements to You to help support and maintain Our Service, to advertise on
third party websites to You after You visited our Service, for payment processing,
to contact You.
ii. For business transfers: We may share or transfer Your
personal information 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.
iii. With Affiliates: We may share Your information with Our
affiliates, in which case we will require those affiliates to honor this
Privacy Policy. Affiliates include Our parent company and any other
subsidiaries, joint venture partners or other companies that We control or that
are under common control with Us.
iv. With business partners: We may share Your information with
Our business partners to offer You certain products, services or promotions.
v. With other users: when You share personal information or
otherwise interact in the public areas with other users, such information may
be viewed by all users and may be publicly distributed outside. If You interact
with other users or register through a Third-Party Social Media Service, Your
contacts on the Third-Party Social Media Service may see Your name, profile,
pictures and description of Your activity. Similarly, other users will be able
to view descriptions of Your activity, communicate with You and view Your
profile.
vi. With Your consent: We may disclose Your personal information
for any other purpose with Your consent.
(f) Retention
of Your Personal Data
The
Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal
Data to the extent necessary to comply with our legal obligations (for example,
if we are required to retain your data to comply with applicable laws), resolve
disputes, and enforce our legal agreements and policies.
The
Company will also retain Usage Data for internal analysis purposes. Usage Data
is generally retained for a shorter period of time, except when this data is
used to strengthen the security or to improve the functionality of Our Service,
or We are legally obligated to retain this data for longer time periods.
(g)
Transfer of Your Personal Data
Your
information, including Personal Data, is processed at the Company's operating
offices and in any other places where the parties involved in the processing
are located. It means that this information may be transferred to — and
maintained on — computers located outside of Your state, province, country or
other governmental jurisdiction where the data protection laws may differ than
those from Your jurisdiction.
Your
consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.
The
Company will take all steps reasonably necessary to ensure that Your data is
treated securely and in accordance with this Privacy Policy and no transfer of
Your Personal Data will take place to an organization or a country unless there
are adequate controls in place including the security of Your data and other
personal information.
(h)
Disclosure of Your Personal Data
i. Business Transactions
If the
Company is involved in a merger, acquisition or asset sale, Your Personal Data
may be transferred. We will provide notice before Your Personal Data is
transferred and becomes subject to a different Privacy Policy.
ii. Law enforcement
Under
certain circumstances, the Company may be required to disclose Your Personal
Data if required to do so by law or in response to valid requests by public
authorities (e.g. a court or a government agency).
iii. Other legal requirements
The
Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
·
Comply with a legal obligation
·
Protect and defend the rights or property of the Company
·
Prevent or investigate possible wrongdoing in connection with the
Service
·
Protect the personal safety of Users of the Service or the public
·
Protect against legal liability
(i) Security
of Your Personal Data
The
security of Your Personal Data is important to Us, but remember that no method
of transmission over the Internet, or method of electronic storage is 100%
secure. While We strive to use commercially acceptable means to protect Your
Personal Data, We cannot guarantee its absolute security.
3. Detailed Information
on the Processing of Your Personal Data
The
Service Providers We use may have access to Your Personal Data. These
third-party vendors collect, store, use, process and transfer information about
Your activity on Our Service in accordance with their Privacy Policies.
(a)
Analytics
We may
use third-party Service providers to monitor and analyze the use of our
Service.
i. Google Analytics
·
Google Analytics is a web analytics service offered by Google that
tracks and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google services.
Google may use the collected data to contextualize and personalize the ads of
its own advertising network.
·
You can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-on. The
add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js)
from sharing information with Google Analytics about visits activity.
·
For more information on the privacy practices of Google, please visit
the Google Privacy & Terms web page: https://policies.google.com/privacy
ii. Firebase
·
Firebase is an analytics service provided by Google Inc.
·
You may opt-out of certain Firebase features through your mobile device
settings, such as your device advertising settings or by following the
instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
·
We also encourage you to review the Google's policy for safeguarding
your data: https://support.google.com/analytics/answer/6004245
·
For more information on what type of information Firebase collects,
please visit the How Google uses data when you use our partners' sites or apps
webpage: https://policies.google.com/technologies/partner-sites
iii. Mixpanel
·
Mixpanel is provided by Mixpanel Inc.
·
You can prevent Mixpanel from using your information for analytics
purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
·
For more information on what type of information Mixpanel collects,
please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
iv. Amplitude
·
Their Privacy Policy can be viewed at https://amplitude.com/amplitude-security-and-privacy
(b)
Advertising
We may
use Service Providers to show advertisements to You to help support and
maintain Our Service.
i. Google AdSense & DoubleClick Cookie
·
Google, as a third party vendor, uses cookies to serve ads on our
Service. Google's use of the DoubleClick cookie enables it and its partners to
serve ads to our users based on their visit to our Service or other websites on
the Internet.
·
You may opt out of the use of the DoubleClick Cookie for interest-based
advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
ii. Facebook
·
Their Privacy Policy can be viewed at https://www.facebook.com/policy.php
iii. Linkedin
·
Their Privacy Policy can be viewed at https://www.linkedin.com/legal/ads-policy
(c)
Email Marketing
We may
use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You. You
may opt-out of receiving any, or all, of these communications from Us by
following the unsubscribe link or instructions provided in any email We send or
by contacting Us.
We
may use Email Marketing Service Providers to manage and send emails to You.
i. User
·
Their Privacy Policy can be viewed at https://user.com/en/privacy-policy/
(d)
Payments
We may
provide paid products and/or services within the Service. In that case, we may
use third-party services for payment processing (e.g. payment processors).
We
will not store or collect Your payment card details. That information is
provided directly to Our third-party payment processors whose use of Your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure the
secure handling of payment information.
i. Stripe
·
Their Privacy Policy can be viewed at https://stripe.com/us/privacy
(e)
Behavioral Remarketing
The
Company uses remarketing services to advertise to You after You accessed or
visited our Service. We and Our third-party vendors use cookies and non-cookie
technologies to help Us recognize Your Device and understand how You use our
Service so that We can improve our Service to reflect Your interests and serve
You advertisements that are likely to be of more interest to You.
These
third-party vendors collect, store, use, process and transfer information about
Your activity on Our Service in accordance with their Privacy Policies and to
enable Us to:
·
Measure and analyze traffic and browsing activity on Our Service
·
Show advertisements for our products and/or services to You on
third-party websites or apps
·
Measure and analyze the performance of Our advertising campaigns
Some
of these third-party vendors may use non-cookie technologies that may not be
impacted by browser settings that block cookies. Your browser may not permit
You to block such technologies. You can use the following third-party tools to
decline the collection and use of information for the purpose of serving You
interest-based advertising:
·
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
·
The EDAA's opt-out platform http://www.youronlinechoices.com/
·
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You
may opt-out of all personalized advertising by enabling privacy features on
Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads
Personalization (Android). See Your mobile device Help system for more
information.
We
may share information, such as hashed email addresses (if available) or other
online identifiers collected on Our Service with these third-party vendors.
This allows Our third-party vendors to recognize and deliver You ads across
devices and browsers. To read more about the technologies used by these
third-party vendors and their cross-device capabilities please refer to the
Privacy Policy of each vendor listed below.
The
third-party vendors we use are:
i. Google Ads (AdWords)
·
Google Ads (AdWords) remarketing service is provided by Google Inc.
·
You can opt-out of Google Analytics for Display Advertising and
customise the Google Display Network ads by visiting the Google Ads Settings
page: http://www.google.com/settings/ads
·
Google also recommends installing the Google Analytics Opt-out Browser
Add-on - https://tools.google.com/dlpage/gaoptout -
for your web browser. Google Analytics Opt-out Browser Add-on provides visitors
with the ability to prevent their data from being collected and used by Google
Analytics.
·
For more information on the privacy practices of Google, please visit
the Google Privacy & Terms web page: https://policies.google.com/privacy
ii. Twitter
·
Twitter remarketing service is provided by Twitter Inc.
·
You can opt-out from Twitter's interest-based ads by following their
instructions: https://support.twitter.com/articles/20170405
·
You can learn more about the privacy practices and policies of Twitter
by visiting their Privacy Policy page: https://twitter.com/privacy
iii. Facebook
·
Facebook remarketing service is provided by Facebook Inc.
·
You can learn more about interest-based advertising from Facebook by
visiting this page: https://www.facebook.com/help/164968693837950
·
To opt-out from Facebook's interest-based ads, follow these instructions
from Facebook: https://www.facebook.com/help/568137493302217
·
Facebook adheres to the Self-Regulatory Principles for Online
Behavioural Advertising established by the Digital Advertising Alliance. You
can also opt-out from Facebook and other participating companies through the
Digital Advertising Alliance in the USA http://www.aboutads.info/choices/,
the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or
the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/,
or opt-out using your mobile device settings.
·
For more information on the privacy practices of Facebook, please visit
Facebook's Data Policy: https://www.facebook.com/privacy/explanation
4. GDPR Privacy
(a)
Legal Basis for Processing Personal Data under GDPR
We may
process Personal Data under the following conditions:
·
Consent: You have given Your consent for processing Personal Data for
one or more specific purposes.
·
Performance of a contract: Provision of Personal Data is necessary for
the performance of an agreement with You and/or for any pre-contractual
obligations thereof.
·
Legal obligations: Processing Personal Data is necessary for compliance
with a legal obligation to which the Company is subject.
·
Vital interests: Processing Personal Data is necessary in order to
protect Your vital interests or of another natural person.
·
Public interests: Processing Personal Data is related to a task that is
carried out in the public interest or in the exercise of official authority
vested in the Company.
·
Legitimate interests: Processing Personal Data is necessary for the
purposes of the legitimate interests pursued by the Company.
In any
case, the Company will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal
Data is a statutory or contractual requirement, or a requirement necessary to
enter into a contract.
(b)
Your Rights under the GDPR
The
Company undertakes to respect the confidentiality of Your Personal Data and to
guarantee You can exercise Your rights.
You
have the right under this Privacy Policy, and by law if You are within the EU,
to:
·
Request access to Your Personal Data. The right to access, update or
delete the information We have on You. Whenever made possible, you can access,
update or request deletion of Your Personal Data directly within Your account
settings section. If you are unable to perform these actions yourself, please
contact Us to assist You. This also enables You to receive a copy of the
Personal Data We hold about You.
·
Request correction of the Personal Data that We hold about You. You have
the right to to have any incomplete or inaccurate information We hold about You
corrected.
·
Object to processing of Your Personal Data. This right exists where We
are relying on a legitimate interest as the legal basis for Our processing and
there is something about Your particular situation, which makes You want to
object to our processing of Your Personal Data on this ground. You also have the
right to object where We are processing Your Personal Data for direct marketing
purposes.
·
Request erasure of Your Personal Data. You have the right to ask Us to
delete or remove Personal Data when there is no good reason for Us to continue
processing it.
·
Request the transfer of Your Personal Data. We will provide to You, or
to a third-party You have chosen, Your Personal Data in a structured, commonly
used, machine-readable format. Please note that this right only applies to
automated information which You initially provided consent for Us to use or
where We used the information to perform a contract with You.
·
Withdraw Your consent. You have the right to withdraw Your consent on
using your Personal Data. If You withdraw Your consent, We may not be able to
provide You with access to certain specific functionalities of the Service.
(c)
Exercising of Your GDPR Data Protection Rights
You
may exercise Your rights of access, rectification, cancellation and opposition
by contacting Us. Please note that we may ask You to verify Your identity
before responding to such requests. If You make a request, We will try our best
to respond to You as soon as possible.
You
have the right to complain to a Data Protection Authority about Our collection
and use of Your Personal Data. For more information, if You are in the European
Economic Area (EEA), please contact Your local data protection authority in the
EEA.
5. CCPA Privacy
This
privacy notice section for California residents supplements the information
contained in Our Privacy Policy and it applies solely to all visitors, users,
and others who reside in the State of California.
(a)
Categories of Personal Information Collected
We
collect 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. The following is a list of
categories of personal information which we may collect or may have been
collected from California residents within the last twelve (12) months.
Please
note that the categories and examples provided in the list below are those
defined in the CCPA. This does not mean that all examples of that category of
personal information were in fact collected by Us, but reflects our good faith
belief to the best of our knowledge that some of that information from the
applicable category may be and may have been collected. For example, certain
categories of personal information would only be collected if You provided such
personal information directly to Us.
i. Category A: Identifiers.
·
Examples: A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address,
account name, driver's license number, passport number, or other similar
identifiers.
·
Collected: Yes.
ii. Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)).
·
Examples: 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.
·
Collected: Yes.
iii. Category C: Protected classification characteristics under
California or federal law.
·
Examples: 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).
·
Collected: No.
iv. Category D: Commercial information.
·
Examples: Records and history of products or services purchased or
considered.
·
Collected: Yes.
v. Category E: Biometric information.
·
Examples: 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.
·
Collected: No.
vi. Category F: Internet or other similar network activity.
·
Examples: Interaction with our Service or advertisement.
·
Collected: Yes.
vii. Category G: Geolocation data.
·
Examples: Approximate physical location.
·
Collected: No.
viii. Category H: Sensory data.
·
Examples: Audio, electronic, visual, thermal, olfactory, or similar
information.
·
Collected: No.
ix. Category I: Professional or employment-related information.
·
Examples: Current or past job history or performance evaluations.
·
Collected: No.
x. Category 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)).
·
Examples: 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.
·
Collected: No.
xi. Category K: Inferences drawn from other personal information.
·
Examples: Profile reflecting a person's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.
·
Collected: No.
Under
CCPA, personal information does not include:
·
Publicly available information from government records
·
Deidentified or aggregated consumer information
·
Information excluded from the CCPA's scope, such as:
·
Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial data.
·
Personal Information covered by certain sector-specific privacy laws,
including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act
(GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's
Privacy Protection Act of 1994.
(b)
Sources of Personal Information
We
obtain the categories of personal information listed above from the following
categories of sources:
·
Directly from You. For example, from the forms You complete on our
Service, preferences You express or provide through our Service, or from Your
purchases on our Service.
·
Indirectly from You. For example, from observing Your activity on our
Service.
·
Automatically from You. For example, through cookies We or our Service
Providers set on Your Device as You navigate through our Service.
·
From Service Providers. For example, third-party vendors to monitor and
analyze the use of our Service, third-party vendors to provide advertising on
our Service, third-party vendors to deliver targeted advertising to You,
third-party vendors for payment processing, or other third-party vendors that
We use to provide the Service to You.
(c)
Use of Personal Information for Business Purposes or Commercial
Purposes
We may
use or disclose personal information We collect for "business
purposes" or "commercial purposes" (as defined under the CCPA),
which may include the following examples:
·
To operate our Service and provide You with our Service.
·
To provide You with support and to respond to Your inquiries, including
to investigate and address Your concerns and monitor and improve our Service.
·
To fulfill or meet the reason You provided the information. For example,
if You share Your contact information to ask a question about our Service, 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.
·
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.
·
For internal administrative and auditing purposes.
·
To detect security incidents and protect against malicious, deceptive,
fraudulent or illegal activity, including, when necessary, to prosecute those
responsible for such activities.
Please
note that the examples provided above are illustrative and not intended to be
exhaustive. For more details on how we use this information, please refer to
the "Use of Your Personal Data" section.
If We
decide to collect additional categories of personal information or use the
personal information We collected for materially different, unrelated, or
incompatible purposes We will update this Privacy Policy.
(d)
Disclosure of Personal Information for Business Purposes or Commercial
Purposes
We may
use or disclose and may have used or disclosed in the last twelve (12) months
the following categories of personal information for business or commercial
purposes:
·
Category A: Identifiers
·
Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))
·
Category D: Commercial information
·
Category F: Internet or other similar network activity
Please
note that the categories listed above are those defined in the CCPA. This does
not mean that all examples of that category of personal information were in fact
disclosed, but reflects our good faith belief to the best of our knowledge that
some of that information from the applicable category may be and may have been
disclosed.
When
We disclose personal information for a business purpose or a commercial 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.
(e)
Sale of Personal Information
As
defined in the CCPA, "sell" and "sale" mean 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 for valuable
consideration. This means that We may have received some kind of benefit in
return for sharing personal information, but not necessarily a monetary
benefit.
Please
note that the categories listed below are those defined in the CCPA. This does not
mean that all examples of that category of personal information were in fact
sold, but reflects our good faith belief to the best of our knowledge that some
of that information from the applicable category may be and may have been
shared for value in return.
We
may sell and may have sold in the last twelve (12) months the following
categories of personal information:
·
Category A: Identifiers
·
Category B: Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))
·
Category D: Commercial information
·
Category F: Internet or other similar network activity
6. Share of Personal
Information
We may
share Your personal information identified in the above categories with the
following categories of third parties:
·
Service Providers
·
Payment processors
·
Our affiliates
·
Our business partners
·
Third party vendors to whom You or Your agents authorize Us to disclose
Your personal information in connection with products or services We provide to
You
(a)
Sale of Personal Information of Minors Under 16 Years of Age
We do
not sell the personal information of Consumers We actually know are less than
16 years of age, unless We receive affirmative authorization (the "right
to opt-in") from either the Consumer who is between 13 and 16 years of
age, or the parent or guardian of a Consumer less than 13 years of age.
Consumers who opt-in to the sale of personal information may opt-out of future
sales at any time. To exercise the right to opt-out, You (or Your authorized
representative) may submit a request to Us by contacting Us.
If
You have reason to believe that a child under the age of 13 (or 16) has
provided Us with personal information, please contact Us with sufficient detail
to enable Us to delete that information.
(b)
Your Rights under the CCPA
The
CCPA provides California residents with specific rights regarding their
personal information. If You are a resident of California, You have the
following rights:
·
The right to notice. You have the right to be notified which categories
of Personal Data are being collected and the purposes for which the Personal
Data is being used.
·
The right to request. Under CCPA, You have the right to request that We
disclose information to You about Our collection, use, sale, disclosure for
business purposes and share of personal information. Once We receive and
confirm Your request, We will disclose to You:
o
The categories of personal information We collected about You
o
The categories of sources for the personal information We collected
about You
o
Our business or commercial purpose for collecting or selling that
personal information
o
The categories of third parties with whom We share that personal
information
o
The specific pieces of personal information We collected about You
o
If we sold Your personal information or disclosed Your personal information
for a business purpose, We will disclose to You:
§
The categories of personal information categories sold
§
The categories of personal information categories disclosed
·
The right to say no to the sale of Personal Data (opt-out). You have
the right to direct Us to not sell Your personal information. To submit an
opt-out request please contact Us.
·
The right to delete Personal Data. You have the right to
request the deletion of Your Personal Data, subject to certain exceptions. Once
We receive and confirm Your request, 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 Providers to:
o
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.
o
Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
activities.
o
Debug products to identify and repair errors that impair existing
intended functionality.
o
Exercise free speech, ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law.
o
Comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 et. seq.).
o
Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics and
privacy laws, when the information's deletion may likely render impossible or seriously
impair the research's achievement, if You previously provided informed consent.
o
Enable solely internal uses that are reasonably aligned with consumer
expectations based on Your relationship with Us.
o
Comply with a legal obligation.
o
Make other internal and lawful uses of that information that are
compatible with the context in which You provided it.
·
The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of Your consumer's rights, including
by:
o
Denying goods or services to You
o
Charging different prices or rates for goods or services, including the
use of discounts or other benefits or imposing penalties
o
Providing a different level or quality of goods or services to You
o
Suggesting that You will receive a different price or rate for goods or
services or a different level or quality of goods or services
(c)
Exercising Your CCPA Data Protection Rights
In
order to exercise any of Your rights under the CCPA, and if You are a
California resident, You can contact Us:
·
By email: hello@mindwrite.ai
Only
You, or a person registered with the California Secretary of State that You
authorize to act on Your behalf, may make a verifiable request related to Your
personal information.
Your
request to Us must:
·
Provide sufficient information that allows Us to reasonably verify You
are the person about whom We 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 the required information if
we cannot:
·
Verify Your identity or authority to make the request
·
And confirm that the personal information relates to You
We
will disclose and deliver the required information free of charge within 45
days of receiving Your verifiable request. The time period to provide the
required information may be extended once by an additional 45 days when
reasonable necessary and with prior notice.
Any
disclosures We provide will only cover the 12-month period preceding the
verifiable request's receipt.
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.
(d)
Do Not Sell My Personal Information
You
have the right to opt-out of the sale of Your personal information. Once We
receive and confirm a verifiable consumer request from You, we will stop
selling Your personal information. To exercise Your right to opt-out, please
contact Us.
The
Service Providers we partner with (for example, our analytics or advertising
partners) may use technology on the Service that sells personal information as
defined by the CCPA law. If you wish to opt out of the use of Your personal
information for interest-based advertising purposes and these potential sales
as defined under CCPA law, you may do so by following the instructions below.
Please
note that any opt out is specific to the browser You use. You may need to opt
out on every browser that You use.
i. Website
You
can opt out of receiving ads that are personalized as served by our Service
Providers by following our instructions presented on the Service:
·
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
·
The EDAA's opt-out platform http://www.youronlinechoices.com/
·
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The
opt out will place a cookie on Your computer that is unique to the browser You
use to opt out. If you change browsers or delete the cookies saved by your
browser, You will need to opt out again.
ii. Mobile Devices
Your
mobile device may give You the ability to opt out of the use of information
about the apps You use in order to serve You ads that are targeted to Your
interests:
·
"Opt out of Interest-Based Ads" or "Opt out of Ads
Personalization" on Android devices
·
"Limit Ad Tracking" on iOS devices
You
can also stop the collection of location information from Your mobile device by
changing the preferences on Your mobile device.
(e)
"Do Not Track" Policy as Required by California Online
Privacy Protection Act (CalOPPA)
Our
Service does not respond to Do Not Track signals.
However,
some third-party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to
inform websites that You do not want to be tracked. You can enable or disable
DNT by visiting the preferences or settings page of Your web browser.
(f) Your
California Privacy Rights (California's Shine the Light law)
Under
California Civil Code Section 1798 (California's Shine the Light law),
California residents with an established business relationship with us can
request information once a year about sharing their Personal Data with third
parties for the third parties' direct marketing purposes.
If
you'd like to request more information under the California Shine the Light
law, and if You are a California resident, You can contact Us using the contact
information provided below.
(g)
California Privacy Rights for Minor Users (California Business and
Professions Code Section 22581)
California
Business and Professions Code section 22581 allow California residents under
the age of 18 who are registered users of online sites, services or
applications to request and obtain removal of content or information they have
publicly posted.
To
request removal of such data, and if You are a California resident, You can
contact Us using the contact information provided below, and include the email
address associated with Your account.
Be
aware that Your request does not guarantee complete or comprehensive removal of
content or information posted online and that the law may not permit or require
removal in certain circumstances.
7. Miscellaneous
(a)
Links to Other Websites
Our
Service may contain links to other websites that are not operated by Us. If You
click on a third-party link, You will be directed to that third party's site.
We strongly advise You to review the Privacy Policy of every site You visit.
We
have no control over and assume no responsibility for the content, privacy policies
or practices of any third-party sites or services.
(b)
Changes to this Privacy Policy
We may
update Our Privacy Policy from time to time. We will notify You of any changes
by posting the new Privacy Policy on this page.
We
will let You know via email and/or a prominent notice on Our Service, prior to
the change becoming effective and update the "Last updated" date at
the top of this Privacy Policy.
You
are advised to review this Privacy Policy periodically for any changes. Changes
to this Privacy Policy are effective when they are posted on this page.
(c)
Contact Information
If you
have any questions about this Privacy Policy, You can contact us by email: hello@mindwrite.ai