Last updated: April 11, 2019
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.
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.
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.
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 SourcesFor 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; andCarry out any other purpose for which the information is collected.SHARING AND TRANSFER OF INFORMATION
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.
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
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
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.
Account InformationFor 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 firstname.lastname@example.org
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 email@example.com and provide us your name and contact information.
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 firstname.lastname@example.org. 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.
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 email@example.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.
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/
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 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