Privacy Policy.

‍What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

‍

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  

• ~When you provide such information directly to us.

• ~~When you use our interactive tools and Services.

• ~~When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

• ~~When you send us an email or otherwise contact us.  

• ~When you use the Services and such information is collected automatically.

• ~~Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).

• ~~If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

• ~~If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
• ~~ When you use our mobile application, we make use of information collected through the device camera through the TrueDepth API made available by Apple,Inc. We only use information that the TrueDepth API collects to generate the 3Dgeometry of the user’s avatar.

• Third Parties

• ~Vendors

• ~~We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

• ~~We may use vendors to obtain information to generate leads and create user profiles.

• ~Advertising Partners

• ~~We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Commercial or Business Purposes for Collecting Personal Data

• ~Providing, Customizing and Improving the Services

• ~~Processing orders or other transactions; billing.

• ~~Providing you with the products, services or information you request, including generating your avatar or digital representation through the use of your biometric information.

• ~~Meeting or fulfilling the reason you provided the information to us.

• ~~Providing support and assistance for the Services.

• ~~Improving the Services, including testing, research, internal analytics and product development.

• ~~Personalizing the Services, website content and communications based on your preferences.

• ~~Doing fraud protection, security and debugging.

• ~Marketing the Services

• ~~Marketing and selling the Services.

• ~~Showing you advertisements, including interest-based or online behavioral advertising.

• ~Corresponding with You

• ~~Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about TrueMeeting or the Services.

• ~~Sending emails and other communications according to your preferences or that display content that we think will interest you.

• ~Meeting Legal Requirements and Enforcing Legal Terms

• ~~Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

• ~~Protecting the rights, property or safety of you, TrueMeeting or another party.

• ~~Enforcing any agreements with you.

• ~~Responding to claims that any posting or other content violates third-party rights.

• ~~Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• ~Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• ~~Hosting, technology and communication providers.

• ~Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• ~~Ad networks.

• ~~Marketing providers.

• ~Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• ~~Companies that track how users found or were referred to the Services.

• ~~Companies that track how users interact with the Services.

• ~Parties You Authorize, Access or Authenticate

• ~~Social media services.

• ~~Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you

Information about Biometric Information We Collect from Our Users

Our Collection and Use of Biometric Information. We may collect biometric information about our users in order to create and operate our users’ avatars, and to train our models. Biometric information is a form of personal data based on an individual’s biometric identifier – such as an iris scan, fingerprint, voiceprint, hand geometry, or facial geometry – that is used to identify an individual. As used in this policy, “Biometric Information” refers to both “biometric information” and “biometric identifiers” as those terms are defined under applicable law. We use Biometric Information to create and operate our users’ avatars and to improve our models and consequently our avatars. We may also use Biometric Information to comply with applicable legal obligations or comply with a request from law enforcement or government entities, unless prohibited by law.  

How We Share Biometric Information. We may share Biometric Information with our hosting and cloud compute service provider to host and process information for us and/or make certain services, features or functionality available to our users on our behalf. Your biometric information may also be cached on the device of participants in your virtual meeting in order to facilitate the Services. We may also share your Biometric Information with third parties where permitted to enforce our terms of use, comply with legal obligations, or cooperate with law enforcement agencies where required by law. Note that we never sell or rent Biometric Information.

Our Retention of Biometric Information. We retain your Biometric Information in accordance with our contractual obligations with our customers, with the specific retention periods determined by our customers. Unless a different retention period is required by our customer by contract, Biometric Information will be retained until the earlier of (i) the initial purpose for collecting or obtaining such Biometric Information has been satisfied or (ii) three years following the user’s last interaction with us. Our hosting and cloud compute provider will only store Biometric Information on our behalf for the retention periods set forth in this section. Such storage by our hosting and cloud compute provider is necessary for us to provide you with the Services.  Our hosting and cloud compute provider will not access or use your Biometric Information for any other purpose. Once the retention periods in this section have expired, Biometric Information will be permanently and irretrievably deleted by our hosting and cloud compute provider. 

How We Secure Biometric Information. We seek to protect your Biometric Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures. We endeavor to protect Biometric Information in the same or more protective manner than the manner in which we store, transmit, or protect other confidential and sensitive information. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Questions about Your Biometric Information. If you have questions about the collection and use of your Biometric Information, please contact us at support@commonground-ai.com.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, MixPanel and Google Firebase both use cookies in connection with their analytics services. The ability of these vendors to use your personal data is subject to their privacy policies at https://mixpanel.com/legal/privacy-policy/ and https://policies.google.com/privacy, respectively. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.  You likewise have the option to opt-out of MixPanel’s use of Cookies by visiting https://help.mixpanel.com/hc/en-us/articles/360001113426-Opt-Out-of-Tracking. 
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” 

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Information about Interest-Based Advertisements: 

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties. 

Deleting Personal Data or Revoking Consent

You may request that we delete your Personal Data at any time by contacting us at support@commonground-ai.com. If you consented to our collection of your Personal Data, you may revoke this consent by contacting us at support@commonground-ai.com. 

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the TrueMeeting website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• www.commonground-ai.com
• support@commonground-ai.com
• 171 Main Street #172, Los Altos, CA 94022