Privacy Policy

The following Privacy Notice describes the practices of Idealab.AI(“Company”, “we”, “us” or “our”) with respect to information that is collected from or about you by the Company when you use our websites and the products or services offered by us (collectively, the “Services”). By accessing and using the Services, you acknowledge that you have read and agree to the privacy practices as described in this Privacy Notice. If you do not agree, please do not access or use the Services. We will review and update this Privacy Notice as our products and services evolve, and we will keep you informed of the changes here.

Some key terms

While there are different definitions of personal information used by different jurisdictions, the term personal information as used herein means information about a specific individual, such as full name, address, mobile number, or email address, which is used to identify a particular individual.

The term non-personal information means information that does not personally identify you and cannot presently be used to identify you, including de-identified information.

The term information may include both personal information and non-personal information.

User means all visitors and users of the Services.

This Privacy Notice applies to those who visit, access or use the Services. Collectively throughout this Notice, we may use the term “You” to reference Users.

Links to Other Websites, Apps and Services

Our websites and other Services may contain links to other third-party websites, apps and services of interest. We have no control over such third-party services. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites and services, and they are not governed by this privacy statement. You should review the privacy statement(s) applicable to the third-party sites and services.

Collection of Your Information

We collect or receive information about your interactions with us. Depending on how you use our Services, this information may include, without limitation:

• registration-related information (such as name, addresses, email addresses, telephone numbers, occupation and information imported from social log in permissions granted to us);
• any voluntary information you provide such as your LinkedIn address and profile information and your interests associated with your searches on the Services;
• any voluntary information you upload such as your resume and other materials;
• information about the Services that you use, how often you use them, and your responses to the offerings and advertisements presented or made available by us;
• information about the searches you perform on our websites or in our other Services and how you use the results of those searches;
• transaction-related information (such as credit card or other preferred means of payment, billing information, credit card number, expiration date, billing address and/or a history of purchases through our Services);
• customer service information about you as a user of our Services;
• information about any devices, connections and methods used to access and interact with us;
• other information specifically related to your use of Services, including information that you publicly post using tools made available by us;
• information based on your usage of our Services (“Usage Data”), which may be collected automatically by us or the services (or third-party services within our Services), which can include the IP addresses or domain names of the computers utilized by the users who use the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (such as successful outcome and error), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (such as the time spent on each page within the Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, other parameters about the device operating system and/or the user's IT environment, and data, conversion rates, marketing and conversion data and statistics, reports, analytics data, reviews and surveys. Usage Data may sometimes be essentially anonymous when collected, but could be used indirectly to identify a person;
• we collect personal information from all communications with Service end users including, without limitation, text messages, faxes, telephone calls, and regular "snail mail," as well as from third-party outside sources including database vendors.

In some countries, including in the European Economic Area, some of this information may be considered “personal data” under applicable data protection laws.

Information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match your information.

We may also receive or collect certain technical information when you use our Services. This may include your browser or operating system, your manner of connecting to the Internet and the name of your Internet service provider or wireless carrier; your Internet protocol (IP) address; information about referring websites or services (websites or services you used immediately prior to using our websites or other Services; exiting websites or services (immediately after using our website or other Services); and data relating to malfunctions or problems occurring when you use our Services. Additionally, we may collect information about other software on your device for the limited purpose of protecting your security or improving your online experience.

How Information may be used

Information may be used for purposes that include, without limitation:

• to operate and improve the Services available through us;
• to personalize the content and advertisements provided to you (including presenting offers to you on behalf of business partners and advertisers);
• to fulfill your requests for tools, software, functionality, features and other products, and services;
• to communicate with you and respond to your inquiries;
• to conduct research about your use of our products; and
• to help offer you other products, features or services that may be of interest;
• to provide customer support and technical assistance;
• for administration of your account;
• to create user profiles;
• to create de-identified analytical information.

Cookies

We may use cookies and similar technologies along with information we collect to enhance and personalize your experience, provide you with your search history, and gather information that helps us optimize our Services. You can choose to accept or decline some cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, it is important to remember that some of our Services may not function properly if your cookies are disabled.

Third Party Vendors or Third Party Services (as defined below) may use their own cookies and/or other third-party cookies together (subject to their own privacy policies) to (a) inform, optimize, and serve ads across the web based on your past visits to our Services and others and (b) report to us how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.  If and to the extent from time to time we use a Google brand for ad serving, analytics, remarketing, retargeting, you can set certain preferences and opt-outs using Google Ads Settings, and Google Analytics’ currently available opt-outs, found here https://www.google.com/ads/preferences/ and here https://adssettings.google.com/.

Push Notifications

We may occasionally send you push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit such communication and notifications through the settings on your device and stop receiving such communications and notifications.

Sharing or Selling Information

We do not sell or disclose personal information (such as name, address, telephone number and credit card information) to data brokers or unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services that you have requested, our authorized advertising, and as described in this Privacy Policy.

Information about you as a user of our Services, (including communications with Us) may be accessed and disclosed under the following circumstances: in response to lawful governmental requests or legal process (for example, a court order, search warrant or subpoena), in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person, when necessary to protect either our rights or our property or for us to render the service you have requested.

In the case where our Services let you share information with others, and your share information publicly, others besides us have access to it, and it may be indexable by search engines, or copied, forwarded, saved or archived by others.

Our Services may include features or functionalities provided by third parties (“Third Party Vendors”) or may integrate or interact with third-party products and services (including, without limitation, via APIs, plug ins, links, frames, embedding, or other interactions) (“Third Party Services”). Such third party may have access to your data, subject to its policies. In the process of providing such functionalities within our Services, your browser or other tools or technology may send certain information to the Third-Party Provider and/or Third-Party Services. The use of these Third-Party Services’ features or functionalities is subject to their own privacy policies.

Business partners or other third parties may receive data about groups of our users, except as otherwise permitted herein, do not receive information that personally identifies you. We may use agents and contractors in order to help operate our Services. Their use of information is limited to these purposes, except as otherwise permitted herein.

We may share your personal information with professional advisors such as auditors, law firms, or accounting firms working on our behalf.

We may disclose information if required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users or business partners. We may disclose information to the extent required by law, or if we have a good-faith belief that we need to disclose it to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose information to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of any information. In the event that ownership is to change as a result of a merger, acquisition, or transfer to another company, your information may be transferred. If such a transfer results in a material change in the use of your information, you will be provided with notice (which may be via updates to this page) about your ability to decline to permit such a transfer.

Any Personal information which we may collect via the Services may be stored and processed in our servers located in the United States or in any other country in which we, or our affiliates, subsidiaries or agents, maintain facilities. You consent to any such transfer of personal information outside your country of residence to any such location.

General Disclosure Policy. We reserve the right to disclose your personal information as described below. We may share aggregated, non personal information, publicly and with our partners like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.

We reserve the right to disclose Usage Data without restriction.

Affiliated Entities. We reserve the right to provide your personal information and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we control or that control us. Service Providers. We reserve the right to provide access to your personal information and Usage Data to our trusted service providers that assist us with the operation and maintenance of our sites and services. For example, we may contract with third parties to process payments, host our servers, provide security and provide production, fulfillment, optimization, analytics and reporting services. We will use commercially reasonable efforts to ensure that our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted. Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your personal information and Usage Data. Legal Process, Enforcement and Security Notice. We reserve the right to disclose your personal information and Usage Data if we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity and (iii) to investigate, respond to, or enforce violations of our rights or the security of our sites and services. When We Participate in a Joint Activities with Marketing Partners. We may participate with another company or individual for purposes of jointly promoting our products, services, or their products and services, promotions. We reserve the right to disclose your personal information to them for purposes of (i) compensation, transaction processing, fulfillment and support, and (ii) for purposes of offering you other product and services, promotions and contests.

We may also use your data in other ways described herein, and as otherwise permitted or required by applicable laws.

Display of Advertising

We may use ad networks to customize and display advertising about our Services. We may share certain information about you as a user (such as age, zip code or other information we have collected or received) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. We may from time to time work with other companies for certain services such as analytics or advertising, and you may be subject to their privacy policies as well, though you may opt out through them directly or contact us with questions.

Other Legal Basis

In accordance with applicable data protection laws, without limiting the above, we may process your personal information where we have a lawful basis for doing so, including:

• Contract Necessity -- Where it is necessary to provide the Services to you under the performance of the contract we have with you or your organization that is our customer;
• Legal Necessity -- Where we are required to do so in accordance with legal or regulatory obligations;
• Consent -- Where you have given your consent; and,
• Legitimate Interests - Where it is in our (or a third party’s) legitimate interests to process your personal information and these interests do not prejudice your own interests or fundamental rights and freedoms.

Your Choices about Your Information

You may choose to restrict the collection or use of your personal information in the following ways:

• Whenever you are asked to fill in a form on our website or our other Services, consider what information to include and exclude; in addition, sometimes there may be a box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• We may provide you with access to your registration information and the ability to edit this information in your account settings dashboard and profile pages.  Please be aware that even after you delete or update information within our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Similarly, if and to the extent any information is indexable by search engines (including, without limitation, public profile information), it may not be updated by such search engines when we update it, and old versions may be archived by them or by third parties outside our control.
• Some of our Services may provide you with additional information and choices about your privacy, which you should review.
• If you have previously agreed to our using your personal information for direct marketing purposes, you may change your mind at any time by writing to us using the contact information below.

Consumer Privacy Choices

You may have certain rights to access, review, update, or delete the personal information we hold about you under applicable law.  Consumer privacy rights vary depending on where you reside, but we will make reasonable efforts to honor your request even if you are a resident of a country or state that does not require us to do so under applicable law. Consumer privacy choices may include:

• Right to Know: you may have the right to request information about the personal information we have collected about you and for what purpose.
• Right to Access: you may have the right to request information about how we process personal information and to obtain a copy of that personal information.
• Right to Portability: you may have the right to receive your personal information, in a commonly used and machine-readable format.
• Right to Deletion: you may have the right to request the deletion of your personal information that we have collected from you.
• Right to Be Free from Discrimination: We will not discriminate against you for exercising your consumer privacy rights.
• Right to Opt-out of Sharing: you may have the right to opt out of our sharing personal information with third parties for some purposes, including sharing that may be defined as a sale under certain laws.
• Right to Make Choices About Email Marketing: you may have the right to make choices about receiving email marketing.

Submitting Access or Deletion Requests

If you would like to access a copy of, or request deletion of the personal information we may maintain about you, or to exercise any other privacy right as set out above:

1. Send a written request via email to privacy@idealab.ai
2. Write and mail to us at:

Idealab.AI, Inc.

130 W. Union Street

Pasadena, CA 91103

Attn: Privacy

We require the following information to authenticate you no matter which method you use to make your request:

1. First name
2. Last name
3. Email address
4. Specify: request to access or delete
5. If you are an agent acting on behalf of someone else, in addition to the information noted above, we will require a copy of your Power of Attorney authorizing you to act on another’s behalf.

If you would like to discontinue receiving marketing emails from us, you may also make the request by email or mail as specified above.

For security purposes, we will seek to verify your identity before we can give you access to any personal data (in order to make sure we send information only to the identified person). For instance, you may need to authenticate your account information. Once we have verified your identity, we will respond to your request as appropriate.

Your request does not guarantee complete access or comprehensive removal as the law may not permit or require removal in certain circumstances. Please also keep in mind that we may not be able to honor all requests but in such case will respond and advise you so

YOUR CALIFORNIA PRIVACY RIGHTS – California Consumer Privacy Act

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses.  First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:

1. What specific pieces of information a business has about the consumer;
2. Categories of personal information it has collected about the consumer;
3. Categories of sources from which the personal information is collected;
4. Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
5. Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business’ systems and records.

Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

We do not “sell” or “share” personal information (such as name, address, telephone number and credit card information) for valuable consideration to unaffiliated third parties. We may share information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

To make a “request to know” or request to delete Personal information, send us an e-mail at privacy@idealab.ai (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA.

If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information.

Pursuant to California’s “Shine The Light law” (California Civil Code § 1798.83), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at privacy@idealab.ai and indicate in the email subject line, “California Shine The Light Request.”  Please include your mailing address, state of residence and email address with your request.

European Economic Area, United Kingdom and Switzerland

If you are an individual in the European Economic Area (EEA), United Kingdom or Switzerland, we collect and process Personal Data (as that term is used) about you only where we have legal basis for doing so under applicable data protection laws in these countries (the General Data Protection Regulation in the EEA; the UK GDPR in the United Kingdom and the Federal Act on Data Protection in Switzerland). Our legal basis depends on the manner in which you access and use the Site and Services. This means we collect and use Personal Data only where:

• We need it to provide you with access to and use of the Site and Services, including comply with our contracts, to operate the websites and Services, provide customer support and personalized features and to protect the safety and security of the Site and Services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our Sites and products and services or to protect our legal rights and interests;
• You give us consent to do so for a specific purpose; or
• We need to process Personal Data to comply with a legal obligation.

We are the controller of Personal Data that you provide for us to provide the Site and Services for your use. You are the controller of any Personal Data that is entered during and as part of your use of the Sites and Services, and we are the processor of that Data on your behalf. We will process Personal Data according to your instructions, which you give us in the process of visiting and using the Site and Services.

You have the right to exercise certain specific choices with respect to your Personal Data:

• Ask how we use your Personal Data: To access your Personal Data and receive copies of your Personal Data.
• Withdraw any prior express consent that you have provided for the processing of your Personal Data at any time without penalty.
• Access your Personal Data and have it corrected or amended if it is inaccurate or incomplete.
• Obtain a transferable copy of some of your Personal Data that can be transferred to another provider when the Personal Data was processed based on your consent.
• If you believe your Personal Data that we retain is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you also have the right to request that we restrict the processing of your Data pending our investigation and/or verification of your claim.
• Request that your Personal Data be deleted or restricted under certain circumstances. For example, if we are processing your Personal Data on the basis of your consent and has no other legal basis to use such, you may request your Personal Data be deleted when you withdraw your consent.

Note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

If you are not satisfied with our response, or believe we are processing your Personal Data in violation of the law, you can submit a complaint with your relevant supervisory authority:

• EEA: (https://ec.europa.eu/newsroom/article29/items/612080)
• UK (www.ico.org.uk)
• Switzerland (https://www.edoeb.admin.ch/)

You can exercise these rights by contacting us email us at: privacy@idealab.ai with proof of your EEA, UK or Swiss residency status. We will strive to respond within one month or will advise you if additional time (up to another two months) is needed.

DATA STORAGE AND RETENTION (International Transfers)

Personal information may be stored on servers in the United States and may also be stored or processed in other countries by our service providers, if and to the extent compliant with law.  You understand and agree that We may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States.  Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have, or as otherwise permitted herein and by law.

If you are a resident of the EEA: Your personal information may be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective.

DO NOT TRACK DISCLOSURES (EEA and California)

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings.  Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers, see above. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising.  Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Security

We have established safeguards to help prevent unauthorized access to or misuse of your information but cannot guarantee that your information will never be disclosed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties that violate applicable law or our and our affiliated providers' policies). To protect your privacy and security, we may use passwords or other technologies to register or authenticate you and enable you to take advantage of our Services, and before granting access or making corrections to your information.

Children

Our Services is not directed towards children under 13 years of age, and we do not knowingly collect any personal information from children under age 13 (or up to age 16 in certain jurisdictions) through the Services. The Services do not fall within the Children’s Online Privacy Protection Act (“COPPA”) and is not monitored as doing so. If we learn that we have collected personal information from a child without verified parental consent, we will take steps to delete that information. Parents or guardians who believe we may have collected such information may contact us at the address listed in the contact information” section below.

How to Contact Us

If you have any questions or concerns about this Privacy Policy or its implementation, you may contact us at privacy@idealab.ai. If you believe your information is wrong, we strive to give you ways to update it quickly or to delete it unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.  We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests for information residing on backup tapes).

SMS & Texting

The Services may include a messaging platform or chatbot feature (the “Chat Platform”). This Privacy Policy governs all use of the Services, including information shared by use of the Chat Platform We may limit requests to the Chat Platform or post additional usage policies from time to time. You shall comply with all laws, rules and regulations that are applicable to your use of the Services, the messages or content you post or send through the Services, or the transactions contemplated in this Agreement, including without limitation, the Telephone Consumer Protection Act of 1991 (“TCPA”),). As between you and us, you are solely responsible for compliance with all such laws with respect to your use of the Services, and any messages or content you post or send through the Service.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, and so you should review this Policy periodically. Your continued use of our website and/or any Services after any changes or revisions to this Privacy Policy constitutes your acceptance of any such changes And indicates your agreement with the terms of the revised Privacy Policy.