Effective date: August 4, 2023
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
Our Commercial or Business Purposes for Collecting Personal Data
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you
Information about Biometric Information We Collect from Our Users
Our Collection and Use of Biometric Information. We may collect biometric information about our users in order to create and operate our users’ avatars, and to train our models. Biometric information is a form of personal data based on an individual’s biometric identifier – such as an iris scan, fingerprint, voiceprint, hand geometry, or facial geometry – that is used to identify an individual. As used in this policy, “Biometric Information” refers to both “biometric information” and “biometric identifiers” as those terms are defined under applicable law. We use Biometric Information to create and operate our users’ avatars and to improve our models and consequently our avatars. We may also use Biometric Information to comply with applicable legal obligations or comply with a request from law enforcement or government entities, unless prohibited by law.
Our Retention of Biometric Information. We retain your Biometric Information in accordance with our contractual obligations with our customers, with the specific retention periods determined by our customers. Unless a different retention period is required by our customer by contract, Biometric Information will be retained until the earlier of (i) the initial purpose for collecting or obtaining such Biometric Information has been satisfied or (ii) three years following the user’s last interaction with us. Our hosting and cloud compute provider will only store Biometric Information on our behalf for the retention periods set forth in this section. Such storage by our hosting and cloud compute provider is necessary for us to provide you with the Services. Our hosting and cloud compute provider will not access or use your Biometric Information for any other purpose. Once the retention periods in this section have expired, Biometric Information will be permanently and irretrievably deleted by our hosting and cloud compute provider.
How We Secure Biometric Information. We seek to protect your Biometric Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures. We endeavor to protect Biometric Information in the same or more protective manner than the manner in which we store, transmit, or protect other confidential and sensitive information. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Questions about Your Biometric Information. If you have questions about the collection and use of your Biometric Information, please contact us at email@example.com.
Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
Deleting Personal Data or Revoking Consent
You may request that we delete your Personal Data at any time by contacting us at firstname.lastname@example.org. If you consented to our collection of your Personal Data, you may revoke this consent by contacting us at email@example.com.