Through the course of providing our Service through the Wit Platform, developers (who are our customers) may provide us with information from or about their End Users, or their End Users' use of their Device or Application (including personal information), including, but not limited to, utterance data, Expressions, Intents and Entities ("Customer Data"). In all of these cases, our software has been integrated into developers' products or applications and, to the extent that we process Customer Data, we do so on the behalf of developers for the purpose of providing the Service to them and in accordance with the Terms of Service. For clarity, the processing of Customer Data (in respect of which Wit acts as a Data Processor, not a Data Controller) is not governed by this Policy, except with respect to the Privacy Shield section below. Please check with the relevant developer about the policies it has in place to protect the personal data of its End Users.
We also process the following personal information from our developer users (collectively referred to as "Wit Data") in order to provide our Services. Wit.ai Inc. is the controller of Wit Data. The categories of information we collect can include:
Information you provide to the Wit website. We may collect and store personal information you provide to our Service when you register for an account or provide it to us in some other manner, including your name, email address, phone number, user name and password, when you register for our Service, request a demo or contact us for information about our Service. When you register for our Service, we will create a Wit Profile for you, containing information such as your screenname and URLs, which are displayed publicly. Where we provide forums, blogs or bulletins that allow for user-generated content, we may also collect and store personal information that you provide in relation to such content in accordance with this Policy. We may also collect any communications between you and Wit, as well as any information you provide if you take part in any interactive features of the Service.
Information you permit us to receive from social networking sites. When you interact with our Service through various social media, such as when you login through GitHub, or interact with us on Facebook or Twitter, we may receive information from the social network site including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.
The provision of certain personal data is mandatory and may be required in accordance with a contractual requirement or to enter into a contract. The collection of any such data will be made clear at the time of collection of the information. If you choose not to submit this information, this may result in us not being able to provide the Service to you.
We automatically collect certain types of usage information when you visit our website or use our Service. When you visit the website, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include information such as your web request, Internet Protocol ("IP") address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our Users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service.
When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device ("Device ID"), mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our service.
Please refer to your browser's or mobile device's technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative's online resources, at http://www.networkadvertising.org). Depending on your mobile device, you may not be able to control tracking technologies through settings.
HOW WE USE THIS INFORMATION
Wit uses Customer Data to operate, maintain, provide and improve the Service, and to process requests from developers in accordance with our Terms of Service or as required by law.
Wit relies on a number of legal bases to lawfully process Wit Data for the purposes described below. We need to process Wit Data as necessary in order to provide our Services, in accordance with our Terms of Service. When we process data that you provide to us as necessary for performing our Terms of Service, you have the right to port it under the GDPR. We may also process Wit Data where necessary to further our legitimate interests and those of others, where those legitimate interests are not overridden by your rights or interests. Users based in the European Economic Area have the right to object to this processing based on legitimate interests and should contact us to do so. More specifically, we use Wit Data for the following purposes:
To provide, update, maintain and protect our Service. We use Wit Data to operate, maintain, and provide to you the features and functionality of the Service. This includes providing custom, personalized content and information such as diagnosing or fixing security or technical issues, analyzing and monitoring usage, trends and other activities that might disrupt our Service.
To communicate with you. We use Wit Data to communicate directly with you and to offer products and services to you and it is in our legitimate interest to promote our Services and issue our direct marketing. We may also send you Service-related emails or messages (e.g., account verification, changes or updates to features of the Service, technical and security notices). For more information about your communication preferences, see "Your Choices Regarding Your Information" below.
Safety and security. We may also use your information for safety and security purposes, including the sharing of your information for such purposes. We do so as it is necessary to deliver safe and secure Services in accordance with our Terms of Service.
As required by applicable law, legal process or regulation. We may process your personal information if applicable law, legal process or regulation requires us to do so.
SHARING YOUR INFORMATION
We may share your personal information in the instances described below in accordance with this Policy. For further information on your choices regarding your information, see the "Your Choices Regarding Your Information" section below.
Corporate affiliates. We may share your personal information with other companies owned by or under common ownership as Wit (such as the Facebook Family of Companies). We share infrastructure, systems and technology and they may use the information we share with them to help operate, provide, improve, understand, customize, support, and market our services and their offerings. This includes helping improve infrastructure and delivery systems, understanding how our Services or theirs are used, securing systems, and fighting spam, abuse, or infringement activities.
Third party vendors, consultants, business partners and other service providers. We engage third party companies or individuals to perform services on our behalf or in order to carry out their work for us, which may include content or service fulfillment, customer support, billing, or providing analytics services.
Third parties at your request. For example, information contained in your Wit Profile, including your GitHub ID, may be viewable to others on the Wit Platform, subject to your settings, and you may have the option to link your information on our Service with your friends via email or social media.
Business re-organization. If we sell all or part of our business, make a sale or transfer of assets or shares, or partake in a reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings, we may disclose and transfer your personal information to one or more third parties as part of that transaction.
Legal and safety reasons. We may process your personal information in order to (i) comply with any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Service, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Wit, Users or the public as required or permitted by law, and (v) detect, prevent or otherwise address criminal, security or technical issues.
Aggregated information. We may also share information with others in an aggregated and depersonalized form that is no longer associated with and can no longer be linked to an identified or identifiable user or individual.
YOUR CHOICES REGARDING YOUR INFORMATION
You have choices regarding what and how your personal information is shared and used:
Marketing communications. If you do not wish to receive promotional emails, you can click the "unsubscribe" button on promotional email communications. Note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Service, or technical and security notices.
YOUR RIGHTS: FOR EU USERS ONLY
Customer Data If your personal data is comprised in Customer Data, then you should contact the developer in relation to any statutory rights you may have to access, port, rectify, erase, restrict or object to developer's processing of your data.
Wit Data If your personal data is comprised in Wit Data and you are based in the European Economic Area, then you have rights to access and port this information, along with rights to rectify, erase, restrict and object to Wit processing your personal data including as set out above in "How We Use This Information". Please use the contact details set out below to contact us should you wish to exercise these rights. Without prejudice to any other rights you may have, if you are based in the EU you also have the right to file a complaint against Wit with your local supervisory authority.
We will retain your information for as long as your account is active or as needed to provide you the Services. We will retain your personal data comprised in Wit Data for as long as is necessary for the purposes set out in this Notice or as needed for us to provide the Service or to perform our contract with you. We will retain and use your personal data to the extent necessary to comply with our legal obligations, to resolve disputes and to enforce our agreements.
We are a global service and information collected through the Service may be stored and processed in the United States or any other country in which Wit or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. These data transfers are necessary to provide the Service.
Wit complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, "Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States. Wit has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
Under the Privacy Shield Principles, individuals have the right to opt out of (i) disclosures of their personal information to third parties; or (ii) uses of their personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals also have the right under the Privacy Shield Principles to access, correct, amend, or delete their personal information that is inaccurate or has been processed in violation of the Privacy Shield Principles, subject to certain exceptions. Wit takes reasonable steps to enable individuals, either directly or through our developer partners, to exercise their rights under the Privacy Shield Principles.
In compliance with the Privacy Shield Principles, Wit commits to resolve complaints about our collection or use of your personal information. EU, Swiss, and United Kingdom individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
The Federal Trade Commission has jurisdiction over Wit's compliance with the Privacy Shield. In certain circumstances, you may be able to invoke binding arbitration with respect to adherence to the Privacy Shield. If Wit shares personal information with certain third parties, Wit may be liable if those parties process that information in a manner that is inconsistent with the Privacy Shield Principles. Wit may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
SECURITY AND STORAGE OF INFORMATION
Wit cares about the security of your information and uses appropriate organizational and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems.
PERSONS UNDER THE AGE OF 13
Wit does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information collected from a child under 13, please contact us at email@example.com.
LINKS TO THIRD PARTY WEBSITES
The Service may contain links to and from third party websites such as our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
UPDATES TO THIS POLICY
We may modify this Policy from time to time to reflect changes in our privacy practices. If we make any material changes to this Policy, we will notify you by contacting you through our services or by posting a notice on our website - or by some combination of these methods. In circumstances where you have not provided us with your contact information, we encourage you to periodically review the Website for the latest information on our privacy practices.
If you have questions about this Policy, or if you would like to exercise your statutory rights with respect to your personal information, please contact us at firstname.lastname@example.org.
LAST REVISION DATE
This Policy was last revised on, and effective as of April 11, 2019.