Privacy Policy

This Privacy Notice explains how Contextual AI, Inc. collects, uses, shares, and otherwise processes your personal information (also known as personal data) in connection with the use of the Contextual AI websites and applications that link to this Privacy Notice (the “Sites”) and in the usual course of business, such as in connection with our events, sales, and marketing activities (collectively, the “Services”). It also contains information about your choices and privacy rights.

1. Our services

We provide the Contextual AI data processing platform (the “Platform Services”) to our customers and users (collectively, “Customers”) under an agreement with them and solely for their benefit and the benefit of their personnel authorized to use the Platform Services (“Authorized Users”). Our processing of Customer data, including any Customer personal data, is governed by our agreement with the relevant Customer. This Privacy Notice does not apply to (i) the personal data that our Customers and their Authorized Users upload, submit or otherwise make available to the Platform Services, which is addressed in our agreements with our Customers; (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notices; or (iii) personal information that we collect and process in connection with our recruitment activities.

We recommend that you read this Privacy Notice in full to ensure that you are informed of our practices and understand any rights or choices you may have.

2. Legislation

All personal data we gather will be processed in accordance with all applicable data protection laws and principles, including the General Data Protection Regulation (“GDPR”) and applicable U.S. State Privacy Laws, including but not limited to the California Consumer Privacy Act (CCPA/CPRA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and other emerging US state regulations, as well as regulatory requirements relating to the processing of personal data and to privacy including, Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

3. Information we collect about you

Information that we collect from or about you includes information you provide when you access our website and/or when you engage with our Services. We may also obtain information about you from trusted third party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. We will only collect information that is adequate, relevant and limited to what is necessary in relation to the purposes identified with this notice.

The table below outlines the categories and types of data we collect along with the source of data. The types of data we collect may change over time. The following table is an indicative list to help you understand the types of data we collect.

4. Purpose for which we hold your information

The main purposes for which we use your personal information are to provide, maintain, improve and update our Services. The following table provides more details on the purposes for which we process your personal data and the legal basis for which we do this.

4.1 Change of use

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the contact details listed in Section 17. If we need to use your personal data for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.

4.2 Consequences of not providing information

Please note that if you decide not to provide us with certain personal information, you may not be able to access certain features of the Sites or use the Services.

5. Sharing your information with third parties

There are various circumstances where we may disclose your personal information to third parties. We will make your information available to third parties with whom we have a relationship to provide services on our behalf. We will only provide to those third parties the information that is necessary for them to perform the services and where there is a lawful basis to do so.

We may share relevant personal information with the following categories of third parties:

Affiliates: with our affiliates and subsidiaries for the purposes described in this Privacy Notice.

Service Providers: with our service providers who assist us in providing the Services, such as billing, payment card processing, customer support, sales and marketing, and data analysis, subject to appropriate contractual prohibitions on their use of your information. We also disclose information to service providers who assist us with detecting and preventing fraud, security threats or other illegal or malicious behavior.

Third-Party Partners and Sponsors: with third party business partners, such as resellers, distributors, and/or referral partners, who are involved in providing content, products or services to our prospects or Customers. We may also engage with third party partners who are working with us to organize or sponsor an event to which you have registered to enable them to contact you about the event or their services (but only where we have a lawful basis to do so, such as your consent where required by applicable law).

Online Advertising Partners: with online advertising providers that tailor online ads to your interests based on information they collect about your online activity over time and across different services (known as targeting online advertising).

Sponsoring Organizations: with the organization that is sponsoring a training or certification program that you take through the Services (e.g., your employer), for example to notify them of your registration and completion of the course.

For legal purposes: when authorized by law or we deem necessary in good faith to comply with legal process; when required to protect and defend the rights or property of Contextual or our Customers, including the security of our Sites, products and services (including the Platform Services); or when necessary to protect the personal safety, property or other rights of the public, Contextual AI, or our Customers.

With your consent: when you instruct us to do so or where you have consented to the disclosure of your information with third parties.

Business Transactions: we may engage in transactions with other companies involving the sale of assets or parts of our business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion of or all of our assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets, including in the course of activities leading up to such transactions.

6. International transfers

We may transfer your personal information to countries other than your country of residence, including where our affiliates, business partners, and service providers are located. These countries may have different data protection laws to the country where you reside.

Wherever we process your personal information, we take appropriate steps to ensure it is protected in accordance with this Privacy Notice and applicable data protection laws. The safeguards we use include implementing the European Commission’s Standard Contractual Clauses or an Adequacy Decision for transfers of personal information from the EEA or Switzerland between us and our business partners and service providers, and equivalent measures for transfers of personal information from the United Kingdom and other global jurisdictions with similar transfer requirements. We also make use of supplementary measures to ensure your information is adequately protected.

7. Data subject rights

As a data subject you will have the following rights in relation to the processing of your personal data under the GDPR and CCPA. You can send us a request in relation to any of the rights outlined below, and we will do our best to adhere to your request as soon as possible and within one month.

7.1 Right to Access

You have the right to know what personal data we hold on you, why we hold the data, and how we are using the data.

When submitting a request, please provide us with as much information as possible to help us identify the information you wish to access (i.e. specific dates).

7.2 Right to Rectification

You have a right to request that the personal data held in relation to you is up to date and accurate.

Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon receipt of your request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.

7.3 Right to Erasure (right to be forgotten)

You have the right to seek the erasure of personal data relating to you in the following circumstances:

• The personal data is no longer required for the purposes for which it was obtained.
• Where the use of the data is only lawful on the basis of consent, you withdraw consent to the processing and no other lawful basis exists.
• The personal data is being used unlawfully.
• You object to the use of your personal data and there are no overriding legitimate grounds for the use of the data.
• Your personal data requires deletion in line with legal requirements.

However, we will be unable to fulfil an erasure request if the personal data is required for any of the activities below:

• Exercising the right of freedom of expression and information.
• Compliance with a legal obligation, such as the performance of a contract or compliance with certain legislation (e.g., if we have a legal requirement to keep your policy data for at least 6 years).
• For the performance of a task carried out in public interest.
• For public health reasons.
• Archiving, research, or statistical purposes in the public interest.
• The establishment, exercise or defense of legal claims.

7.4 Right to restriction of processing

You have the right to restrict the extent for which your personal data is being used by us in circumstances where:

• You believe the personal data is not accurate (a restriction period will exist until we update your information).
• The processing of the personal data is unlawful, but you wish to restrict the use of the data rather than erase it.
• Where the personal data is no longer required by us, but you require the retention of the data for the establishment, exercise, or defense of a legal claim.
• You have a pending objection to the future use of your personal data.

When the use of your data has been restricted, your personal data will only be further used with your consent, for the establishment, exercise or defense of legal claims, for the protection of the rights of other people, or for reasons important to public interest.

7.5 Right to portability

You have the right to the provision of all personal data that you have provided to us in relation to you in a structured, commonly used machine-readable format where:

• The lawfulness of the use of your personal data by us is reliant on the basis of a contract.
• The lawfulness of the use of your personal data by us is reliant on the provision of your consent.
• The data is being utilized by fully automated means.

We will refuse such a request if the data being requested may adversely affect the rights and freedoms of others.

7.6 Right to object

You have the right to object to the further use of your personal data where:

• The lawful basis for the use of your personal data by us is reliant on the basis of our legitimate interests.
• Where personal data is being processed for the purposes of direct marketing or profiling related to direct marketing.

7.7 Right to object to automated processing, including profiling

You have the right not to be subject to a decision based solely on automated processing or profiling, where such decisions would have a legal effect or significant impact on you.

Where we (or one of our third-party processors) use profiling, which produces legal effects for you that significantly affect you, you will have the right to object to such processing.

7.8 Right to withdraw consent

Where we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent and opt-out of the processing of your personal data at any time.

7.9 Right to complain

If you are not satisfied with our use of your personal data or our response to any request by you to exercise your rights, then you have the right to complain to the relevant regulatory authority. You will not be discriminated against for exercising your privacy rights.

8. How to update/amend the personal information you have provided

You are entitled to know whether we hold information about you and, if we do (subject to certain limitations), to have access to that information and have it corrected if it is inaccurate or out of date.

If you want to correct, update or delete your account information, please log on to your Contextual AI account and update your profile.

If you (or an authorized agent acting on your behalf) wish to exercise any of your rights under applicable data protection laws, submit a request online by emailing us at privacy@contextual.ai.

We will respond to requests that we receive in accordance with applicable laws. We may take certain steps to verify your request using information available to us, such as your email address or other information associated with your Contextual AI account, and if needed we may ask you to provide additional information for the purposes of verification. Any information you provide to us for verification purposes will only be used to process and maintain a record of your request.

Depending on the laws applicable to your request, if you are not satisfied with our response to your request, you may have the ability to appeal our response. If an appeal right is applicable to you, we will let you know in our response to you.

9. Marketing

We may periodically send you marketing communications that promote our products and services consistent with your choices. We rely on consent to contact you for marketing purposes.

You may opt out from receiving such communications by following the unsubscribe instructions in the communication you receive. Please note that it may take us some time to process your request in accordance with applicable law, and that we may still send you important service-related communications regarding our products or services, such as communications about your subscription or account, service announcements or security information.

10. Notice of right to opt out of data ‘sales’ and ‘targeted advertising’

Depending on your location, you may have the right to opt out of the “sale” of your personal information or the disclosure of your personal information for purposes of online targeted advertising (our online advertising activities are explained further in our Cookie Notice). We do not ‘sell’ personal information in the traditional sense of exchanging information for monetary payment. However, because the definitions of ‘sale’ and ‘targeted advertising’ under applicable law may include the disclosure of your information to certain types of advertising and marketing partners, we provide the right to opt-out of these activities. To opt out of such disclosures based on cookies and similar tools, please email privacy@contextual.ai. We do not knowingly ‘sell’ or ‘share’ the personal information of individuals under 18 years of age.

11. Notice to authorized users

Our Platform Services are intended to be used by organizations. Where the Platform Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Platform Services and responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the Platform Services. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this Privacy Notice. Please contact your organization or refer to your organization’s policies for more information.

12. Data retention

We retain the personal data described in this Privacy Notice for as long as you use our Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in this Privacy Notice (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.

Your personal data will not be held for longer than is necessary for the purposes for which it was obtained. This means that the period of time for which we store your personal data may depend on the type of personal data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

13. Data security

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and therefore any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorized access. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Third party services

Our Services may contain links to third party websites, applications, services, or social networks (including co-branded websites or products that are maintained by one of our business partners). We may also make available certain features that allow you to sign into our Sites using third party login credentials (such as LinkedIn, Facebook, Twitter and Google+) or access third party services from our Platform Services (such as Github). Any information that you choose to submit to third party services is not covered by this Privacy Notice. We encourage you to read the terms of use and privacy notices of use of such third party services before disclosing your information with them to understand how your information may be collected and used.

15. Children’s data

The Sites and Platform Services are not directed to individuals under 18 years of age and we do not knowingly collect personal information from individuals under 18 years of age. If we learn that we have collected any personal information from an individual under 18 years of age, we will take steps to delete such information. If you are aware that an individual under 18 years of age has submitted information to us, please contact us at privacy@contextual.ai.

16. Changes to this policy

We may make changes to this Privacy Notice from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of the Site or our Services, or your interaction with us following the posting of any changes will mean you consent to those changes.

17. Questions or complaints

Please contact us at privacy@contextual.ai if you have any questions or complaints about our privacy practices or this Privacy Notice. You can also write to us at 150 W Evelyn Ave, Suite 200, Mountain View, California 94041, USA. If you interact with us through or on behalf of your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct any questions or complaints to that organization.