Welcome to the Privacy Policy of iollo, Inc. ("iollo," "we," "us," or "our"). At iollo, we are deeply committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy is designed to provide you with a thorough and transparent explanation of our practices regarding the collection, use, disclosure, and protection of information in connection with our website located at https://www.iollo.ai (the "Website"), our proprietary software as a service (SaaS) platform (the "Platform") which is accessible as a web application via our Website and/or a mobile application, and any other interactions you may have with us.

We strongly encourage you to read this Privacy Policy carefully and in its entirety. It is crucial that you understand how we handle your information and what rights you have concerning your data. By using our services, you acknowledge that you have read, understood, and agreed to the practices described in this policy.

1. Scope and Consent

1.1. Applicability: This Privacy Policy applies to three primary groups:

a) Visitors to our Website who view publicly-available content ("Visitors")

b) Customers who have registered to access and use our Platform ("Customers")

c) Customer's employees and contractors who are authorized to access and use the Platform on behalf of the Customer ("Authorized Users")

1.2. Agreement to Terms: By visiting our Website, Visitors explicitly agree to the terms outlined in this Privacy Policy and our accompanying Terms of Use. Similarly, by accessing and/or using our Platform, each Customer and Authorized User agrees to abide by this Privacy Policy and the associated Platform Terms of Use.

1.3. Defined Terms: Any capitalized terms not explicitly defined within this Privacy Policy shall carry the meanings assigned to them in our Terms of Use.

1.4. Consent: By using our services, you are giving your consent for us to collect, use, and disclose your information as described in this Privacy Policy. If you do not agree with any part of this policy, please refrain from using our Website or Platform.

1.5. Age Restriction: Our services are intended for use by individuals who are at least 18 years old. By using our services, you represent and warrant that you are at least 18 years of age.

2. Information We Collect

In the course of operating our Website and Platform, and through our interactions with you, we collect and/or receive various types of information. You authorize us to collect and/or receive such information, which may include:

2.1. Contact Information: When you reach out to us through the Website, email, mail, or phone, or when you subscribe to receive information about our products and services, we may collect:

a) Your name

b) Email address

c) Phone number

d) Company name

e) Job title

f) Mailing address

g) Any other information you provide in your communication

We use this Contact Information to respond to your inquiries, provide requested information, and for direct marketing of our current and future services.

2.2. Account Information: To create an account and access our Platform, you will need to provide:

a) Your email address

b) A password of your choice

c) Your full name

d) Company affiliation

e) Job role or title

f) Other relevant professional information

We use this Account Information to process your account creation, verify your identity, manage your account, and customize your experience on our Platform.

2.3. Your Data: While using our Platform, you will provide us with various types of data, which we refer to as "Your Data." This may include:

a) Content you create, upload, or store on the Platform

b) Information about your clients or patients

c) Project-related data

d) Feedback and comments

e) Any other information you choose to provide through the Platform

We handle Your Data in accordance with our Platform Terms of Use and this Privacy Policy.

2.4. Automatically Collected Information: When you access or use our Website and Platform, we employ various technologies to automatically collect or receive certain information, including:

a) Browser type and version

b) Operating system

c) IP address

d) Device type (e.g., mobile, tablet, desktop)

e) Unique device identifiers

f) Pages viewed and time spent on pages

g) Links clicked

h) Referring website address

i) Language preferences

j) Time zone settings

k) Geolocation data (if enabled on your device)

l) Network connection type

m) Application performance data

n) Error logs

o) User interaction data

We use this information to enhance the functionality of our Website and Platform, personalize your experience, analyze usage patterns, improve our services, and ensure the security and stability of our systems.

2.5. Cookies and Similar Technologies: We use various types of cookies and similar tracking technologies to collect information and provide you with a better experience:

a) Essential Cookies: These are necessary for the Website and Platform to function properly and cannot be switched off.

b) Performance Cookies: These help us understand how visitors interact with our Website by collecting and reporting information anonymously.

c) Functionality Cookies: These allow the Website to remember choices you make and provide enhanced, more personal features.

d) Targeting Cookies: These are used to deliver advertisements more relevant to you and your interests.

e) Social Media Cookies: These enable you to share our content on social media platforms and interact with our social media features.

f) Analytics Cookies: These help us measure and analyze the effectiveness of our marketing campaigns and user engagement.

2.6. Third-Party Analytics: We may utilize third-party analytics services (such as Google Analytics, Mixpanel, and Hotjar) to evaluate the use of our Website and Platform. These services may collect information about your online activities over time and across different websites. They help us understand user behavior, compile reports on activity, and provide other services related to website and internet use. You can learn more about how these services collect and process data by visiting their respective privacy policies:

a) Google Analytics: https://policies.google.com/privacy

b) Mixpanel: https://mixpanel.com/legal/privacy-policy/

c) Hotjar: https://www.hotjar.com/legal/policies/privacy/

2.7. Advertising Data: We may share certain information about you with third-party advertising partners for ad distribution and optimization. These partners may use cookies, pixel tags, and similar technologies to collect information for tailoring, targeting, analyzing, and optimizing ads. Our advertising partners may include:

a) Google Ads

b) Facebook Ads

c) LinkedIn Ads

d) Twitter Ads

You have the option to opt-out of certain types of targeted advertising by visiting http://www.aboutads.info/choices or adjusting your device settings.

2.8. Log Files: We gather certain information automatically and store it in log files. This information may include:

a) IP addresses

b) Browser type

c) Internet Service Provider (ISP)

d) Referring/exit pages

e) Operating system

f) Date/time stamp

g) Clickstream data

We use this information to analyze trends, administer the site, track users' movements around the site, and gather demographic information about our user base as a whole.

2.9. Mobile Device Data: When you access our Platform through a mobile device, we may collect additional information such as:

a) Device type and model

b) Operating system and version

c) Unique device identifiers

d) Mobile network information

e) App version and usage statistics

3. Use and Sharing of Information

We may use and share your information for various purposes, including but not limited to:

3.1. Service Provision and Improvement:

a) To provide, maintain, and enhance our Website and Platform

b) To process transactions and fulfill your requests

c) To provide customer support and respond to inquiries

d) To improve and optimize our services based on user feedback and usage patterns

e) To develop new features, products, and services

f) To perform technical operations, such as updating software and resolving technical issues

g) To customize and personalize your experience on our Platform

3.2. Communication:

a) To send administrative messages, updates, and security alerts

b) To provide information about our products, services, and promotions

c) To respond to your comments, questions, and requests

d) To send surveys and collect feedback about our services

e) To notify you about changes to our services or policies

f) To communicate with you about your account and transactions

3.3. Marketing and Advertising:

a) To conduct marketing campaigns and send promotional materials

b) To measure and analyze the effectiveness of our advertising efforts

c) To serve targeted advertisements based on your interests and browsing behavior

d) To create and manage customer profiles for marketing purposes

e) To participate in and manage affiliate marketing programs

f) To organize and promote events, webinars, and conferences

3.4. Analysis and Research:

a) To conduct market research and analyze trends in user behavior

b) To generate aggregated, non-identifying statistical data

c) To improve our understanding of customer needs and preferences

d) To perform data analysis and testing to improve our services and develop new features

e) To monitor and analyze usage patterns and trends across our Website and Platform

f) To create predictive models to enhance our services and business operations

3.5. Security and Fraud Prevention:

a) To detect, prevent, and address technical issues

b) To protect against fraudulent, unauthorized, or illegal activity

c) To ensure the security of our Website, Platform, and user accounts

d) To verify your identity and authenticate access to your account

e) To monitor and enforce compliance with our terms of service and policies

f) To investigate and resolve disputes and security incidents

3.6. Legal Compliance:

a) To comply with applicable laws, regulations, and legal processes

b) To enforce our terms of service and other legal rights

c) To respond to lawful requests from public authorities

d) To protect our rights, privacy, safety, or property, and that of our users or others

e) To detect, prevent, or otherwise address fraud, security, or technical issues

f) To comply with industry standards and best practices

3.7. Business Transactions:

a) In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company

b) To facilitate due diligence processes and business transitions

c) To transfer information to a successor entity in the event of a corporate reorganization, merger, sale, or acquisition

3.8. Service Providers:

a) To share information with third-party service providers who help us operate our business and deliver services to you

b) These providers are contractually obligated to protect your information and use it only for the purposes we specify

c) Categories of service providers may include:

- Hosting and cloud computing providers

- Payment processors

- Analytics and data analysis services

- Customer support and help desk services

- Marketing and advertising partners

- Email and communication service providers

- Security and fraud prevention services

3.9. With Your Consent:

We may use or share your information for any other purpose with your explicit consent.

4. Your Choices and Rights

We respect your privacy rights and provide you with choices regarding your personal information:

4.1. Access and Updates: You can access and update certain personal information by:

a) Logging into your account on our Platform and modifying your profile

b) Contacting us directly using the information provided in Section 13

c) Submitting a formal data subject access request, where applicable under local laws

4.2. Marketing Communications: You can manage your receipt of marketing and non-transactional communications by:

a) Clicking the "unsubscribe" link in any of our marketing emails

b) Adjusting your communication preferences in your account settings

c) Contacting us to update your communication preferences

Please note that you cannot opt out of receiving transactional emails related to your account or use of our services.

4.3. Cookies and Tracking Technologies: You can manage your preferences for cookies and similar technologies by:

a) Adjusting your browser settings to refuse or delete cookies

b) Using available opt-out mechanisms for specific third-party advertising and analytics services

c) Utilizing the cookie preference center on our Website, if available

Please be aware that disabling cookies may impact the functionality of our Website and Platform.

4.4. Data Portability: In some jurisdictions, you may have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format. To exercise this right:

a) Log into your account and use the data export feature, if available

b) Contact our privacy team with a formal request for data portability

c) Specify the particular data you wish to receive and the format you prefer

4.5. Deletion: You may request the deletion of your personal information, subject to certain exceptions provided by law. To initiate a deletion request:

a) Use the account deletion option in your account settings, if available

b) Contact our support team with a formal deletion request

c) Provide necessary verification of your identity

Please note that certain information may be retained for legal or operational purposes even after a deletion request.

4.6. Objection: In certain circumstances, you may have the right to object to the processing of your personal information. This might apply to:

a) Processing for direct marketing purposes

b) Processing based on legitimate interests

c) Processing for scientific or historical research purposes or statistical purposes

To exercise your right to object, please contact our privacy team with details of your objection.

4.7. Withdrawal of Consent: Where we process your data based on your consent, you have the right to withdraw that consent at any time. To do so:

a) Use the relevant options in your account settings

b) Contact our support team to withdraw specific consents

c) Note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal

4.8. Do Not Sell My Personal Information: In jurisdictions where applicable (e.g., California under CCPA), you have the right to opt-out of the sale of your personal information. To exercise this right:

a) Click on the "Do Not Sell My Personal Information" link on our Website, if available

b) Contact our privacy team with a formal request to opt-out of data sales

4.9. Complaint Submission: If you believe your privacy rights have been violated, you have the right to lodge a complaint with a supervisory authority or with us directly. To file a complaint with us:

a) Use our dedicated complaint submission form on the Website

b) Email our privacy team with details of your complaint

c) We will investigate and respond to your complaint in a timely manner

5. Data Security

5.1. Security Measures: We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to:

a) Encryption of data in transit and at rest using industry-standard protocols

b) Regular security assessments and penetration testing

c) Access controls and authentication mechanisms

d) Firewalls and intrusion detection systems

e) Regular security awareness training for our employees

f) Physical security measures for our data centers and offices

5.2. Data Breach Response: In the event of a data breach that compromises your personal information, we will:

a) Promptly investigate the incident and take necessary remediation steps

b) Notify you and relevant authorities as required by applicable laws

c) Provide you with information about the breach and our response

d) Offer appropriate support, which may include credit monitoring services

5.3. Employee Access: We restrict access to personal information to our employees, contractors, and agents who need to know that information in order to process it for us. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

5.4. Third-Party Security: We take steps to ensure that our service providers and business partners maintain similar levels of data protection. However, we cannot guarantee the security of information that is transmitted to us or stored on our systems.

5.5. User Responsibilities: You play a crucial role in protecting your information. We urge you to take precautions such as:

a) Using strong, unique passwords for your account

b) Not sharing your account credentials with others

c) Logging out of your account after each session

d) Being cautious when accessing your account from public or shared computers

e) Keeping your devices and software up to date

5.6. Ongoing Improvements: We regularly review and update our security practices to address new and emerging threats and improve the security of our systems.

6. Data Retention

6.1. Retention Period: We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

a) The length of time we have an ongoing relationship with you

b) Whether there is a legal obligation to which we are subject

c) Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations)

6.2. Account Information: If you choose to close your account, we will generally delete your account information within 30 days of account closure. However, we may retain certain information as required by law or for legitimate business purposes.

6.3. Marketing Information: If you have opted out of receiving marketing communications from us, we will retain certain information about your marketing preferences for a reasonable period of time in order to comply with your opt-out request.

6.4. Anonymized Data: We may retain anonymized or aggregated data indefinitely, which cannot be linked directly back to you.

6.5. Backup Data: We maintain backup copies of our systems, which may include your personal information, for a limited period of time for disaster recovery purposes.

7. International Data Transfers

7.1. Global Operations: iollo operates globally, and your information may be transferred to, stored, and processed in countries other than the one in which you reside. Specifically, our primary data centers are located in:

a) United States

b) European Union

7.2. Data Protection Laws: Data protection laws may differ between countries. By using our services, you acknowledge that your information may be transferred to and processed in countries where data protection laws may be less comprehensive than in your home country.

7.3. Safeguards: When we transfer personal information across borders, we take appropriate measures to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it. These measures may include:

a) Entering into Standard Contractual Clauses approved by the European Commission

b) Obtaining your explicit consent for certain types of data transfers

c) Ensuring that recipients of your data are certified under the EU-U.S. or Swiss-U.S. Privacy Shield Framework

d) Implementing Binding Corporate Rules for transfers between our group companies

7.4. EU-U.S. and Swiss-U.S. Privacy Shield: While we no longer rely on the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as a legal basis for transfers of personal data in light of the judgment of the Court of Justice of the EU in Case C-311/18, we continue to comply with the Privacy Shield Principles for all personal data received from the EU, EEA, and Switzerland in reliance on the Privacy Shield.

7.5. Data Transfer Impact Assessments: We conduct regular assessments of our data transfer mechanisms to ensure they meet the requirements of applicable data protection laws.

8. Children's Privacy

8.1. Age Restriction: Our services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18.

8.2. Parental Consent: If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately. If we become aware that we have collected personal information from a child under the age of 18 without parental consent, we will take steps to remove that information from our servers.

8.3. COPPA Compliance: Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. We comply with the Children's Online Privacy Protection Act (COPPA) and similar laws around the world where applicable.

8.4. Educational Services: If we offer any educational services that may be used by individuals under 18, we will comply with applicable laws such as the Family Educational Rights and Privacy Act (FERPA) in the United States.

8.5. Reporting: If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us using the information provided in Section 13, and we will endeavor to delete that information from our databases.

9. Do Not Track

9.1. Browser Settings: Some web browsers incorporate a "Do Not Track" (DNT) or similar feature that signals to websites that a user does not want to have their online activity tracked.

9.2. Our Response: Currently, we do not respond to or alter our practices when we receive a DNT signal from a visitor's browser. However, we remain committed to providing you with meaningful choices about the information collected on our Website and Platform for third-party purposes.

9.3. Third-Party Tracking: We cannot control the collection or use of your information by third parties for tracking purposes. If you are concerned about this type of tracking, we encourage you to review the privacy policies and opt-out procedures of these third parties.

9.4. Alternative Controls: While we don't respond to DNT signals, we offer other choices for controlling data collection and use, including those described in the "Your Choices and Rights" section of this policy.

10. California Privacy Rights

10.1. CCPA Compliance: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) regarding your personal information. These rights include:

10.2. Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

a) The categories of personal information we collected about you

b) The categories of sources for the personal information we collected about you

c) Our business or commercial purpose for collecting or selling that personal information

d) The categories of third parties with whom we share that personal information

e) The specific pieces of personal information we collected about you

10.3. Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

10.4. Right to Opt-Out of Sales: If we sell your personal information, you have the right to opt-out of that sale at any time.

10.5. Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

a) Deny you goods or services

b) Charge you different prices or rates for goods or services

c) Provide you a different level or quality of goods or services

d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

10.6. Verifiable Consumer Requests: To exercise your rights under the CCPA, you will need to submit a verifiable consumer request to us. You may do this by:

a) Calling us at (650) 855-2685

b) Submitting a request through our website at https://www.iollo.ai

c) Emailing us at privacy@iollo.com

10.7. Authorized Agent: You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you must provide the authorized agent with written permission to do so and verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

11. Nevada Privacy Rights

11.1. Right to Opt-Out: Nevada residents have the right to opt-out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information, as "sell" is defined by Nevada law, and we have no plans to do so in the future.

11.2. Nevada-Specific Requests: If you are a Nevada resident and would like to make an information request pursuant to Nevada law, please contact us using the information provided in Section 13.

12. Changes to This Policy

12.1. Policy Updates: We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. When we do, we will update the "Last updated" date at the top of this Privacy Policy.

12.2. Notification of Changes: For significant changes to this Privacy Policy, we will make reasonable efforts to notify you, such as:

a) Sending an email notification to the email address associated with your account

b) Displaying a prominent notice on our Website or within our Platform

c) Notifying you through your account dashboard

12.3. Review of Changes: We encourage you to periodically review this Privacy Policy to stay informed about our information practices. Your continued use of our services after any changes or revisions to this Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.

12.4. Material Changes: If we make material changes to how we treat our users' personal information, we will notify you through a notice on this Privacy Policy page and other appropriate means.

12.5. Objection to Changes: If you object to any changes, you may close your account. Continuing to use our services after we publish or notify you of changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please don't hesitate to contact us:

Email: privacy@iollo.com

Phone: (650) 855-2685

Mailing Address:

iollo, Inc., 2261 Market Street, #4822, San Francisco, CA, 94114

Last Updated: 08/07/2024