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Last Updated: August 28, 2023
This Privacy Policy is designed to help you understand how Persefoni AI Inc., its brands, affiliates, and subsidiaries (“Persefoni”, “we”, “us”, or “our”) collects, uses, processes, and discloses your personal information, and to help you understand and exercise your privacy rights.
For additional information about the privacy choices you have regarding your personal information, please review the “Your Privacy Choices and Rights” section below. If you are a resident of California, please refer to Section 13, “Supplemental Notice for California Residents” section below for information about the categories of personal information we collect and your rights under California privacy laws.
By using our Services (as defined below), you agree that your personal information will be handled as described in this Privacy Policy. Your use of our Services and any dispute over privacy, is subject to this Privacy Policy and our Terms and Conditions, available here, including their applicable terms governing limitations on damages and the resolution of disputes.
This Privacy Policy applies to personal information processed by Persefoni in the course of our business, as collected from our websites (the “Site”), applications, and our related online and offline offerings (collectively, the “Services”).
An Important Note. This Privacy Policy does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Please ensure that your use of the Services complies with the terms of our contracts with our Customers and our instructions to the Customers, which may include specific guidance not to enter personal information in open text fields where it is not requested or required to operate the Services. Any questions or requests relating to Customer Data should be directed to our customer.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
When you use our Services, we collect the following categories of personal information:
Information You Provide to Us Directly
Account Creation. When you create a user account, we collect your name, title, email address, username, and password. We may also collect your phone number and photo if you choose to enter it.
Communications with Us. When you request information about our Services, sign up for a newsletter, request customer or technical support, or otherwise communicate with us, we may collect personal information from you such as name, email address, phone number, or mailing address.
Customer Service and Support. If you call or otherwise interact with Persefoni’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record audio conferencing between you and our representatives for training and quality assurance purposes.
Interactive Features. Persefoni may offer interactive features such as commenting functionalities, forums, chat services, and social media pages. Persefoni may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.
Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Persefoni and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Online Courses. When you create a user account to access online courses, such as Carbon Accounting Essentials Courses, we collect your name, email address, username, and password.
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with your account and the devices you use.
Technologies are functionality, such as Cookies, Pixel Tags and Web Beacons, that enable small data files to be placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services. We, as well as third parties that may provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, web beacons and other Technologies to automatically collect information through the Services.
Please refer to Persefoni's cookie declaration page for further information on the cookies utilized.
Our uses of such Technologies fall into the following general categories:
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
We may obtain information about you from other sources, including through third-party services and other organizations. For example, if you access or use our Services through a third-party application, such as a social networking service or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services. If you are from a region that requires a legal basis for processing personal information (such as the European Union (EU) or the United Kingdom (UK)), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. In general we rely on the following legal bases for our processing of personal information:
We use your personal information as follows:
To provide the Services or Information Requested.
Our legal basis for the above purposes is that the processing is necessary to deliver our Services to you under the terms of the contract to which we agreed.
Administrative Purposes.
Marketing Our Services.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at privacy@persefoni.com.
De-identified and Aggregated Information Creation and Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses. We may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in de-identified form and not to attempt to re- identify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.
Sharing Content with Friends or Colleagues. Our Services may offer various tools and functionalities to share content on the Services with others. For example, we may allow you to provide information about third parties through our referral services. Our referral services may allow you to forward or share certain content with third parties, such as an email inviting a third party to evaluate or use our Services.
Other Purposes. Persefoni may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information.
Service Providers. We may share any personal information we collect about you with our third party service providers. The types of service providers to whom we entrust personal information generally include service providers for:
Additionally we store your personal data with our third party service providers under the legal basis to provide Services and our legitimate interest to maintain security of the Services provided.
Affiliates. We may share personal information with our affiliated entities. We utilize Persefoni wholly owned subsidiaries in various parts of the world to provide marketing and services, therefore if you provide consent to be contacted, your data will be shared with that wholly owned subsidiary.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services. Data shared with our business partners is conducted under the legal basis of consent to be contacted for the Services and/or to provide Services.
Interest-Based or Personalized Advertising. Through our Services, Persefoni may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising” and is conducted under the legal basis of legitimate interest. These cookies are optional and Customers have the right to disable these cookies via the Services.
Products, APIs, and Software Development Kits. We may use third party products, APIs, and software development kits (“SDKs”) as part of the functionality of our Services. Products, APIs, and SDKs may allow third parties including advertising partners to collect your personal information to provide content that is more relevant to you. Data shared with products, APIs, and SDKs is conducted under the legal basis of performing our contract with you for the Services. For more information about our use of products, APIs and SDKs, please contact us at privacy@persefoni.com.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
General. You may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us at privacy@persefoni.com.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email or email us at privacy@persefoni.com with the subject line “Opt-Out.” Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
Technologies (Cookies) and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at thenai.org/opt-out, youronlinechoices.eu and aboutads.info/choices.
Please note you must separately opt out in each browser and on each device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that except as otherwise described in this Privacy Policy, we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us at privacy@persefoni.com.
We will process such requests in accordance with applicable laws. To protect your privacy, Persefoni will take steps to verify your identity before fulfilling your request.
We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from, or less protective than, the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we may use the EU Standard Contractual Clauses and/or the UK International Data Transfer Addendum to support such transfer.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
If you have any questions about our privacy practices or this Privacy Policy, please contact us at:
Persefoni AI Inc.
2415 W Broadway Rd
#41022
Mesa, AZ 85274-3042
privacy@persefoni.com
Our EU Representative:
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:
Instant EU GDPR Representative Ltd.
Adam Brogden
+35315549700
Office 2, 12A Lower Main Street
Lucan Co. Dublin, K78 X5P8
Ireland
contact@gdprlocal.com
Our UK Representative:
Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.
Adam Brogden
+44 1772 217800
1st Floor Front Suite
27-29 North Street, Brighton
England
contact@gdprlocal.com
This Supplemental Notice for California Residents provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act (“CCPA”). To the extent you are a California resident, and we collect “personal information” subject to the CCPA, the following applies. This section does not address or apply to our handling of publicly available information or personal information that is otherwise exempt from the CCPA.
The following list identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Depending on how you use the Services, we may collect and disclose the following categories of personal information:
Identifiers, such as full name, email address, phone number, username, alias, IP address, unique personal identifier, online identifier, city, and state, or other similar identifiers. The third parties to whom we may disclose this information for a business or commercial purpose include:
Customer records, such as name, user ID or username, account name, and contact information. The third parties to whom we may disclose this information for a business or commercial purpose include:
Commercial information, such as records of Services purchased, obtained, or considered, or other purchasing or use histories or tendencies. The third parties to whom we may disclose this information for a business or commercial purpose include:
Internet or other electronic network activity, which includes, but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our Site and the Services, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services. The third parties to whom we may disclose this information for a business or commercial purpose include:
Location data, such as general location information about a particular individual or device. The third parties to whom we may disclose this information for a business or commercial purpose include:
Audio, electronic, visual, or similar information, which includes, but is not limited to, information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, and user profile images. The third parties to whom we may disclose this information for a business or commercial purpose include:
Professional or employment-related information, such as job title, company name, business email, business phone number, business location, and other similar professional-related information. The third parties to whom we may disclose this information for a business or commercial purpose include:
Protected classifications, which we may collect in limited circumstances, such as gender, age, and date of birth. The third parties to whom we may disclose this information for a business or commercial purpose include:
Inferences, such as inferences drawn from other personal information about a consumer reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes. The third parties to whom we may disclose this information for a business or commercial purpose include:
Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; affiliates and subsidiaries; business partners; vendors and service providers; Internet service providers; operating systems and platforms; social media platforms; and marketing, advertising, and data analytics providers.
Purposes of Collection, Use, and Disclosure. As described above in Section 3. How We Use Your Information and Section 4. Disclosures of Personal Information, in general, we may collect, use, disclose, and otherwise process personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
Sensitive Personal Information. We do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA.
Retention. We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. In some cases, rather than delete your personal information, we may de-identify or aggregate it and use it in compliance with the CCPA.
Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, Internet and network activity information, and commercial information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising and to improve and measure our ad campaigns. We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).
Privacy Rights for California Residents. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:
Submitting Privacy Requests. California residents may exercise their CCPA privacy rights as set forth below:
In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well. More information about GPC is available at: https://globalprivacycontrol.org/.
If you have any questions about our privacy practices or this Privacy Policy, please contact us as noted above in Section 12. Contact Us.
