Clarifai Privacy Policy

EFFECTIVE DATE: June 30, 2020

Please read the following to learn how we treat your Personal Data (as defined below). BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT TO OUR COLLECTION, USE, AND SHARING OF YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF. Your use of Clarifai’s Services is at all times subject to the Terms of Use (https://www.clarifai.com/terms) which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use. If you have any questions, feel free to contact us at support@clarifai.com. You can also learn more at https://www.clarifai.com.

What This Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you or third parties that are users of our Services (“Third-Party Users”) access or use our Services or that we otherwise gather for business purposes. “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.

Sources of Personal Data

We collect Personal Data about you from:

• You

  • when you provide such information directly to us, such as:

    • when you create an account and use our Services

    • when you send us Personal Data (including images, videos and text, and geolocation or other metadata attached to such Personal Data)

    • when you voluntarily interact with other users of the Services and share content

• • • when you send us an email or otherwise contact us

  • when Personal Data is automatically collected when you use the Services, such as:

    • through Cookies (defined below)

    • if you use certain applications and software we make available (such as our SDKs and APIs), we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services

  • when you add annotations constituting Personal Data about you to the data you send to us by using our models and algorithms to make predictions about, or by adding tags that describe, such data.

• Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:

  • Third-Party Users. Third-Party Users may provide Personal Data about you:

    • when Third-Party Users use our Services and send us Personal Data about you, including images, videos and text, and geolocation or other metadata attached to such Personal Data

    • if Third-Party Users use certain applications and software we make available (such as our SDKs and APIs), we may receive and collect information transmitted from their computing device for the purpose of providing them the relevant Services, and the information may include Personal Data about you

    • when Third-Party Users add annotations constituting Personal Data about you to the data they send to us when they use our Services by using our models and algorithms to make predictions about, or by adding tags that describe, such data

  • Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may also receive your Personal Data from third parties that provide us with sales leads.

  • Social networks connected to the Services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your account with us.

  • We utilize public datasets, some of which may contain data (such as images or videos of individuals) which may constitute Personal Data.

• Us, when we add annotations constituting Personal Data about you to (i) the data you send to us, (ii) the data Third-Party Users send to us or (iii) the public datasets that we utilize by using our models and algorithms to make predictions about, or by adding tags that describe, such data.

Categories of Personal Data We Collect

The following sections detail the categories of Personal Data that we collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out the categories of third parties with whom we share that Personal Data. More information regarding those sources and categories are set forth in the charts below.

Category of Personal Data	Examples of Personal Data Collected	Source	Third Parties With Whom We Share Data for Business Purposes
Contact Data/Identifiers	First and last name Email Company name Job title and function Phone number Location Password	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Social Network Data	URLs of publicly available accounts on social networks such as LinkedIn Online Identifiers Social media profile IDs Credentials from other online services you use to access the Services, such as email address, full name and profile image from when you sign into our Service using Google Sign-In	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Payment Information	Credit card number Debit card number Billing address	You	Service providers
Device/IP Information	IP address Browser	You Third parties	Service providers
Web Analytics	Browsing history Search history Geographic information Length of visit Pageviews Referral source adIDs Forms submitted Content downloaded	You Third parties	Service providers
Biometric Data	Images and videos and information relating to images or videos, such as patterns associated with images or videos for facial recognition purposes	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Other Visual Information	Data may include other types of information which may constitute Personal Data (e.g. an image of a car with a license plate).	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Geolocation and other metadata	Geolocation and other metadata which may constitute Personal Data.	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Predictions and Tags	You or a Third-Party user may use our models and algorithms to make predictions about data that you or a Third-Party User sends to us, or to add tags to such data. These predictions and tags may contain Personal Data, including age, gender or other demographic data, identifiers, biometric data or geolocation data.	You Third parties	Service providers Parties you or a Third-Party User sharing your Personal Data with us authorizes, accesses or authenticates
Inferences, Predictions and Tags Generated by Us	We may infer new Personal Data from data we collect, including using automated means to generate information about your characteristics (such as using our models and algorithms to make predictions about age, gender and other demographics biometric data or geolocation data). We may also add tags constituting Personal Data to describe data we collect.	Generated by us	Service providers

How We Use Your Personal Data

Commercial or Business Purposes for Collecting Data
Providing, Customizing, and Improving the Services	Providing you or the applicable Third-Party User with the products, services, and information requested and meeting or fulfilling related purposes (for example, using Personal Data that you or such Third-Party User provides to us to perform image recognition services, including facial recognition services, for you or such Third-Party User) Training our models and algorithms to be faster, smarter and more accurate. For instance, we at times use biometric data, as described above, internally to train our models and algorithms in our facial recognition technology. Note that we do so with appropriate authorization (if and as required by applicable law), and we do not distribute Personal Data itself to users who did not provide us with such Personal Data (other than certain names of celebrities in our “Celebrity” model). Any models and algorithms trained on Personal Data and made available to users generally does not include Personal Data itself (other than certain names of celebrities in our “Celebrity” model). Providing support and assistance for the Services Creating and managing your account or other user profiles Billing Personalizing website content and communications based on your preferences Improving the Services, including testing, research, internal analytics, product development Improving the quality of the product through development and research Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”)
Corresponding With You	Communicating with you about the Services, including Service announcements, updates or offers Responding to your inquiries and fulfilling your requests
Legal Requirements	Protecting against or deterring fraudulent, illegal or harmful actions and maintaining the safety, security and integrity of the Services 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, Clarifai 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 use your Personal Data for a variety of purposes, where permitted by applicable law:

In certain circumstances, we may disclose your Personal Data to the following categories of service providers and other parties:

Categories of Third Parties With Whom We Share Personal Data	Business Purpose for Sharing Data
Service Providers
Payment Processors	Our payment processing partner (currently Stripe, Inc.) collects your voluntarily provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy (https://stripe.com/legal) for information on its use and storage of Personal Data
Security and Fraud Prevention Consultants	Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity
Hosting, Technology and Communications Providers; Fulfillment Providers; Data Storage Providers; Analytics Providers; Staff Augmentation Personnel	Performing operational services (such as hosting, billing, fulfillment, data storage, security, web service analytics) and/or make certain services, features or functionality available to our users Debugging to identify and repair errors that impair existing intended functionality. Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider, such as HubSpot Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality or safety of our services
Parties You or a Third-Party User Sharing Your Personal Data With Us Authorizes, Accesses or Authenticates
Other Users	Any information that a user may share with other users is not in any way private. We recommend that you carefully consider whether to disclose any Personal Data in any information you share with other users. What is shared may be seen and/or collected by other third parties and may be used by others in ways we are unable to control or predict.
Social Media Services	We will share your Personal Data if you intentionally interact with any social media service through the Services.

Business Transfers

All Personal Data 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.

Government Requests; Legal Process

Sometimes, we may be required to hand over information to the government or as part of a legal process (like a lawsuit or arbitration). If we are permitted to do so, we will notify you or the applicable Third-Party User that provided us with such information of any such requirement before we comply. We intend to defend our customers’ rights against unlawful search and seizure. However, we also refuse to support criminal activity.

More Information Regarding Automatic Collection of Personal Data and Cookies

The following sections provide additional information about how we collect your Personal Data.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile identifiers, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base, and operate and improve our Services. For example, we use Cookies to tailor the Services by tracking navigation habits, measuring performance, customizing user experiences with the Services and for analytics and fraud prevention. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit 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). Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option and there is currently no industry consensus as to what constitutes a Do Not Track signal. For these reasons, our Services, like many web service site operators, do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

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 and remember your preferences.

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, how long visitors are viewing pages on the Services, mouse clicks, mouse movements, scrolling activity, and text typed into 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, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. 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/. We also use analytics services provided by Periscope, HubSpot, DemandBase, Seamless.AI and Marketo.

Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can score leads and provide you with web and email content that we believe is relevant to you.

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 may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your device. Although you are not required to accept Clarifai’s Cookies, if you block, reject, or delete them, 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 (“EU”).

Data Security and Retention

The security of your Personal Data is important to us. 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. We endeavor to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and in storage. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of your Personal Data. We store and process your information on our servers in the United States ("U.S."). We maintain what we consider industry standard backup and archival systems. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records (for example by making good faith efforts to store Personal Data in a secure operating environment that is not open to the public), please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data shared with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. If at any time during or after our relationship we believe that the security of your Personal Data may have been compromised, we may seek to notify you or the Third-Party User that provided us with your Personal Data of that development. If a notification is appropriate, we will endeavor to notify you or such Third-Party User as promptly as possible under the circumstances. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile. Please keep your email address in your account up to date. You can update that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. You consent to our use of email as a means of such notification.

If you prefer for us to use the U.S. Postal Service to notify you in this situation, please email us at support@clarifai.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you or the Third-Party User that provided us with your Personal Data regarding a compromise of your Personal Data.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide Services to you or the Third-Party User that provided us with your Personal Data. 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, as otherwise permitted or required by applicable law, rule or regulation, or if you or the Third-Party User that provided us with your Personal Data have given us express consent to retain Personal Data for longer. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

The Services are not directed to or intended for use by children under 16, and children under 16 are prohibited from using the Services. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. By accessing, using and/or submitting information to or through the Services, you represent that you are not under 16. If we learn we have collected Personal Data from a child under 16 without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child (or his/her parent or legal guardian) that he/she cannot use the Services, and we will subsequently delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at support@clarifai.com.

If you are between age 16 and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Data as otherwise provided herein.

If you use the Services on behalf of another person, regardless of age, you agree that Clarifai may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

California Resident Rights

If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of ourcustomers’ end users or employees in connection with our provision of certainservices to our customers. If we are processing your Personal Data as a serviceprovider, you should contact the entity that collected your Personal Data in the firstinstance to address your rights with respect to such data. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@clarifai.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data purchased by each category of third-party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Submitting a request by following the instructions found here
• Emailing us at: support@clarifai.com

You may also authorize an agent (and “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out

In this section, we use the term ‘sell’ as it is defined in the CCPA. We will not sell your Personal Data and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@clarifai.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@clarifai.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union Data Subject Rights

EU Residents

If you are a resident of the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Clarifai will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@clarifai.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data about you that we collect from you or from third parties.

Personal Data Use and Processing Grounds

The “How We Use Your Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you or the Third-Party User that provided us with such Personal Data, which enables us to provide the Services to you or such Third-Party User. When we process data due to contractual necessity, failure to provide such Personal Data will result in the inability of you or such Third-Party User to use some or all portions of the Services that require such data.

• • Contact data
  • Social network data
  • Payment information
  • Device/IP information
  • Web analytics
  • Biometric data

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

• • Contact data
  • Device/IP information
  • Web analytics
  • Social network data
  • We may also de-identify or anonymize Personal Data to further our legitimate interests.

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

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

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@clarifai.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Clarifai's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data From the European Economic Area to the United States

The Services are hosted and operated in the U.S. through Clarifai and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Clarifai in the U.S. and will be hosted on U.S. servers, and you authorize Clarifai to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, the details of which are further set forth below.

Clarifai has certified to the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU, and to the Swiss-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from Switzerland. For more information about the Privacy Shield Program, and to view Clarifai’s certification, please visit https://www.privacyshield.gov. Clarifai is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU or Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Clarifai’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. NeuralNetOne, Inc., a wholly owned subsidiary of Clarifai, also adheres to the Privacy Shield Principles.

Please contact us at privacy@clarifai.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through ICDR/AAA, an alternative dispute resolution provider located in the United States. You can visit https://go.adr.org/privacyshield.html for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means. If there is any conflict between the terms in this Privacy 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/.

We may be required to disclose Personal Data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How We Use Information that is not Personal Data

We may use information that is not Personal Data (including Personal Data that has been de-identified and/or aggregated) to better understand who uses Clarifai and how we can deliver a better experience, or otherwise at our discretion.

Controlling Your Personal Data & Notifications

If you are a registered user of the Services, you can modify certain Personal Data or account information by logging in and accessing your account. If you wish to close your account, please email us at support@clarifai.com. Clarifai will use reasonable efforts to delete your account and the related information at your request as soon as reasonably possible. Please note, however, that Clarifai reserves the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law.

You must promptly notify us if any of your account data is lost, stolen or used without permission.

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 as well, but we will alert you to changes by placing a notice on the https://www.clarifai.com/ 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 use, please do not hesitate to contact us at:

• Email: support@clarifai.com

If you are located in the European Union, you may use the following information to contact our Data Protection Officer and our European Union-Based Member Representative:

• European Data Protection Office (EDPO)
• By mail: Avenue Huart Hamoir 71, 1030 Brussels, Belgium
• Email: privacy@edpo.brussels