Privacy PolicyRETUNE AI Inc., together with its affiliates ("Re:tune", "we", "our" or "us"), provides certain technology services (collectively, the "Services"). This Privacy Policy ("Policy") describes how we collect, use, disclose and protect information from and about you through the Services, our website https://retune.so/, any other website or mobile application that links to this Policy (the "Site"), and any other interactions (e.g., customer service and other communications) that you may have with Re:tune.PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES.Scope of this PolicyFor purposes of this Policy:
- An "Authorized User" means an individual who accesses the Services as, or on behalf of, a Customer, including Customer personnel.
- A "Customer" means an entity that has contracted with Re:tune (such as through our Terms of Services) to access our Services.
- A "Customer End User" means an individual whose information Re:tune receives from Customer, or otherwise processes on Customer's behalf, in connection with the Services provided by Re:tune to Customer.
- A "Site Visitor" means an individual who visits our Site outside of the context of our Customers' use of the Services.
This Policy applies to our handling of information about Site Visitors, prospective Customers, and Customers and Authorized Users (in relation to their procurement of the Services and management of their relationship with Re:tune). We refer collectively to these categories of individuals as "you" throughout this Policy.However, this Policy does not cover information about Customer End Users that Re:tune receives from Customer, or otherwise processes on Customer's behalf, in connection with the Services provided by Re:tune to Customer pursuant to the Re:tune Terms of Service.If you are a Customer End User and you have questions about how your information is collected and processed through the Services, please contact the organization (Re:tune Customer) who has provided your information to us for more information.The Information We CollectWe collect, store, and use certain information from or about you for the purposes described below:Information You Provide To UsWe collect a variety of information that you provide directly to us. For example, we collect information from you when you:
- Sign up for and use the Services
- Communicate with us (for example, when you communicate with our customer service teams or submit requests or questions to us via online forms, email, phone, chat, message boards, or otherwise)
- Interact with us by phone, email or message boards in our sales and marketing efforts
- Attend our conferences or events or interact with us at other conferences or events
The types of data we may collect directly from you include:
- First and last name
- Business contact information (email address, phone number, postal address)
- Personal contact information (email address, phone number, postal address)
- Username and password associated with the Services
- Your position and role in your company or organization
- Any other information you choose to directly provide to us in connection with your use of the Site or Services
Information We Collect Through Automated MeansWhen you use our Site or Services, we and our service providers (who are third parties that perform services on our behalf) may automatically collect certain information about your device and how you use the Site or Services, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Site or Services, software and hardware attributes (including device IDs), number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site or Services, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).To collect this information, we and our service providers may use "cookies" or similar tools that track, measure, and analyze the behaviors and usage patterns of our users. Cookies are small data files that can be stored on your browser and device so we can recognize you when you return. We use cookies for analytics purposes, to deliver certain features of the Site or Services, to help us understand how users engage with the Site or Services, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Site or Services may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser, or if accessing the Site or Services via a mobile device, refer to the manufacturer's instructions. For more details, please refer to our Cookie Policy.Information We Collect From OthersFrom time to time, we may collect information about you from other sources, including our affiliates, marketing vendors, and third-party databases. We use this information to supplement the information that we collect directly from you and for any of the purposes described in the next section.When you "like" or "follow" us on Facebook, LinkedIn, Twitter or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us.How We Use Your InformationWe use your information for various purposes depending on the types of information we have collected from and about you to:
- Provide and maintain our Site and Services
- Respond to your inquiries and requests for information, and provide you with more effective and efficient customer service
- Engage in analysis and research regarding use of the Site and Services, improve the Site and Services, and develop new products and services
- Measure the effectiveness of our advertising and deliver relevant advertising to you
- To suggest Services that may be of interest to you
- Secure our Site and Services and resolve technical issues being reported
- Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/De-Identified Information: We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and sponsors.Legal Bases For Use Of Your InformationThe legal bases for using your information as set out in this Policy are as follows:
- Where we need to perform the contract we are about to enter into or have entered into with you for the Site or Services
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
- Where we have your consent to process your information in a certain way
Online Analytics And Advertising
1. Analytics.
We may use third-party web analytics services (such as those of Google Analytics) on our Site or Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. If you receive email from us, we may use certain analytics tools to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
2. Third Party Advertisers.
We may partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third party advertisers may use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests.
How We Share And Disclose Your InformationWe will share your information in the following ways:
- Service Providers.
We provide access to or share your information with select third parties who help us deliver or improve our Site and Services or perform services on our behalf, including billing and payment, advertising and marketing, analytics, fraud prevention, research, data storage or processing, security, and consulting and legal services.
- Protection of Re:tune and Others.
By using the Site or Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by applicable law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce any contracts with you; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Re:tune, its agents and affiliates, its users and/or the public.
- Business Transactions.
In accordance with applicable legal obligations, your information may be provided to third parties in connection with a merger or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Re:tune or our assets, or as part of a corporate reorganization or stock sale or other change in corporate control or business change, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
- Aggregate/De-Identified Information.
From time to time, we may share Aggregate/De-identified Information about use of the Site or Services or our user base with partners and others in our discretion, but such information will not identify you personally.
- With Your Consent or at Your Direction.
In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
Retention Of Your InformationWe keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws.Your Rights And Your ChoicesYou have certain rights with respect to your information as further described in this section.Your Legal RightsIf you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the "Contact Information" section below at any time. Your local laws (e.g., if you are a citizen or resident of the European Economic Area or California) may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- update information which is out of date or incorrect
- delete certain information that we are holding about you
- restrict the way that we process and disclose certain of your information
Such laws may also permit you to revoke your consent to the processing of your information for certain purposes. We will consider all requests and provide our response within the time period stated by applicable law and as otherwise required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.If you are a Customer End User and your information has been collected by Re:tune as a result of our Customer's use of the Services pursuant to the Re:tune Terms of Service between Customer and Re:tune, Re:tune collects and processes any information of yours under the directions of the relevant Customer. If these circumstances apply to you and you wish to access, correct, delete or exercise any rights you may have under applicable data protection laws with respect to any information that we have collected about you, please direct your query to the relevant Customer, as this may expedite the completion of your request. We will provide reasonable assistance to our Customers to give effect to data subject rights as appropriate and required by applicable laws.Marketing CommunicationsIf, in accordance with applicable legal requirements, we send you marketing communications regarding our Services or the services of third parties that we believe will be interesting to you, you can ask us to stop sending such communications at any time by contacting us using the information in the "Contact Information" section below. In our marketing email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain transactional emails from us, such as those confirming your requests or providing you with updates regarding our Policy or other terms.Third Party Links And FeaturesOur Services may contain links to third-party websites. If you choose to visit these sites and use their services, please note that we are not responsible for their content or privacy practices. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites, and not this Policy. We urge you to read the privacy policies of these third parties.International UsersYour information is maintained and processed by us and our third-party service providers in the United States and elsewhere. Thus, your information may be maintained, processed, and stored in other jurisdictions that may have different data protection laws than those in your country of residence. In the event that your information is transferred in these ways, please note that we comply with applicable legal requirements governing the transfer of information across borders. By using the Services, you agree to and acknowledge these transfers.How We Protect Your InformationRe:tune takes a variety of technical and organizational security measures to protect the information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to us online.Changes To Our PolicyWe reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, or advances in technology. We will make the revised Policy accessible on the Re:tune website, so you should review the Policy periodically. You can know if the Policy has changed since the last time you reviewed it by checking the "Last Updated" at the end of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.Contact InformationRe:tune welcomes your comments and questions regarding this Policy and the collection and use of your information. If you have questions or concerns, please email us at support@retune.soLast Updated: December 20, 2023