Privacy Policy
Last Updated Date: June 14, 2023
All questions, comments, and requests regarding data processing at Centrum-AI Inc., 548 Market St, PMB 53905, San Francisco, CA, 94104-5401, US, should be addressed to dataprotection@centrum-ai.com.
Your privacy is important to us. Please review this Privacy Policy that explains our information practices, the kinds of information we collect, how we use and share that information, and how you can opt-out of a use or correct or change such information. This Privacy Policy is incorporated by reference into our Terms of Use (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “Centrum-AI,” “we,” and “us” include Centrum-AI, Inc., and our affiliates and subsidiaries.
Scope
This Privacy Policy applies to how we collect, use, and disclose Personal Information we may obtain when:
You visit our websites or social media channels (each a “Site”); and
You use our mobile applications, products, and other online or offline offerings (collectively with the Sites, the “Services”), communicate with us, visit our offices or attend our events, among other activities this Privacy Policy discusses.
Centrum-AI often processes customer Personal Information as data processor, without knowing its content or origin. The customer is regarded as the data controller for such data within the meaning of applicable data protection laws, and Centrum-AI adheres to the privacy terms in its agreements with customers regarding the handling of customer Personal Information. If you have any questions about how your Personal Information is used or you wish to exercise any rights under applicable data protection laws as part of the Services, please inquire with the applicable customer directly.
Centrum-AI’s expectations for all individuals or entities whose responsibilities include Processing Personal Information for us is to protect it by following the terms of this Privacy Policy.
Revisions to this Privacy Policy
Information that we collect through our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time, and will notify you of the revised Privacy Policy by posting it on the Services or by sending you an email or other notification. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect. The “Last Updated Date” above indicates the date this Privacy Policy became effective.
Collection and Use of Information
Our primary goals in collecting information from you are to administer your use of the Services (including your Account, if you are an Account holder), to improve the functionality of the Services and to enable you to enjoy and easily navigate the Services.
Your Account Information
If you create Account with us, we will collect certain Personal Information from you, such as your name, email address and phone number. We may collect this information directly from you, or, if you provide us with your login credentials, from a social networking site (“SNS”) such as Facebook, in which case we may access and collect Personal Information from your SNS account based on that account’s privacy settings. To create your Account, we may also access and collect Personal Information and other information from Third Party Accounts that you link to your Account.
Third-Party Account Information
If you have an Account, in order to provide the Services to you, we’ll access, collect and, in some instances, store some or all of your content from Third Party Accounts that you link to your Account. Examples of Third Party Accounts that may be linked to your Account include Google Gmail and calendar accounts and Salesforce accounts. If you link your Google Gmail and calendar account(s) to your Account, then we will access your user data associated with those accounts via the Google API. Examples of information that we may access, collect and/or store from your Third Party Accounts include e-mail communications, e-mail opening information from individuals you communicate with, calendar event information, contact information from your Gmail and Salesforce address books and other data from your Salesforce account. We may combine, enhance or aggregate information from your Third Party Accounts with publicly-available information. For example, we may enrich contact information from your Gmail and Salesforce address book with public database information such as company size and estimated revenue. We may also access and use your Google user data to recommend updates to your linked Salesforce account, such as updating your Salesforce CRM to include colleagues from your Gmail contacts, or syncing customer communications between your Gmail and Salesforce accounts. If you authorize us to update your linked Salesforce account, then we may share your Google user data with Salesforce for the purpose of updating your linked Salesforce account. We may also access, use and store your Google user data in aggregated and non-identifying form for the purpose of improving, customizing and enhancing the Services.
Information Collected Using Cookies and Other Web Technologies
We use automated data collection tools such as Cookies and Web Beacons to collect certain information.
Cookies. We use Cookies on our Site. A Cookie is a small text file that is stored on your computer for record-keeping purposes. We may use both session Cookies and persistent Cookies to identify that you’ve logged into the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services.
Web Beacons. We may use Web Beacons (also known as Web bugs, pixel tags or clear GIFs) – tiny graphics with a unique identifier – for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services and to monitor how many visitors view our Services. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Information Collected Automatically
Our servers automatically record certain information about how you use our Services (we refer to this information as “Log Data”). Log Data may include information such as your Internet Protocol (IP) address, browser type, operating system, the web page that you visited before accessing our Services, the pages or features of our Services that you browsed and the time spent on those pages or features, search terms, the links on our Services that you clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services. We may use your IP address to generate aggregate, non-identifying information about how our Services are used.
Information Sent by Your Mobile Device
We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
Location Information
When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
How We Use Your Information
We Process Personal Information for a variety of business purposes, including:
To provide the Services or respond to user requests, including to:
Manage individual information and accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of our Services; and
Answer requests for customer or technical support.
For administrative purposes including to;
Measure interest and engagement in our Site and Services;
Conduct research and development;
Improve our products and Services;
Develop new products and Services;
Ensure internal quality control;
Verify individual identity;
Communicate with you about your Account, activities on our Site and Services and policy changes;
Prevent potentially prohibited or illegal activities; and
Enforce our Terms.
Third Party APIs and Software Development Kits
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. We use the following SDKs: Amazon Web Services (“AWS”) and ObjectiveFS. For more information about our use of APIs and SDKs, please contact us as set forth below.
Rights of Access, Rectification, Erasure, and Restriction
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
Communications from Us
We may use your Account information to send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding in-Service purchases and updates to our Terms of Use or this Privacy Policy.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect (including your Personal Information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
Data Retention
We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Links to Other Sites
Our Services may contain links to websites and services owned or operated by third parties (each, a “Third-Party Service”). Any information that you provide to a Third-Party Service is subject to the Third-Party Service’s privacy policy, not ours. We’re not responsible for the content, privacy or security practices and policies of any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-Party Services that you access.
International Transfer
Your Personal Information may be transferred to, Processed, maintained on, and stored outside of your state, province, country or other governmental jurisdiction (including, but not limited to, the European Union, the United States or other countries) where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and Process it there. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.
Your Choices: Right to Object to Processing
General. You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track. Our Site does not have the capability to respond to or honor ‘Do Not Track’ signals or similar mechanics received from various web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of cookies, pixel tags, local storage, and other technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu, www.youradchoices.ca/choices, and www.aboutads.info/choices. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Our Policy Toward Children
Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, we do not share Personal Information with third parties for their own marketing purposes.
Supervisory Authority
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
Definitions
“Personal Information” is any information relating to an identified or identifiable natural person.
“Process” or “Processing” as used in this Privacy Policy means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (7) health information; (8) sexual orientation or information about the Individual’s sex life; or (9) information relating to the commission of a criminal offense.
Contact
All questions, comments and requests regarding this Privacy Notice may be addressed to dataprotection@centrum-ai.com.
Centrum-AI, Inc.
548 Market St PMB 53905
San Francisco, CA, 94104-5401, US
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