Privacy Policy

Last Update / Effective Date: October 15th, 2020

 

This Privacy Policy (“Policy”) describes the Personal Information collected by or on behalf of AnthillAI, Inc. (“Anthill,” “we,” “us,” or “our”) through the www.anthillai.com website and mobile application (the “Site”) and our machine learning employee engagement technology (collectively, the "Product") and our interactions with you, and how Personal Information is used, shared and protected.

 

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 11 BELOW FOR ADDITIONAL PROVISIONS THAT MAY APPLY TO YOU.

 

Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. All changes will be effective immediately upon posting to the Platform. Material changes will be conspicuously posted on the Platform or otherwise communicated to you.

 

If you use the Product, you must comply with our Term of Use (“Terms”) found at https://www.anthillai.com/terms-and-conditions.

 

  1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

 

We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”):

     A. Identifiers: Identifiers such as: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, or other similar identifiers.

     B. Protected Classifications: Characteristics of protected classifications under California or federal law such as age and gender.

     C. Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

     D. Geolocation Data: Geolocation data.

     E. Employment Information: Professional or employment-related information.

      F. Inferences: Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

   2. CATEGORIES OF SOURCES

 

We may collect all categories of Personal Information listed above from the following categories of sources:

 

Source:  We Collect Personal Information Directly From You. We collect Personal Information that you provide directly to us. Personal Information is required to use certain Product features, for example, to create online accounts, purchase the Product, contact us via email or phone, request a demo via our Request Demo form (where we may retain the content of your message and our response), receive or request data from us (e.g., newsletters), and respond to communications from us.

 

Anthill Accounts. When you set up an account to use the Product, we will collect your name, e-mail address, job title, current team name, and your supervisor’s name. This data is used to populate a profile within your account.

 

Marketing Communications; Opt-Out.  When you create an account with us, you will be opted-in to receive marketing communications from us. We use your contact information to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver communications to you. You may opt-out of such marketing emails by using the unsubscribe link in the email or contacting us at info@anthillai.com with “Unsubscribe” in the subject line. To opt-out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth below. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or transactions.

 

Feedback.  When you provide comments or feedback about our Product, the content on the Site, or our products ("Feedback"), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

 

Business Contracts with Us.  When a business contracts directly with us for the purchase of our products, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and Anthill.

 

Source:  We Collect Personal Information Automatically.  We automatically collect certain information from you when you access our Product.

 

Account Activity.  We may collect data about how you use (i) your online account, and (ii) the Product when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you.

 

Cookies & Other Tracking Technologies.

 

What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.

 

What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

 

Why do we collect Cookies? We use Cookies to:

 

  • make our Site function properly;

  • provide personalized experiences;

  • tailor our interactions with you;

  • help with our marketing efforts;

  • provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and

  • help us improve our products and services.

 

What type of information do Cookies collect? The Cookies on our Site may collect information such as:

 

  • the IP addresses assigned to the computers and other devices you use;

  • your internet service provider;

  • the device ID number;

  • approximate geographic location;

  • the Site pages visited or clicked on;

  • the date and time you visited the Site, and the amount of time spent on the Site;

  • your operating system, browser type, search requests, and other similar information;

  • the websites you access before and after visiting the Site, and

  • data related to how and when you use the Site.

 

We may combine information from Cookies with Personal Information, including data obtained from other sources.

 

How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

 

First-party versus third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties.

 

How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.

 

Google Analytics.  We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.

 

We may also implement additional add-on services to Google Analytics, such as Demographics and Interest Reporting.

 

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

 

Online Behavioral Advertising.  We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.  

 

We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

 

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

 

Source:  We Collect Personal Information From Third-Party Sources.  We obtain data about individuals from third-party content providers and we may combine that data with Personal Information or other data we collect. This enhances our existing data about our users (e.g., adding address data), improves our ability to contact you, and enhances our marketing capabilities.

 

3. PURPOSE FOR COLLECTING PERSONAL INFORMATION

 

We may use all categories of Personal Information listed above for the following business purposes:

 

As Stated or Agreed to at the Point of Collection.  We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration.  We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Product’s demographics and user preferences, for evaluating applications, and managing profiles.

Product Management.  We use Personal Information for Product management, such as troubleshooting problems, improving the content and functionality of the Product, statistical and other analyses of the Product, and to customize the Product to you and our users.

Advertising and Communications.  We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Product, to notify you of changes to our Terms or this Policy, and for other similar communications.

To Protect Our Rights.  We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Product, or to other users of the Product. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

4. CATEGORIES OF THIRD PARTIES AND/OR SERVICES PROVIDERS WITH WHOM WE SHARE PERSONAL INFORMATION

 

We may share all categories of Personal Information listed above with the following categories of third parties and/or service providers:

 

Our Customers: In connection with our Product, we may share with our customers aggregated Personal Information about our customer’s employees who use the Product.

Employees and Affiliates.  We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.

Third-Parties and/or Service Providers.  We may share Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Site; provide targeted advertising and other marketing; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide payment processing services and online storefronts; provide public relations; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Site.

Government Officials / Law Enforcement.  We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Anthill or any other party.

 

Professional Advisors.  We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Anthill.

 

Change in Ownership.  In the event (a) Anthill is subject to a change of control, (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.

 

Other.  We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

 

5. USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION

 

Anthill may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Anthill is the sole and exclusive owner of such de-identified and aggregated information, including if Anthill de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

 

6. CHILDREN

 

The Product is not directed at children under 16 years of age. We do not knowingly collect, use, or share Personal Information from children under 16. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

 

For clarity, to our knowledge, we do not sell the Personal Information of anyone under the age of 16 years old without affirmative authorization.

 

7. SOCIAL MEDIA

 

We are active on social media, including Facebook and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages.

 

The Site allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site.

 

Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

 

8. DATA SECURITY

 

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

 

no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.

 

9. ACCESS FROM OUTSIDE THE UNITED STATES

 

If you access the Product from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.

 

10. THIRD-PARTY WEBSITES

 

The Product may link to, or be linked to, websites not owned or controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

 

11. CALIFORNIA RESIDENTS

 

The purpose of this section is to provide information and additional provisions that apply regarding Anthill’s processing of personal data of California residents in accordance with the California Consumer Privacy Act of 2018 (“CCPA”). THIS SECTION ONLY APPLIES TO YOU IF YOU ARE A RESIDENT OF CALIFORNIA. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents.  In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the CCPA.

 

The Collection, Source, Purpose and Sharing of Your Personal Information.

 

Categories of Personal Information.  We collect the categories of Personal Information described in Section 1.

 

Categories of Sources From Which Personal Information is Collected.  The categories of sources from which your Personal Information is collected is described in Section 2.

Purposes for Collecting Personal Information.  Our purposes for collecting your Personal Information are described in Section 3.

Categories of Third Parties / Services Providers With Whom Personal Information is Shared.  The categories of third parties and / or service providers with whom we share your Personal Information are described in Section 4.

We Do Not Sell Personal Information

In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. "Sale" / “Sold” / "Sell" has the definition set forth in the CCPA. 

Categories of Personal Information Disclosed for a Business Purpose

 

In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.

 

  • Identifiers

  • Protected Classifications

  • Internet Activity

  • Geolocation Data

  • Employment Information

  • Inferences

 

Your Rights to Access and Deletion.  California residents have certain rights under the CCPA, such as the right to request certain information or request deletion of their personal information.  Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their Personal Information:

 

Right to Access.  You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or Selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you (i.e. "data portability"), and (f) a list of categories of Personal Information we disclosed for a Business Purpose in the last 12 months.

Right to Deletion.  You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

How to Exercise Your Rights of Access and Deletion.  To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:

www.anthillai.com

info@anthillai.com

More on Submitting Requests.  You may submit your requests here:  https://www.anthillai.com/contact-us.   

Verifiable Consumer Request.  In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

 

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information we collect during the verification process for the purpose of verifying your identity.  If you maintain an account with us, we may use that account to respond to your request and/or verify your identity.  If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why. 

 

When We Will Respond.  We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

 

Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA.

Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Anthill, and (c) directly confirm with Anthill that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. 

 

We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. 

 

Furthermore, a parent or legal guardian may make a request on behalf of their child.

Shine the Light.  Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.

 

California’s “Do-Not-Track” Requirement. we currently do not respond to “do not track” requests.

12. CONTACT US

If you have any questions you may contact us as set forth below:

 

AnthillAI, Inc.

www.anthillai.com

info@anthillai.com

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