SNAPFEEDBACK PRIVACY POLICY

Last Updated: July 25, 2023

This Privacy Policy describes how SnapFeedback (“SnapFeedback,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our products and services, including our software client, mobile applications, chatbot, and websites (collectively, our “Services”), or otherwise interact with us, such as through our customer support channels or on social media pages. This Privacy Policy does not apply to products and services that link to a different privacy policy.

We may change this Privacy Policy from time to time. We will notify you by revising the date at the top of this policy if we make any changes. If we make significant changes to this Privacy Policy, we will provide you with additional notice (such as by adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

For California residents, please see the “Your California Privacy Rights” section.

For those located in the European Economic Area (EEA), the United Kingdom, or Switzerland, please also see the “Additional Disclosures for Individuals in Europe” section.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Transfer of Information to the United Kingdom and Other Countries

Your Choices

Data Retention

Additional Disclosures for Individuals in Europe

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information provided directly to us. For example, when you create an account, participate in a meeting, use another product or service that integrates our Services, communicate through our text chat feature, use our calendar integration or email invitation feature, provide feedback, make a purchase, communicate with us via third-party platforms such as LinkedIn, Twitter, Facebook, and Instagram, request customer support, explicitly opt into our collection of specific data from you, or otherwise communicate with us. The types of personal information we may collect include your name, username, email address, postal address, phone number, account login information for our accounts and accounts on video conferencing platforms, profile photo, your image and/or voice, social media profile ID, user presentations, text chat communications, feedback on our Services, hashed payment card value, and other payment-related information like your billing address, and any other information you choose to provide.

Information We Collect Automatically During Interactions with Us

When you access or use our Services or otherwise interact with us, we automatically collect certain information, including:

Activity Information: We collect information about your activity on our Services, such as visual and audio files that include users’ video input and output and users’ audio input and output.

Meeting Information: Certain features and integrations of our Services will collect meeting details, including the names and email addresses of invitees and participants, the meeting subject and description, meeting location, and any included meeting access details, like the meeting ID. We notify users in the video conference that the meeting is being measured and data is being collected, and we provide details on why, along with an opt-out option. We provide notice giving meeting attendees an opportunity to opt out of the collection of meeting information.

Transactional Information: When you purchase our Services, we collect information about the transaction, such as Service details, purchase price, and the date of the transaction.

Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and hashed email address, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services. If you download any of our mobile apps, we may access information you have stored on your mobile device operating system. For example, with your permission, we may access photos or videos from your mobile device or calendar information from your mobile device’s calendar.

Approximate Location Information: We collect your approximate location information from calendar invitations as well as from your IP address, as described below.

Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the “Your Choices” section below.

Information We Collect from Other Sources

We also obtain information about you from other sources. For example, we may collect personal information from the video conferencing platforms you use, from third-party data brokers who provide us with audio and visual data sets, or from other users, such as when they refer our Services to you. We may also collect personal information from third parties who use our Services to provide their own products and services or that integrate our Services into their products and services, such as those that integrate our Services into the social media filters they offer.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. Examples of information we may derive or infer include the following:

– We use audio and visual information to score users’ affect and behavior during meetings and to produce analytics, like users’ individual talk times.

– We also use audio and visual information, as well as other information like language, to infer certain demographic characteristics about users, which we use to improve our models and increase the accuracy of their output. We also infer users’ role during a meeting, such as the client or team manager.

– We use users’ names and email addresses to identify them during meetings and to infer company affiliation, which enables us to compile metrics on each company’s participation during a meeting.

– We use meeting scheduling information to infer characteristics of a scheduled meeting, such as identifying its type or purpose; and

– We use IP addresses to infer users’ approximate location.

USE OF INFORMATION

We use the information we collect to analyze users’ participation during meetings, including analyzing and scoring user sentiment and engagement. We also use the information we collect to:

– Recoginising and analyze trends, usage, and activities in connection with our Services and generate reports with our analysis, including real-time reports and alerts;

– Make inferences and derive information about users and their organizations, including for purposes of compiling metrics about an organization’s or user’s participation in a meeting, as described above in Information We Derive;

– Provide, maintain, and improve our Services, including maintaining user accounts with us and using information to train and improve our models within our Services;

– Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;

– Respond to your comments and questions and provide customer service;

– Communicate with you about products, services, and events offered by SnapFeedback and others and provide news and information that we think will interest you (see the “Your Choices” section below for information about how to opt out of these communications at any time);

– Personalize the advertisements you see on third-party platforms and websites (for more information, see the “Advertising and Analytics” section below);

– Personalize your experience with us, including by tracking your preferences on our Services;

– Send you technical notices, security alerts, and support and administrative messages;

– Debug to identify and repair errors in our Services;

– Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of SnapFeedback and others;

– Comply with our legal and financial obligations; and

– Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share information we collect about you in the following circumstances or as otherwise described in this policy:

– We share information with other users, including sharing real-time reporting and analytics with other meeting participants, as well as additional reporting after the meeting.

– We share information with vendors, service providers, and consultants that access information to perform work for us, such as companies that assist us with web hosting, data storage, data analytics, payment processing, fraud prevention, customer service, and marketing and advertising. We may also allow users within an organization to access user data.

– If you provide a review, testimonial, or feedback about our Services, or post content in another public area of our Services, we may share this information publicly.

– We may disclose information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

– We may share information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of SnapFeedback, our users, the public, or others.

– We share information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

– We may share information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

– We share personal information with your consent or at your direction.

– We also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by SnapFeedback and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. For individuals in Europe, visit http://www.youronlinechoices.eu/. You may also change your settings using the consent management tool on our Services. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

DO NOT SELL MY PERSONAL INFORMATION

SnapFeedback does not sell your personal information for money. However, like many other companies, we do use third-party cookies and related technologies to provide you with ads targeted to your interests, and this may be deemed a “sale” under applicable laws. You have the right to opt-out of sharing your information for targeted advertising. To exercise this right, please click on the “Do Not Sell My Personal Information” link provided in our Services.

TRANSFER OF INFORMATION TO THE UNITED KINGDOM AND OTHER COUNTRIES

SnapFeedback is based in the United Kingdom, and we may process your information in other jurisdictions. Therefore, we, and those that perform work for us, may transfer your information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We provide adequate safeguards for the transfer of information in accordance with applicable law, such as by obtaining your consent, relying on the adequacy decisions from relevant regulatory bodies, or executing Standard Contractual Clauses. You may contact us at contact@snapfeedback.co to request a copy of the Standard Contractual Clauses we use to facilitate the transfer of information outside the European Economic Area, Switzerland, and the United Kingdom.

YOUR CHOICES

In-Meeting Choices

During a meeting, you can remove SnapFeedback from the meeting by typing “opt out” into the meeting chat, and you can remove the SnapFeedback bot from the meeting in the same way you would remove any other meeting participant from the meeting.

Account Information

You may update and correct certain account information at any time by logging into your account or emailing us at contact@snapfeedback.co. If you wish to delete your account, review the “How to Delete My Account” instruction or email us at contact@snapfeedback.co with your account information, but note that we may retain certain information as required by law or for our legitimate business purposes.

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. You may also change your cookie settings using the consent management tool on our Services. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

COMMUNICATIONS PREFERENCES

You may opt-out of receiving promotional emails from SnapFeedback by following the instructions in those communications. If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

DATA RETENTION

We store information we collect for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. We store your audio and video information, including information derived therefrom, in accordance with our internal policies, but in no case for longer than 2 years. For paid accounts, we will store your data until you (i) stop paying, or (ii) request that we delete some or all of your data.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data. For details on your rights and how to exercise them, please see the “Additional Disclosures for Individuals in Europe” section above.

If you have any questions about this Privacy Policy, please contact us at contact@snapfeedback.co.