Last updated: 06th December 2022

Delve AI, Inc. and its Group companies (collectively “Delve AI”, "we", "us", and "ours") is committed to protecting your privacy. This Privacy Notice (“Notice”) describes how Delve AI processes Personal Data in its capacity as a controller (i.e. Delve AI decides what Personal Data is collected and what it is used for) or processor (i.e. Delve AI only processes the data as per the controller's instructions), as the case may be. It also describes your choices regarding use, access and correction of your Personal Data.

DEFINITIONS

The capitalized terms used in this Notice but not defined herein shall have the same meaning as defined in the Terms of Service at https://www.delve.ai/tos (“Terms”).

OVERVIEW

We categorize the personal data that we process as follows:

User Data

Data we collect from the visitors of our Website(s) and Users of our Service(s), both directly and by automated means.

Client User Data

Data we process on behalf of our clients. This includes visitors to Your websites and data from integrations that you have enabled in our Service(s).

USER DATA

We collect information from users of our Service(s) and visitors to our Website(s). The information is collected in order to provide the Service(s).

USER-PROVIDED INFORMATION

When You sign-in to our Service(s) we collect the following information:

AUTOMATICALLY COLLECTED INFORMATION

If You are visiting our Website(s), as is true of most websites, We gather certain information automatically and store it in log files. This information may include the following: pages accessed (including title, URL and content), Internet Protocol (IP) addresses (including name of owner and reverse domains of the IP addresses), browser type, device information, Internet Service Provider (ISP), city/state/country, referring/exit pages with relevant search queries (when applicable), operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other data we collect about you.

HOW ARE WE USING THE DATA

We use User Data:

To provide the Service(s).

We use User Data in delivery, maintenance and enhancement of the Service(s), to provide support and to prevent or address technical or security issues.

To communicate with you

We may send You service-related messages and notifications. These include notifications that are part of the Service(s). You can control what and when to receive these notifications. We also send administrative messages regarding your Delve AI subscriptions, technical status updates and other related notifications.

We may also send You messages regarding new product features and helpful tips on using the product and to offer training and support. You can opt-out from such messages at any time.

For payments and billing

We collect payment and billing data from paid Service Plan clients for fulfilment of payments for the Service(s).

For improvement of the Service(s) and analytics

To help improve the Service(s), our Website(s) and to develop new features and functionality we collect and analyze usage information. Processing User Data for analytics and abstraction purposes is done in aggregated or anonymized form.

LEGAL BASIS

We process User Data only where:

1. Processing User Data is necessary for providing the Service.
2. Processing is necessary to comply with a legal obligation.
3. Processing is in legitimate interests of Delve AI, but not in conflict of our users' rights.

YOUR RIGHTS

You can request a copy, correction or deletion of your personal data by emailing privacy@delve.ai. We will respond to your request within 30 days.

CLIENT USER DATA

Client User Data means data that we process on Your behalf and which is gathered from Your websites or from integrations such as Google Analytics that have been enabled by You in our Service(s).

DATA FROM GOOGLE ANALYTICS

Delve AI gathers data about visitors on Your websites from Google Analytics.

This data includes:

• Pages/screens accessed, depth
• Time of views/events
• Referring sites, applications, or services, including the relevant search queries that led visitors to Client’s website
• Browser information and operating system
• Device and network information
• Name of the owner and reverse domain of the IP address
• Demographics, including age group and gender
• Interest categories
• User types, such as new versus returning
• Location and language
• Google ads, campaigns, ad groups, keywords, targeting, placement and destination
• E-commerce, products, categories and brands
• Events, goals, conversions and transactions

DATA FROM ORGINFO INTEGRATION

Delve AI gathers data about visitors on Your websites via OrgInfo integration.

This data includes:

• Internet Protocol (IP) address
• Name of the owner and reverse domain of the IP address
• Internet Service Provider (ISP)
• Pages/screens accessed, depth
• Time of views/events
• Referring sites, applications, or services, including the relevant search queries that led visitors to Client’s website
• Browser information and operating system
• Device and network information
• Location and language

DATA FROM SOCIAL MEDIA PLATFORMS AND WEBSITES

Delve AI gathers publicly accessible data from social media platforms (such as Twitter, Facebook, Instagram, Linkedin, Pinterest, Tiktok and YouTube) and websites (such as Yelp).

This data includes:

• Identifiers such as username/handle and ID
• Profile/bio information such as name, profile picture, description, location and URL
• Demographic information such as age and gender
• Engagement/reviews activity such as follows, followers/subscribers, likes, posts/tweets, shares/retweets, replies, comments, mentions, tags, reviews and ratings

If you would like to opt-out and block your social data from being processed by Delve AI platform, please submit the Social data opt-out request form.

HOW ARE WE USING THE DATA

Delve AI acts as a data processor in regards to Client User Data. You are in full control of what happens and who has access to the Client User Data. We never share or use Client User Data except as specifically agreed in the Terms.

RESPONSIBILITY OF THE CLIENT

It is Your sole responsibility to ensure that You have obtained permission from Your customers and other website users to provide this information to Delve AI via the Service(s). Delve AI shall have no liability whatsoever for Your failure to obtain this permission and hereby disclaims such liability. You hereby agree to defend, indemnify and hold harmless Delve AI and its affiliates and their respective officers, directors, employees, agents, successors and assigns from any third party claims arising from Your provision of Client User Data to Delve AI using the Service.

COOKIES AND TRACKING

We use cookies on our Website(s).

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site or service provider's systems to recognize your browser, capture and remember certain information.

Please see our Cookie Policy for further information about our use of Cookies and similar technologies.

LOCATION

We store our data in Amazon Web Services (https://aws.amazon.com) and Google Cloud (https://console.cloud.google.com/) data centres in USA.

We use model contractual clauses with our clients to provide adequate protection for the transfer and processing of your personal data in the United States.

SHARING AND DISCLOSURE

We do not share or disclose information to third parties except in the following situations:

User instructions or consent

Information may be disclosed to third-parties if we are explicitly instructed to do so by the user, or by user consent.

Third-party service providers

We may engage third-party companies service providers or business partners to process our data and to support our business. These include for example server and hosting providers, payment processors and customer service and management tools.

Up-to-date list of our sub-processors is available on request from privacy@delve.ai.

Change of ownership

We may disclose User Data to allow a change of ownership of Delve AI (including, but not limited to, an acquisition by or merger with another company) and related transfer of all such information to the new owner, in which case any information remains protected in accordance with this Privacy Notice.

Legal obligations

We may disclose personal data if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.

Enforcement of our rights, prevention of fraud, and for safety

We also may disclose personal information in order to:

1. protect Delve AI from fraud, abuse or other criminal activity
2. protect Delve AI rights and property against third-party allegations and claims
3. enforce our contracts and policies
4. protect rights and safety of others

COMPLIANCE

EU General Data Protection Regulation (GDPR)

We are committed to EU General Data Protection Regulation.

Children's Online Privacy Protection Act

We do not collect any information from anyone under 13 years of age. Our Website(s) and Service(s) are all directed to people who are at least 13 years old.

Changes to this Privacy Notice

We will notify Delve AI users of any non-trivial changes to this Privacy Notice via email.

ANY QUESTIONS?

If you have questions or complaints regarding our privacy notice or practices, please contact us at privacy@delve.ai or via postal mail at Delve AI, Inc., 548 Market St #49064, San Francisco, CA 94104-5401, USA with a CC to legal@delve.ai.