Privacy Policy

 

A.I. COVERSATION SYSTEMS CONVERSATIONAL PLATFORM – PRIVACY NOTICE

This privacy notice explains how A.I. Coversation Systems Ltd. and its affiliates (“A.I. COVERSATION SYSTEMS“) collect, use, store and share your personal data in connection with the A.I. COVERSATION SYSTEMS Conversational Platform (the “Platform”) and/or the Services.

  1. APPLICABILITY
    1. This Privacy Notice (“PN“) is in effect as of the date set forth below.
    2. You (“User“) are not under any legal obligation to submit personal data to A.I. COVERSATION SYSTEMS. However, in case User chooses not to submit personal data to A.I. COVERSATION SYSTEMS, User may not be able to become a User and/or use the Platform and/or the Services.
    3. A.I. COVERSATION SYSTEMS may change this PN from time to time, therefore User should check back periodically. A.I. COVERSATION SYSTEMS will post any changed PN on its Platform. If A.I. COVERSATION SYSTEMS makes any changes to this PN that materially affect A.I. COVERSATION SYSTEMS’s practices with regard to the personal data A.I. COVERSATION SYSTEMS previously collected from User, A.I. COVERSATION SYSTEMS will endeavor to provide User with notice in advance of such change via email. A.I. COVERSATION SYSTEMS will seek User’s prior consent to any material changes, if and where this is required by applicable data protection laws.
    4. This PN does not apply to any content processed and/or stored by User when using the Platform and/or the Services. Also, the PN does not apply to any products, services, websites, links or any other content that are offered by third parties. User is advised to check the terms of use, privacy policies and/or privacy notices of such third parties.
    5. Any capitalized terms which are not defined herein shall have the meaning assigned to them in the A.I. COVERSATION SYSTEMS Conversational Platform Terms of Use and Services (“TOU“).
  1. PERSONAL DATA COLLECTED BY A.I. COVERSATION SYSTEMS
    1. Information provided by User

A.I. COVERSATION SYSTEMS collects any data User provides A.I. COVERSATION SYSTEMS with, including but not limited to:

      1. 2.1.1.User’s contact details (e.g. name, postal address, email address, phone number);
      2. 2.1.2.User’s payment information (e.g. credit card and bank account information);
      3. 2.1.3.User password and other authentication and security credential information;
      4. 2.1.4.Any communication between User and A.I. COVERSATION SYSTEMS, e.g. emails, phone conversations, chat sessions (except as indicated differently by User on the Platform).
    1. Information collected automatically

A.I. COVERSATION SYSTEMS automatically collects data when User visits, interacts with, or uses the Platform and/or the Services, including but not limited to:

      1. 2.2.1.Identifiers and information contained in cookies;
      2. 2.2.2.User’s settings preferences, backup information; 
      3. 2.2.3.Content User viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs);
      4. 2.2.4.Network and connection information, such as the Internet protocol (IP) address and information about User’s Internet service provider; 
      5. 2.2.5.Device information, such as browser type and version, operating system, or time zone setting; location of the device.
  1. PERSONAL DATA COLLECTED BY THIRD PARTIES.
    1. This PN does not apply to any products, services, websites, links or any other content that are offered by third parties on the Platform and/or the Services. User is advised to check the applicable third party agreements, and/or other third party policies. A.I. COVERSATION SYSTEMS does not have any control over such third parties’ privacy practices, or the technology used by such third parties in order to collect any personal data. Each User is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services.
  1. A.I. COVERSATION SYSTEMS’S USE OF PERSONAL DATA
    1. A.I. COVERSATION SYSTEMS processes User’s personal data to operate, provide, and improve the Platform and/or the Services, including but not limited to:
      1. 4.1.1.creating and managing User Accounts;
      2. 4.1.2.contacting User by A.I. COVERSATION SYSTEMS and communicating with User with respect to the Platform and/or the Services, e.g. by phone, email, chat; responding inquiries from User;
      3. 4.1.3.informing User about updates or offers;
      4. 4.1.4.personalizing the Platform and/or the Services, i.e. identifying User’s interests and recommending offers that might be of interest to User;
      5. 4.1.5.marketing and promoting the Platform and/or the Services;
      6. 4.1.6.providing assistance and support;
      7. 4.1.7.fulfilling User requests; meeting contractual or legal obligations;
      8. 4.1.8.protecting Users security, e.g. preventing and detecting fraud;
      9. 4.1.9.internal purposes, e.g. trouble shooting, data analysis, testing and statistical purposes.
    2. Except as provided herein, A.I. COVERSATION SYSTEMS does not use any personal data other than as necessary to provide the Platform and/or the Services, without obtaining User’s prior consent.
    3. A.I. COVERSATION SYSTEMS may ask for User’s consent to use User’s personal data for a specific purpose which will be provided to User.
  1. COOKIES
    1. A.I. COVERSATION SYSTEMS uses tracking mechanisms such as cookies in order to provide the Platform and/or the Services. A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Services may not work properly.
    2. By clicking on a link to a third-party website or service on the Platform and/or the Services, a third party may also transmit cookies to User. This PN does not cover the use of cookies by any third parties, and A.I. COVERSATION SYSTEMS is not responsible for such third parties’ privacy policies and practices.
    3. Without derogating from the foregoing, please note the following: 
      1. 5.3.1.A.I. COVERSATION SYSTEMS uses Google Analytics. Please click on www.google.com/policies/privacy/partners/ in order to find out how Google Analytics collects and processes data.
      2. 5.3.2.A.I. COVERSATION SYSTEMS uses FACEBOOK PIXELS. WITH RESPECT TO A.I. COVERSATION SYSTEMS USE OF FACEBOOK PIXELS PLEASE NOTE THE FOLLOWING:
        1. 5.3.2.1.THIRD PARTIES, INCLUDING FACEBOOK, MAY USE COOKIES, WEB BEACONS, AND OTHER STORAGE TECHNOLOGIES TO COLLECT OR RECEIVE USER’S INFORMATION FROM THE PLATFORM, WEBSITES AND ELSEWHERE ON THE INTERNET AND USE THAT INFORMATION TO PROVIDE MEASUREMENT SERVICES AND TARGET ADS;
        2. 5.3.2.2.USER CAN OPT-OUT OF THE COLLECTION AND USE OF INFORMATION FOR AD TARGETING;
        3. 5.3.2.3.A MECHANISM FOR EXERCISING SUCH OPT-OUT CHOICE CAN BE FOUND AT: __________ [Please insert a link for Users to opt out of Facebook Pixel.]
  2. SHARING PERSONAL DATA OF USER FOR LEGAL PURPOSES
    1. A.I. COVERSATION SYSTEMS may be required to retain or disclose personal information in order to:
      1. 6.1.1.comply with applicable laws or regulations;
      2. 6.1.2.comply with a court order, subpoena or other legal process;
      3. 6.1.3.respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in User’s jurisdiction or elsewhere);
      4. 6.1.4.engage with third-party service providers and/or sub-contractors which provide services for A.I. COVERSATION SYSTEMS’s business operations, a list of which can be received upon request;
      5. 6.1.5.disclose to third parties aggregated or de-identified information about Users for marketing, advertising, research, or other purposes;
      6. 6.1.6.disclose and/or transfer data to another entity if A.I. COVERSATION SYSTEMS is acquired by or merged with another A.I. COVERSATION SYSTEMS, if A.I. COVERSATION SYSTEMS sells or transfer a business unit or assets to another A.I. COVERSATION SYSTEMS, as part of a bankruptcy proceeding, or as part of any other similar business transfer;
      7. 6.1.7.A.I. COVERSATION SYSTEMS believes release is appropriate to comply with the law, enforce or apply A.I. COVERSATION SYSTEMS’s terms and other agreements, or protect the rights, property, or security of A.I. COVERSATION SYSTEMS, Users, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
    2. When A.I. COVERSATION SYSTEMS shares User’s data with third parties as specified above, A.I. COVERSATION SYSTEMS makes reasonable efforts to require such recipients to agree to only use the personal data A.I. COVERSATION SYSTEMS shares with them in accordance with this PN and A.I. COVERSATION SYSTEMS’s contractual specifications and for no other purpose than those determined by A.I. COVERSATION SYSTEMS in line with this PN.
  1. SECURITY 

A.I. COVERSATION SYSTEMS has taken appropriate technical and organisational measures to protect the information A.I. COVERSATION SYSTEMS collects about User from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. User should be aware, however, that no data security measures can guarantee 100% security.

  1. USERS IN THE EUROPEAN ECONOMIC AREA (EEA)
    1. Definition

Personal Data” means data that may be used, either alone or together with other information, to identify an individual user, including, without limitation, a user’s name, address, telephone number, username, email address, city and country, geolocation, unique identifiers, picture, or other similar information and includes personal data as defined in the General Data Protection Regulation 2016 /679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“).

    1. Legal Basis for Processing of Personal Data

A.I. COVERSATION SYSTEMS will only process User’s Personal Data if it has one or more of the following legal bases for doing so:

      1. 8.2.1.Contractual Necessity: processing of Personal Data is necessary to enter into a contract with User, to perform A.I. COVERSATION SYSTEMS’s contractual obligations to User under the TOU, to provide the Platform and/or the Services, to respond to requests from User, or to provide User with customer support;
      2. 8.2.2.Legitimate Interest: A.I. COVERSATION SYSTEMS has a legitimate interest to process User’s Personal Data;
      3. 8.2.3.Legal Obligation: processing of User’s Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
      4. 8.2.4.Consent: processing of User’s Personal Data with User’s consent.
    1. User’s Rights regarding Personal Data
      1. 8.3.1.Subject to applicable law, User has certain rights with respect to User’s Personal Data, including the following:
        1. 8.3.1.1.User may ask whether A.I. COVERSATION SYSTEMS holds Personal Data about User and request copies of such Personal Data and information about how it is processed;
        2. 8.3.1.2.User may request that inaccurate Personal Data is corrected;
        3. 8.3.1.3.User may request the deletion of certain Personal Data;
        4. 8.3.1.4.User may request A.I. COVERSATION SYSTEMS to cease or restrict the processing of Personal Data where the processing is inappropriate;
        5. 8.3.1.5.When User consents to processing User’s Personal Data for a specified purpose by A.I. COVERSATION SYSTEMS, User may withdraw User’s consent at any time, and A.I. COVERSATION SYSTEMS will stop any further processing of User’s data for that purpose.
      2. 8.3.2.In certain circumstances, A.I. COVERSATION SYSTEMS may not be able to fully comply with User’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, A.I. COVERSATION SYSTEMS will still respond to notify User of such a decision. 
      3. 8.3.3.User can exercise User’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting A.I. COVERSATION SYSTEMS at coco@a-i.com. In some cases, A.I. COVERSATION SYSTEMS may need User to provide A.I. COVERSATION SYSTEMS with additional information, which may include Personal Data, if necessary to verify User’s identity and the nature of User’s request.
    2. Transfer of User’s Personal Data outside of the EEA
      1. 8.4.1.A.I. COVERSATION SYSTEMS currently stores Personal Data in the Company’s data centers located in the US.
      2. 8.4.2.When transferring Personal Data from the EEA to the US, A.I. COVERSATION SYSTEMS relies on the EU-US Privacy Shield.
  1. INTERNATIONAL STORAGE

Each User is advised to be aware that personal data A.I. COVERSATION SYSTEMS collects may be transferred to, processed and stored outside User’s jurisdiction, and that data protection laws in the jurisdiction where the information is collected stored and/or processed may differ from User’s jurisdiction. Each User hereby gives User’s consent to this transfer, processing and storage of User’s information outside its jurisdiction.

  1. PERSONAL DATA OF CHILDREN

The Platform and/or the Services are not intended for children. Children under 18 years of age, may use the Platform and/or the Services only with the involvement of a parent or guardian.

  1. QUESTIONS REGARDING USER’S PERSONAL DATA? 

If User has any questions about this PN or A.I. COVERSATION SYSTEMS’s data practices in general, please contact us using the following information:

A.I. Coversation Systems, Ltd.

Anat Treibatch

Email: coco@a-i.com

Last update: March 1, 2020.