Perceptful.AI Privacy Notice

Perceptful.AI is committed to protecting your privacy. This Privacy Notice explains how we handle information about you that is under our control when you use our Services, visit our websites, or otherwise interact with us. This Privacy Notice also sets out the rights and choices that you have in relation to the personal information that we have about you and how you can exercise them.

Perceptful.AI’s Services

Perceptful.AI’s platform allows you to synthesize insights into actionable recommendations from content uploaded to or ingested by the engine, and to share the results with others or export for others. Collectively, we refer to the Perceptful.AI platform and all its offerings as our “Services”.

This Privacy Notice is incorporated by reference into and forms part of the Perceptful.AI Master Agreement.

Collection and Use of Personal Information

We collect information about you when you use our Services, visit our websites, and/or interact with us in a business context. Information may be collected when you provide it to us directly, or automatically when you use the Services and/or our websites. We may also collect data from other sources, including those that are publicly available or from third-party data providers.

Perceptful.AI collects and uses personal information to provide you with Services and to improve our service offerings. Our purposes for collecting and using personal information include:

• We collect and use contact and account details for account management, personalization, and in-platform communication;
• We collect and use billing, payment and other transactional data for customer relation and subscription management;
• We collect and use platform usage data for providing Services as well as notification about platform changes and updates; and
• We collect and use logs, usage data, and customer support data for maintaining security, resolving support issues, and improving our Services.

With your consent, we may use your personal information to provide you with marketing messages such as exclusive offerings, updates, promotions, and notifications about our products or services, customer or partner programs.

Minors

We do not knowingly collect personal information from minors. Our Services are not intended for use by minors and should only be accessed by individuals who are at least 18 years old and are using the Services for business purposes. If you believe we may have information from a minor, please contact us.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and browsing behavior information. When you visit our websites or use our platform, we may collect information from you automatically through cookies or similar technology. Currently, we use strictly necessary cookies for the proper functioning of our website and on our platform.

Sharing of Personal Information

We do not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.

• Authorized employees and contractors. Perceptful.AI restricts access to your information to authorized employees and contractors on a need-to-know basis to fulfil their job duties. All our employees and contractors are obligated to protect the confidentiality and privacy of your information.
• Service Providers, Authorized Resellers, and Partners. We will share information about you with authorized service providers to help us communicate with you and manage our business operations including data hosting, security, and payment processing. We take your privacy into consideration when selecting service providers who are permitted to process your information for the purpose of assisting us in providing the Services.
• Customer Organizations. Where your employer or an entity has purchased Services on your behalf, we may disclose information about you such as your name and email address, and some usage information including whether a user has logged in to the Services, frequency of login, and time spent using the Services to assist your employer or the entity in managing its use of the Services.
• Successor and Affiliated Entities. We may share information about you among Perceptful.AI-controlled affiliates and subsidiaries to provide the Services and for our general business purposes. Our affiliates and subsidiaries will protect your information in a manner that is consistent with this Privacy Notice and where applicable, in accordance with that entity’s policies. We may also share or transfer your information if we are part of a corporate transaction such as a merger or acquisition or sale of assets. In such an event, we will inform those entities of the requirement to handle your information in accordance with this Privacy Notice.
• Legal and Regulatory Authorities. We may need to disclose information about you where we believe that it is reasonably necessary to comply with a law or regulation, or if we are otherwise legally required to do so, such as in response to a court order or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands. For government access requests concerning you or your organization, we would first attempt to redirect the request to you and/or notify you unless we are legally prohibited from doing so. In addition, we may disclose information about you if we believe it is necessary to investigate, prevent, or take action: (a) against illegal activities, fraud, situations involving potential threats to our rights or property (or to the rights or property of those who use our Services), or to protect the personal safety of any person; or (b) regarding situations that involve the security of our Services, abuse of the Services infrastructure, or the Internet in general, such as denial of service attacks.
• Professional Advisors. We use professional advisors, including lawyers and accountants, and may be required to disclose information about you when engaging them for their services and as necessary for audits, financial and other regulatory reviews.

Safeguards and Retention of Personal Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.

We retain personal information only for as long as necessary to carry out the purposes identified in this Privacy Notice or to meet our legal or business requirements.

We may also create and retain aggregate, de-identified or anonymized personal information for internal research and analysis purposes, including to improve business operations.

Your Privacy Rights and Choices

Depending on the data protection laws that apply to you, you may have the right to:

• Request access to your information in our control
• Request correction of inaccurate information in our control
• Request deletion of your information in our control
• Request a transfer of your information to a third party in a machine-readable format
• Object to our processing of your information, withdraw your consent, or ask us to restrict the processing of your information
• Opt out of certain disclosures of your information to third parties, including for targeted advertising purposes

You also have the right not to be discriminated against for exercising any of these rights. If you would like to exercise any of your rights, such as access, correction, or deletion of your information, you may email our Privacy Office for assistance. We will handle your request within the period set out by law, typically thirty (30) days, unless it is unusually extensive or complex, in which case we will advise you of the expected timeline for handling your request. We may also ask for additional information to confirm your identity.

For marketing communications, you may opt out by contacting our Privacy Officer.

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have privacy laws that are different from the laws applicable in your place of residence.

Our Services are managed by Perceptful.AI’s headquarters in Canada. As the European Commission considers Canada to be a country which provides adequate data protection, information about you may be lawfully transferred from the European Economic Area (“EEA”) to Canada.

Our data servers are located in Ireland, and third-party service providers and partners operate around the world. These third-party service providers may process or store personal information on servers outside of the EEA, UK, and Switzerland. We rely on adequacy (if sent to Canada), and the EU-US Data Privacy Framework (“DPF”), the UK extension to the EU-US DPF, the Swiss-US DPF, or standard contractual clauses (“SCCs”), if sent to the US or onward to other countries, to ensure that information about you is lawfully transferred under European data protection laws.

We take reasonable safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

Profiling

In some instances, we may use your personal information to learn about your preferences and to provide customized products or services to you. Where applicable, we will inform you of the technology used for collecting/using your profiling, locating, identifying information and providing a way for you to activate them. You may deactivate at any time.

GDPR and UK Data Protection Laws

Depending on the situation and the type of data involved, Perceptful.AI may act as a data controller or a data processor. Perceptful.AI may act as a data controller when we are:

• Collecting information from you to set up and manage your Perceptful.AI account (for example, your name and email address);
• Monitoring usage information on our websites and platforms;
• Managing your contact and other related information to send transactional, marketing, and other communications to you;
• Responding to a support or general inquiry; and
• Recruiting individuals for job opportunities.

The legal bases for processing information about you include:

• It is necessary to perform a contract; for example, to fulfill our obligations of providing Services to you.
• Legitimate interest; for example, to improve our Services to you or to maintain the security of the Services.
• Your consent; for example, when you sign up for our newsletter or when you apply for a job. Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time.
• Compliance with applicable laws; for example, processing payroll and tax information to comply with employment and tax legislation.

You are acting as a data controller and Perceptful.AI is acting as a data processor when you are using our Services and making decisions about the personal information that is being processed in the Services. We rely on you to comply with applicable privacy laws when handling information about individuals through the Services, including obtaining any necessary consents and providing any necessary notices.

There are certain obligations under the GDPR and other data protection laws that you have as a data controller, including being responsible for managing information on the Services. As a data processor, Perceptful.AI will only access and process information to provide you with the Services in accordance with your instructions, the Terms of Service, and applicable laws. As part of delivering the Services, we may process information to further improve the Services, such as enhancing usability and developing new features.

If you are using the Services as an authorized user of a Perceptful.AI customer (e.g., your employer), that customer determines their own policies regarding the processing of personal information, which may apply to your use of the Services.

California Privacy Rights

If you are a consumer as defined by the California Consumer Privacy Act (“CCPA”), this section applies to you and supplements our Privacy Notice. Under the CCPA, you have the following rights:

• The right to know about the personal information collected about you
• The right to have your personal information deleted
• The right to correct inaccurate personal information
• The right not to be discriminated against for exercising consumer rights under the CCPA
• The right to opt-out of the “sale” or “sharing” of your personal information.

While we share or disclose personal information with third parties or service providers for the purpose of providing the Services, managing our relationship with you, and for personalized advertising purposes, we do not “sell” your personal information in the traditional sense. However, the definitions of “sale” and “sharing” under the CCPA may include the disclosure of your information to our advertising and marketing partners.

You may opt out of the “sale” or “sharing” of your personal information for advertising purposes by contacting our Privacy Officer. We do not knowingly “sell” or “share” the personal information of individuals under 16 years of age.

Contact us

If you have any questions, concerns or comments about this Privacy Notice or the manner in which we or our service providers handle your personal information, or wish to request access to or correction of your personal information in our records, please contact us at:

Privacy Officer
Perceptful.AI
privacy@perceptful.ai

You may also bring your questions or concerns to your local data protection authority.

Changes to this Privacy Notice

We may update this Privacy Notice periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Notice when it was most recently updated.