Effective Date: March 17, 2020
This Policy contains the following sections:
Please read this Policy carefully to understand how we handle your information. If you do not agree with this Policy, please do not use the Services. If you have questions about this Policy, please contact us via email at firstname.lastname@example.org.
Information We Collect
We obtain information about you through the means discussed below when we provide the Services.
Information You Provide to Us. We collect various information you directly provide to us when you use the Services, for example, when you:
Register to use the Services, we will collect information such as your name, email address, log-in credentials, and pronouns.
Interact with the Services, such as by communicating with Remy, our artificial intelligence chat bot, via text or audio chat, we will collect the information that you voluntarily provide through these communications, which may include information about your demographics, interests, mood, feelings, health, hobbies, and information you discuss about other individuals, as well as the text and audio from your conversation. With your consent, we may collect a voice print from your audio communications to better identify you in future chat communications. Sharing information with Remy is always voluntary, so please don’t share any sensitive information that you do not want shared through these communications.
Make a purchase through the Services, we, or third-party payment processors, will collect information such as your shipping address, credit or debit number, verification number, and expiration date.
Contact us with questions or for customer service, we will collect contact information such as your name, email address, and phone number, and any information you provide in connection with your question.
Participate in a contest, sweepstakes, research study, or email survey, we will collect basic contact information and any other information you provide in connection with these activities.
Choose to integrate the Services with other apps/functionalities on your mobile device (e.g., your photos, calendar, or contacts), we will collect information contained in these other apps/functionalities in accordance with your app and device settings.
Information We Collect Through Automated Means. When you access or use our Services, we may automatically receive and store certain information about you through your device(s). As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies, to assist in this information.
Device Information. We collect technical information associated with the device(s) you use to access our Services, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
Usage Information. We also collect a variety of information to better understand use of our Services. This may include the webpage that you were visiting before accessing our Services, the pages or features of our Services you use,, how much time you spend there, date and time of use, and information about your usage preferences.
Information From Third-Party Connections and Platforms. If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or Google), you may allow us to have access to and store certain information from such third-party service, depending on your settings on that service. If you do not wish to have this information shared, you may be able to adjust your account settings on those Services, or choose not to use these connections to access our Services. Please see the privacy policies and terms for these third parties for more information.
Information From Publicly Available Sources and Others. We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and others that we may use to supplement the information that we collect directly from you in order to derive your possible interests and provide more relevant experiences with us.
Location Information. When you use the Services, we may collect general location information (such as your city/state inferred from your IP address). If you permit the Services to access more precise location information (e.g., your GPS coordinates) through the permission settings on your mobile operating system or browser, we may collect the precise location of your device when the Inwords app is running in the foreground or the background of your device. This information may be used to deliver tailored content through the Services Your mobile device may allow you to adjust your settings so that location information is not available to any mobile web Service or application, including the Inwords app.
How We Use Your Information
We, or our service providers, use your information for various business and operational purposes depending on the types of information that we have collected from and about you and the specific Services you use. The main use of your information is to leverage cutting-edge artificial intelligence and machine learning techniques to analyze and better understand how you interact with Remy to provide an enhanced, and personalized experience, to you. The more conversations you have with Remy, and the more information you share, the more personalized your conversations with Remy will become. We also use your information in order to:
provide the information and services you request
provide you with effective customer service
contact you with operational information and notices related to your use of the Services
contact you with special offers and other promotional content we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us)
invite you to participate in surveys and provide feedback to us
analyze use of the Services and improve the content, functionality and usability of the Services
secure the Services and prevent fraud
understand and resolve app crashes and other issues being reported
comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others
establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others
for any other purpose with your consent.
Combined Information: For the purposes discussed in this Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.
Aggregate/De-Identified Information: We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.
Cookies and Similar Technologies
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future.
A web server log is a file where website activity is stored.
An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services.
A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookie
As we adopt additional technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
Online Analytics and Interest-Based Advertising
Analytics. We may use third-party analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Interest-Based Advertising. When you use the Services, Symbiose may display advertising to you about products, services, and related features that we think may be of interest to you to improve and personalize your use of the Services. We may personalize ads based various factors such as the features you are using, demographic and geographic data, and other information that we collect about you. This advertising may be based on your current activity or your activity over time and may be tailored to your interests.
In order to provide this interest-based advertising, we may use third party service providers who, on our behalf, may place cookies or other tracking technologies, such as cookies and SDKs on your computer browser, mobile phone applications, or other device to collect information about your use of the Services in order to provide interest-based advertising to you both on the Services and on other websites..
If you are interested in more information about interest-based advertising and how you can generally control cookies other tracking technologies from being put on your computer to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link, or TrustArc’s Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page.
Facebook also offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. For more information, you will need to log in to Facebook via the Sign In link and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app).
Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising even if you opt-out as described above. In that case, the advertising will just not be based on your interests.
Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals. Learn more about Do Not Track.
How We Share Your Information
Symbiose will share your information in the following ways:
Service Providers. We share information collected through the Services with select third parties who use the information to provide services on our behalf, such as Services operation, surveys, web hosting, marketing and sales, billing and payment processing, analytics and online advertising, security, fraud prevention, and legal services.
Other Users of this Service. To the extent that you post content in publicly-accessible parts of the Services, or choose to make certain of your content viewable by other users, such content can be read, collected, and used by others with permission to view it.
Related Entities. We may share your information with our affiliates (entities that control or are under the control of Symbiose) for business purposes. We will require these entities to comply with the terms of this Policy with regard to their use of your information.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, user information would likely be one of the transferred assets. If such transfer is subject to notifications or restrictions under applicable laws, we will comply with such requirements.
Your Consent. We may also share or disclose your information with your consent or at your direction.
How We Protect Your Information
We take a variety of physical, technical, administrative, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no online activity is ever fully secure or error-free. While we strive to protect your information against unauthorized use or disclosure, we cannot guarantee that your information is absolutely secure. Please keep this in mind when disclosing any information to Symbiose.
When you sign up for an account, you may be required to establish a username and password. If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Symbiose Contact Information” section below.
Retention of Information
We retain your information for as long as your account is active or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect Symbiose and our users, and enforce our agreements.
Third Party Links and Features
The Services may contain links to third-party services (e.g., social media sites like Facebook and Twitter) and third-party plug-ins (e.g., the Facebook “like” button and the Twitter “follow” button). These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. Symbiose does not control these third parties and is not responsible for the content or data practices of such third-party websites or services. Any information you provide to third parties on their websites or services is covered under their privacy and data collection policies, and is not covered by this Policy. We urge you to review the privacy and security policies of these third parties.
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Your Rights and Choices
We respect your right to make choices about the ways we collect, use, and disclose your information.
Your Legal Rights: Depending on the laws of your local jurisdiction, you may have certain rights and choices with respect to your information. For example, under local laws, you may be able to ask us to:
Provide access to certain information we hold about you
Update or correct your information
Delete certain information
Restrict the use of your information
We will consider all requests and provide our response within the time period stated 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 will let you know where this is the case or if certain rights don’t apply in your country or state of residence. We may request you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law.
Marketing Communications: You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, and promotions that might appeal to your interests by contacting us using the information below. In commercial 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 operational emails, such as those reflecting our relationship or transactions with you.
Information for California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
CCPA Categories of California Personal Information We Collect. Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the CCPA “categories” of personal information we collect. The categories we collect are: identifiers (such as name, address, email address); internet or other network or device activity (such as browsing history or IP address); general and precise geolocation information; audio, electronic, and visual information (such as voice data from a chat); biometric information (such as a voice print to recognition your voice in a group conversation); and other information that identifies or can be reasonably associated with you. We also may collect certain categories of information that you choose to disclose as part of your use of the Services, including via participation in a text or audio chat with Remy or the creation of a note in the Inwords app. The categories of information collected through your chats with Remy will depend on what information you choose to share
How We Use and Disclose These Categories of Personal Information. We and our service providers may use and disclose (and in the past 12 months have used and disclosed) all of the personal information we collect for the business purposes described in this Policy, and in accordance with our disclosures in the “How We Share Your Information” section above.
Your California Privacy Rights. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain personal information we hold about you.
Delete certain personal information we have about you.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and other account information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at email@example.com.
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties, as such term is defined in the CCPA. We do not engage in such activity.
California “Shine the Light” Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Information for Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing firstname.lastname@example.org. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Information for International Users
Symbiose is based in the United States and, regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the United States.
We reserve the right to update or modify this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Policy accessible through use of the Services, 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 “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided notice in accordance with legal requirements. Your use of this Service following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy.
Symbiose Contact Information
If you wish to contact us or have any questions or concerns about this Policy, please contact us by email at email@example.com