- To deliver targeted advertising to you. We may process
your information to develop and display personalised content and advertising tailored to your interests, location, and
more.
- To determine the effectiveness of our marketing and promotional
campaigns. We may process your information to better understand how to provide
marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual's
vital interest. We may process your information when necessary to save or protect an
individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal
information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect
your rights, or to fulfil
our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal information. As such,
we may rely on the following legal bases to process your personal information:- Consent. We may process
your information if you have given us permission (i.e.
consent) to use your personal information for a specific purpose. You can withdraw your consent
at any time. Learn more about withdrawing your consent.
- Legitimate Interests. We
may process your information when we believe it is reasonably necessary to achieve our
legitimate business interests and those interests do not outweigh your interests and fundamental
rights and freedoms. For example, we may process your personal information for some of the
purposes described in order to:
- Develop and display personalised and relevant advertising content for our users
- Support our marketing activities
- Legal Obligations. We may
process your information where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or
defend our legal rights, or disclose your information as evidence in litigation in which we are
involved.
- Vital Interests. We may process your information
where we believe it is necessary to protect your vital interests or the vital interests of a third
party, such as situations involving potential threats to the safety of any person.
In legal terms, we are generally the 'data controller' under European data protection laws of the
personal information described in this Privacy Notice, since we determine the means and/or
purposes of the data processing we perform. This Privacy Notice does not apply to the personal
information we process as a 'data processor' on behalf of our customers. In those situations, the customer that we
provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible
for your personal information, and we merely process your information on their behalf in
accordance with your instructions. If you want to know more about our customers' privacy
practices, you should read their privacy policies and direct any questions you have to them.
If you are located in
Canada, this section applies to you.
We may process your information if you have
given us specific permission (i.e. express consent) to use
your personal information for a specific purpose, or in situations where your permission can be
inferred (i.e. implied consent). You can withdraw your
consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
- If collection is clearly in the interests of an
individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
- For identifying injured, ill, or deceased
persons and communicating with next of kin
- If we have reasonable grounds
to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable
to expect collection and use with consent would compromise the availability or the accuracy of
the information and the collection is reasonable for purposes related to investigating a breach of
an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to
comply with a subpoena, warrant, court order, or rules of the court relating to the production of
records
- If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the purposes for which the
information was produced
- If the collection is solely for journalistic, artistic, or literary
purposes
- If the information is publicly available and is specified by the
regulations
- We may
disclose de-identified information for approved research or statistics projects, subject to ethics
oversight and confidentiality commitments
4. WHEN AND WITH WHOM
DO WE SHARE YOUR PERSONAL INFORMATION?
In
Short: We may share information in specific situations described in this
section and/or with the following third parties.
We may need to share your
personal information in the following situations:
- Business Transfers. We may share or transfer your
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.
- Business Partners. We may share your information with our business
partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER
TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may
use cookies and similar tracking technologies (like web beacons and pixels) to gather
information when you interact with our Services. Some online tracking technologies help us
maintain the security of our Services, prevent crashes, fix
bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online
tracking technologies on our Services for analytics and advertising, including to help manage
and display advertisements, to tailor advertisements to your interests, or to send abandoned
shopping cart reminders (depending on your communication preferences). The third parties and
service providers use their technology to provide advertising about products and services
tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which
includes targeted advertising, as defined under the applicable laws) under applicable US state
laws, you can opt out of these online tracking technologies by submitting a request as described
below under section 'DO UNITED STATES
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'
Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice.Google Analytics
We may share your information with Google
Analytics to track and analyse the use of the Services. To opt out of being tracked
by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the
Google Privacy &
Terms page.
6. DO WE OFFER ARTIFICIAL
INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence,
machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools
powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to
enhance your experience and provide you with innovative solutions. The terms in this Privacy
Notice govern your use of the AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party service
providers ('AI Service
Providers'), including
Deepgram, ElevenLabs, OpenAI and Google Cloud AI. As outlined
in this Privacy Notice, your input, output, and personal information will be shared with and
processed by these AI Service Providers to enable your use of our AI Products for purposes
outlined in 'WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?' You must not use the AI Products in any
way that violates the terms or policies of any AI Service Provider.
Our AI Products
Our AI Products are designed for the following functions:
- Natural language
processing
How We Process Your
Data Using AI
All personal information processed using our AI
Products is handled in line with our Privacy Notice and our agreement with third parties. This
ensures high security and safeguards your personal information throughout the process, giving
you peace of mind about your data's safety.
7.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and
process your information in countries other than your own.
Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and
processed by us in our facilities and in the facilities of the third parties with whom we may share
your personal information (see 'WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?' above), including facilities in the United States, and other
countries.
If you are a resident in the European Economic Area (EEA), United Kingdom
(UK), or Switzerland, then these countries may not necessarily have data protection laws or other
similar laws as comprehensive as those in your country. However, we will take all necessary
measures to protect your personal information in accordance with this Privacy Notice and
applicable law.
8. HOW LONG DO WE KEEP
YOUR INFORMATION?
In Short: We
keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless
otherwise required by law.
We will only keep your personal information for as long as it is necessary for
the purposes set out in this Privacy Notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).
When we
have no ongoing legitimate business need to process your personal information, we will either
delete or anonymise
such information, or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
9. DO WE COLLECT
INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age or the
equivalent age as specified by law in your jurisdiction.
We do not knowingly collect, solicit
data from, or market to children under 18 years of age or
the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you
represent that you are at least 18 or the equivalent age as
specified by law in your jurisdiction or that you
are the parent or guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your
jurisdiction has been collected, we will
deactivate the account and take reasonable measures to promptly delete such data from our
records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your
jurisdiction, please contact us at greg@31labs.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European
Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account
at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK,
Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; (iv) if applicable, to data portability; and (v) not to be
subject to automated decision-making. If a decision that
produces legal or similarly significant effects is made solely by automated means, we will inform
you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right
to object to the processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section 'HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?' below. We will
consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are
relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any
time. You can withdraw your consent at any time by contacting us by using the contact details
provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However,
please note that this will not affect the lawfulness of the processing before its withdrawal
nor, when applicable law allows, will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
If you have questions or comments about
your privacy rights, you may email us at support@31labs.com.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically communicates your
choice not to be tracked online. If a standard for online tracking is adopted that we must follow in
the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser
DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond
to them at this time.
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident
of California, Colorado, Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey,
Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you
may have the right to request access to and receive details about the personal information we
maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete
your personal information. You may also have the right to withdraw your consent to our
processing of your personal information. These rights may be limited in some circumstances by
applicable law. More information is provided below.Categories of Personal Information We Collect
The table below shows the categories of
personal information we have collected in the past twelve (12) months. The table includes
illustrative examples of each category and does not reflect the personal information we collect
from you. For a comprehensive inventory of all personal information we process, please refer to
the section 'WHAT INFORMATION DO WE
COLLECT?'
| Category | Examples | Collected |
|---|
A. Identifiers | Contact
details, such as real name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email address, and account
name |
NO
|
B. Personal information as defined in
the California Customer Records statute | Name, contact information, education,
employment, employment history, and financial information |
NO
|
C.
Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status,
and other demographic data |
NO
|
D. Commercial information | Transaction information, purchase history, financial details, and payment
information | |
E.
Biometric information | Fingerprints and voiceprints |
NO
|
F.
Internet or other similar network activity | Browsing history, search history,
online behaviour, interest
data, and interactions with our and other websites, applications, systems, and advertisements |
NO
|
G.
Geolocation data | Device location |
NO
|
H.
Audio, electronic, sensory, or similar information | Images
and audio, video or call recordings created in connection with our business activities |
YES
|
I.
Professional or employment-related information | Business
contact details in order to provide you our Services at a business level or job title, work history,
and professional qualifications if you apply for a job with us |
NO
|
J.
Education Information | Student records and directory information |
NO
|
K.
Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above
to create a profile or summary about, for example, an individual’s preferences and
characteristics |
NO
|
| L. Sensitive personal Information | |
NO
|
We may
also collect other personal information outside of these categories through instances where you
interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer
support channels;
- Participation in customer surveys or
contests; and
- Facilitation in the delivery of our
Services and to respond to your inquiries.
We will use and retain the collected personal
information as needed to provide the Services or for:
- Category H - As long as the user has an
account with us
Will your information be shared with anyone else?
We may use your personal
information for our own business purposes, such as for undertaking internal research for
technological development and demonstration. This is not considered to be 'selling' of your personal information.
We have not disclosed, sold, or shared any personal information to
third parties for a business or commercial purpose in the preceding twelve (12) months.
We will not sell or share personal information in
the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data
protection laws. However, these rights are not absolute, and in certain cases, we may decline
your request as permitted by law. These rights include:
- Right to know whether or not we are
processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with
us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for
targeted advertising (or sharing as defined under
California’s privacy law), the sale of personal
data, or profiling in furtherance of decisions that produce legal or similarly significant effects
('profiling')
Depending
upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being
processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to
obtain a list of the categories of third parties to which we have disclosed personal data (as
permitted by applicable law, including the privacy law in
California, Delaware, and Maryland)
- Right to obtain a list of specific third parties to which we have disclosed
personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
- Right to obtain a list of third parties to which we have sold personal data (as permitted by
applicable law, including the privacy law in Connecticut)
- Right to review, understand, question,
and depending on where you live, correct how personal data has been profiled (as permitted by
applicable law, including the privacy law in Connecticut
and Minnesota)
- Right to limit use and disclosure of
sensitive personal data (as permitted by applicable law, including the privacy law in California)
- Right to opt out of the collection of sensitive data and
personal data collected through the operation of a voice or facial recognition feature (as
permitted by applicable law, including the privacy law in Florida)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting greg@31labs.com, by emailing us at greg@31labs.com, or by referring to the contact details at the bottom
of this document.
Under certain US state data
protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from
an authorised agent that
does not submit proof that they have been validly authorised to act on your behalf in accordance with
applicable laws.
Request
Verification
Upon receiving your
request, we will need to verify your identity to determine you are the same person about whom
we have the information in our system. We will only use personal information provided in your
request to verify your identity or authority to make the request. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for security or fraud-
prevention purposes.
If you submit the request through an authorised agent, we may need to collect
additional information to verify your identity before processing your request and the agent will
need to provide a written and signed permission from you to submit such request on your
behalf.Appeals
Under certain US state data protection laws, if we decline to take action
regarding your request, you may appeal our decision by emailing us at support@31labs.com. We will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If your
appeal is denied, you may submit a complaint to your state attorney general.California 'Shine The
Light' Law
California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who
are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a California resident
and would like to make such a request, please submit your request in writing to us by using the
contact details provided in the section 'HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?'
13. DO OTHER REGIONS
HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you
reside in.
Australia and New
Zealand
We collect and process your
personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice
satisfies the notice requirements defined in both Privacy
Acts, in particular: what personal information we collect
from you, from which sources, for which purposes, and other recipients of your personal
information.
If you do not wish to provide the personal information
necessary to fulfil their
applicable purpose, it may affect our ability to provide our services, in particular:
- offer you the
products or services that you want
- respond to or help
with your requests
At any time, you have the right
to request access to or correction of your personal information. You can make such a request by
contacting us by using the contact details provided in the section 'HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'
If you are unsatisfied with the manner in which we address any complaint
with regard to our processing of personal information, you can contact the office of the regulator,
the details of which are:
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary
to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version
will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to
this Privacy Notice, we may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this Privacy Notice frequently
to be informed of how we are protecting your information.
31 LABS LTD
71-75
Shelton Street , London WC2H 9JQ, UK
London, England WC2H 9JQ
United Kingdom
If you are a
resident in the United Kingdom, we are the 'data
controller' of your personal information. We have appointed
Grigoriy Tkachenko to be our representative in the UK. You can contact them directly regarding our
processing of your information, by email at greg@31labs.com, or by post to:
__________
__________ __________
England
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on
the applicable laws of your country or state of residence
in the US, you may have the right to request access to the personal
information we collect from you, details about how we have processed it, correct inaccuracies, or
delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.
These rights may be limited in some circumstances by applicable law. To request to review,
update, or delete your personal information, please visit: greg@31labs.com.