What Information Do We Collect and How is Such Information Used?
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.
When you create an Account, you may provide information that could be Personal Information, such as your username, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you messages about our Services. You may unsubscribe from these messages through your Account settings or by clicking on the unsubscribe link included at the bottom of marketing emails, although we, regardless, reserve the right to continue sending you non-marketing emails, such as emails about your accounts and our business dealings with you.
Information you provide to us:
When you use the Services, you may provide us with your audio recordings ("Audio Recordings") and any text, images or videos that you upload or provide to us in the context of the Services.
We also collect information that you include in your profile, such as your photo and birthday.
Information you provide us about others:
If you choose to collaborate on a task with your co-workers or friends, or refer us to them, you provide us with the email address and contact information of your co-workers or friends.
If you provide an Audio Recording, this may contain the Personal Information of third parties. Before you do so, please make sure you have the necessary permissions from your co-workers, friends or other third parties before sharing Personal Information or referring them to us.
Information Collected from Other Sources:
Further, our products may request permissions to take actions on your behalf using your third-party account credentials. For example, if you choose to integrate Colibri products with your Zoom or Slack account, Colibri products will request authority to read incoming messages and send emails on your behalf.
We do not collect financial information. However, we receive transaction information from our payment processor Square.
We may collect your phone number and the unique device ID number of the mobile device on which you use the Application.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
When you participate in one of our surveys, we may collect additional personal information.
We also collect other types of personal information that you provide to us voluntarily.
If you participate in a contest, sweepstakes or other promotion, we will collect any data you provide in connection with that promotion.
We may also obtain information from other sources and combine that with information we collect on our Services.
We may also collect personal information at other points in our Services that state that personal information is being collected.
IP Address Information and Other Information Collected Automatically:
- When you use our Services, some information is automatically collected. For example, when you use our Services, how you use the Services, information about the type of device you use, your Open Device Identification Number, date/time stamps for your visit, your unique device identifier, your browser type, operating system, Internet Protocol (IP) address, and domain name are all collected. This information is generally used to help us deliver the most relevant information to you and administer and improve the Services. In addition, in the event our Application crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application.
- We may gather certain information automatically and store it in log files, including IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to improve the content of the Services, market research purposes, to communicate information to visitors and to better tailor our Services to our users’ needs.
- We may collect and create anonymous and/or deidentified data records about how both unregistered and registered users, collectively, use the Services ("Aggregate Information"), such as the number and frequency of visitors to the Site or Application. Some of this information is derived from Personal Information. We reserve the right to use Aggregate Information for any purpose and disclose it to third parties in our sole discretion. This Aggregate Information is not Personal Information and we use reasonable efforts to ensure that it cannot be tied back to you, your Account, your web browser or mobile device. We use this anonymous data to enhance the content of our Services and improve the Services, for example by allowing us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
Information Collected Using Cookies:
- Most browsers or mobile devices have an option for turning off the cookie feature, which will prevent your browser or mobile device from accepting new cookies, as well as (depending on the sophistication of your browser or mobile device software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they may enable you to take advantage of some features of the Services.
Information Related to Advertising and the Use of Web Beacons:
We don’t serve advertisements. We may serve it in the future. In that case, this Policy will be amended accordingly.
General Uses of Information:
- operate, maintain, and improve our sites, products, and services;
- process and deliver contest entries and rewards;
- respond to comments and questions and provide customer service;
- send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
- link or combine user information with other personal information we get from third parties, to help understand your needs and provide you with better service;
- protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
- to process orders or otherwise provide and deliver products and services you request;
- to process and deliver orders for additional services;
- identify you as a user in our system;
- facilitate the creation of and secure your Account on our network; and
- develop and improve marketing and advertising for the Services and partner services.
We may store and process personal information in the United States and other countries.
We may get information about you from other sources. We may add this to information we get from the Services.
How, and With Whom, Is My Information Shared?
The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.
Public Information about Your Activity on the Services:
Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or Application or otherwise through the Services.
Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.
IP Address Information:
User Profile Information:
User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
We do not collect financial information.
Information Disclosed Pursuant to Business Transfers:
Information Disclosed for Our Protection and the Protection of Others:
Information We Share With Your Consent:
We may share your Personal Information to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, with your consent, or to third parties designated by you.
Is Information About Me Secure?
Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, phone, and browser or other device by signing off after you have finished accessing your Account.
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We otherwise store all of our information, including your IP address information, using industry-standard techniques. We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security and we do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.
What Information of Mine Can I Access?
If you are a registered user, you can access and edit information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.
California Privacy Rights:
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Alterra.ai, Inc., 341 El Carmelo Ave., Palo Alto CA 94306
How Long Do You Store My Information?
Colibri stores all Personal Information for as long as necessary to fulfill the purposes set out in this Policy, or for as long as we are required to do so by law or in order to comply with a regulatory obligation. When deleting Personal Information, we will take measures to render such Personal Information irrecoverable or irreproducible, and the electronic files which contain Personal Information will be permanently deleted.
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing firstname.lastname@example.org. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public. We may retain an archived copy of your records as required by law or for legitimate business purposes.
What Choices Do I Have Regarding My Information?
- You can use some of the features of the Services without registering for an Account, thereby limiting the type of information that we collect.
- You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
- You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
- You may opt-out of providing your Personal Information to the Application at any time by uninstalling the Application.
What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to email@example.com. We will make every effort to resolve your concerns.
A Note about Children
We do not intentionally gather personal information from users who are under the age of 13. If a child under 13 submits personal information to Colibri and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: firstname.lastname@example.org.
Users Outside of the United States
EU-US and Swiss-US Privacy Shield
Accountability for Onward Transfer
If we transfer your Personal Information to another country, we may remain liable and will take appropriate measures to protect your privacy and the Personal Information we transfer.
We’ll take appropriate physical, technical, and organizational measures to protect your Personal Information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
Data Integrity and Purpose Limitation
We’ll collect only as much Personal Information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent. We’ll take appropriate steps to make sure the Personal Information in our records is accurate.
Recourse, Enforcement and Liability
341 El Carmelo Ave.,
Palo Alto CA 94306
Legal Bases for Processing EU Users’ Personal Information
We only process your information when we have the legal basis to do so. That is, we will only process your Personal Information when:
- We need it to provide you the Services;
- It satisfies Colibri’s legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting the Services and protecting our legal rights;
- We need to process your data to comply with our legal obligations.
Transfer of EU Users’ Personal Information outside the EU
We may transfer your Personal Information to Colibri-affiliated entities in third parties in the United States or other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we transfer Personal Information of customers in the European Economic Area or Switzerland to any such country, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules, or other appropriate legal mechanisms to safeguard the transfer. Please refer to the Section “EU-US and Swiss-US Privacy Shield” below.
EU Users’ Rights to Control Personal Information
You have control over your Personal Information. Below are the rights you have and the steps you can take to exercise them. Please note that your rights may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep, and it may take time for us to investigate your request. If you believe that we are not respecting your rights with regard to your Personal Information, you may lodge a complaint with your local supervisory authority.
Right to Access
You have a right to request a copy of the Personal Information that Colibri holds. To request this information, please email us at email@example.com.
Right to Rectification
If you believe that any Personal Information that Colibri holds is incorrect, you have the right to correct that information. You can change your Colibri account information on the “Settings” page, and if you have any further concerns regarding the accuracy of your information, please email us at firstname.lastname@example.org.
Right to Erasure, Restriction, or Objection to Processing
If you believe we do not have the right to process your information or you object to our processing for a particular purpose, or if you want us to erase your Personal Information altogether, please email us at email@example.com.
Right to Withdraw Consent
If you gave us consent to process your Personal Information for a particular purpose, you have the right to withdraw that consent by emailing us at firstname.lastname@example.org. Your withdrawal of consent does not affect the lawfulness of our processing of your Personal Information prior to the withdrawal.
You have the right to obtain the Personal Information that you have directly submitted to Colibri in a format you can transfer to another service provider. If you want to exercise this right, please email us at email@example.com.
Mode and place of processing the Data
Methods of processing
Colibri takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Colibri, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Colibri (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Colibri. The updated list of these parties may be requested from Colibri at any time.
Legal basis of processing
Colibri may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
Note: Under some legislations Colibri may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which Colibri is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Colibri;
- processing is necessary for the purposes of the legitimate interests pursued by Colibri or by a third party.
In any case, Colibri 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.
The Data is processed at Colibri's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries and about the security measures taken by Colibri to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Colibri using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between Colibri and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of Colibri’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Colibri within the relevant sections of this document or by contacting Colibri.
Colibri may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Colibri may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the Users is collected to allow Colibri to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Infrastructure monitoring, Tag Management, Hosting and backend infrastructure, Managing contacts and sending messages, User database management, Handling payments and Managing support and contact requests.
For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable Colibri to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilizes the Data collected to track and examine the use of Colibri, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Unless otherwise specified, Colibri processes any payments by credit card via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Colibri isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed. The payment processors are responsible for the processing of your Personal Information, and may use your Personal Information for their own purposes in accordance with their privacy policies.
Square (Square, Inc.)
Square is a payment service provided by Square Inc.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Colibri to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Colibri.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored:
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
This type of service has the purpose of capturing User’s online meetings and phone conversations subject to Colibri’s Services.
Twilio (Twilio, Inc.)
Twilio is a communication service provided by Twilio, Inc.
Personal Data processed: Any data that may be encapsulated in User’s online meetings and phone conversations subject to Colibri’s Services.
Speech recognition services
Whereas by default Colibri relies on its own in-house Automatic Speech Recognition (ASR) engine, it may also use third-party ASR engines, e.g. when handling languages other than English.
Google ASR (Google LLC)
Google ASR is an Automatic Speech Recognition (ASR) engine that provides automatic speech-to-text transformation.
Personal Data processed: Any data that may be encapsulated in User’s online meetings and phone conversations subject to Colibri’s Services.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailChimp (The Rocket Science Group LLC)
Mailchimp is an online marketing platform operated by The Rocket Science Group LLC.
Personal Data processed: name, email address.
Typeform (Typeform SL)
Typeform is a service that allows to create online forms and collect information online provided by Typeform SL
Personal Data processed: any type of personal data collected through typeforms.
Managing support and contact requests
This type of service allows Colibri to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
This type of service helps Colibri to manage the tags or scripts needed on Colibri in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
User database management
This type of service allows Colibri to build user profiles by starting from an email address, a personal name, or other information that the User provides to Colibri, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that Colibri can display and use for improving Colibri.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Colibri.
Pipedrive (Pipedrive OÜ)
Pipedrive is a User database management service provided by Pipedrive OÜ.
Effective Date: April 25, 2021
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