In order to ensure transparency and give you more control over your personal information, this Privacy Notice (“Privacy Notice”) governs how we, AnyVision Interactive Technologies Ltd. (d/b/a Oosto) (“Oosto,” “we,” “our,” or “us”) use, collect, and store personal information that we collect or receive from or about you (“you”) in connection with https://oosto.com/ (the “Website”) and the products and services provided by us (the “Services”).
Ordinarily, when acting on behalf of customer Oosto will be a “processor“, according to the definition of that term in Regulation (EU) 2016/679 (GDPR), and the UK GDPR. In limited circumstances Oosto may act as a “controller” (for instance when processing the personal data of people who visit our website, or who work for our customers). This Privacy Notice is intended to apply where Oosto is acting as a “controller“. We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Notice carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Notice is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.
Table of contents:
- What personal information we collect, why we collect it, and how it is used
- Customer information
- How we protect and retain your personal information
- How we share your personal information
- U.S. privacy rights
- Your privacy rights
- International transfers of personal information
- Use by children
- Interaction with third party products
- Analytic tools/Cookies
- Our California Do Not Track Notice
- Contact us
Oosto’s mission is a video analytics solution that provides face, body, and behavior detection and alert.
This Privacy Notice can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Notice. If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.
1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
(i) We Process the Following Personal Information:
(a) Information provided through the Website. When you use the Website, we collect and process full name, email address, job title, company name and details, industry, phone number, country, and any other information that you decide to provide us with.
The Website may include the option to purchase certain Services from us. If you choose to make a purchase, you must provide account and billing information, invoice related information, and other data required to process the order. We may also update such data should you permit us to bill you or your credit card for recurring charges, such as monthly or other types of periodic payments. We may use the tools, software, or services of third-party service providers to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy Notice of said third-party service provider.
In addition, when you decide to submit your information to our Careers site, we collect full name, email address, phone number, CV/resume, LinkedIn profile URL, personal website, cover letter, portfolio, personal note.
(b) Information provided through the Services. When customers’ users create a user account to our online platform, we collect and process full name, email address, phone number, company details, internet protocol (IP) address, traffic data, and observability data (for example, system performance metrics and logs). In addition, if you or a third party sends Oosto a comment, message, or other communication (such as, by way of example only, email, letter, text, fax, phone call, or voice message) about you or your activities on or through the website and/or the Oosto products or services, then Oosto may collect any personal or non-personal information provided in or with the communication. This information may be used to respond to your communication, to improve our products and services, or for other purposes as described in this Privacy Notice. In some limited cases, Customers may send Oosto examples of false/positive results. In limited cases, customers may send Oosto examples of false positive/results.
(c) Information automatically collected. We automatically collect certain information through your use of our Website and Services, such as cookies, pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider, and other information about actions taken through the use of the Services and Website.
(d) Information from Other Sources. Oosto also obtains information from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners, and service providers.
(e) Information you provide to us in person. For example, when you visit one of our exhibition booths or attend an event, provide us with your contact details. We will use this information to answer your enquiries or provide additional information to you.
(f) Information we collect from online interactions. For example, if you attend a webinar, contact us via social media, or otherwise interact with our business, including as a representative of a current/prospective customer, supplier, or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, job title, company name and details, industry, phone number, country, and any other information that you decide to provide us with. In addition, if you send us a comment, message, or other communication (for example, email, LinkedIn, or phone call), then we may collect any personal or non-personal information provided in or with the communications.
(ii) We process information for the following purposes:
(a) To allow you to make use of our Website. We will use your information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal data to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us; (iii) to analyze your use of our Website and to improve our Website; (iv) to monitor and ensure the security of our Website, (v) for marketing purposes, and (vi) to customize your experience.
(b) To provide you with the Services. We will use the information, including, without limitation, for the following purposes: (i) to create an account; (ii) to provide you the Services and to process your requests; (iii) communicate with you about your use of the Services and for support purposes; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Services, including, updates pertaining to your subscription, and related to the services we provide you with; (vi) to personalize your experience with our Services; (vii) to allow you to create more users and administrate your users; (viii) to generally administer and improve the Services; (ix) remember your preferences and settings; (x) to understand how you use our platform and to improve our Services; (xi) for internal quality control purposes; (xii) to establish a business relationship; and (xiii) to generally administer the Oosto Services.
(c) For Improvement of our Products and Services. Oosto uses information collected from you to improve, enhance, and train our products and Services (e.g., to fix false positive results in our software) and Website.
(d) To Market our Website and Services. Oosto uses information to market the Oosto’s Website and Services. Such use includes (i) sending you promotional materials, updates, newsletters, and offers about the performance, functionality, and other services that may interest you; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Oosto’s services; (v) other purposes disclosed at the time you provide information; (vi) as you otherwise consent; (vii) analyzing the effectiveness of our marketing campaigns and strategies; (viii) using analytics to better understand preferences and interests; (ix) engaging with you on social media platforms; (x) collecting feedback through surveys and other methods to enhance our services and marketing approaches; (xi) sharing information with third-party partners for co-branded marketing efforts or joint promotional activities; (xii) Utilizing third-party data sources to enhance our understanding of your preferences and interests for more effective marketing; and (xiii) Collaborating with affiliate and partner networks to expand our marketing reach and deliver targeted promotions.
(e) Security purposes. Some of the above mentioned information will be used for detecting, taking steps to prevent, and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
(f) De-identified and Aggregated Information Use. In certain cases, we may or will anonymize, aggregate, or de-identify your information and further use it for internal and external purposes, including, without limitation, to analyze and improve Oosto’s Website and Services (including through the use of artificial intelligence) and for research purposes. We will use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
(g) Cookies and Similar Technologies. We use Technologies to automatically collect information through the Website and Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. For further information, visit https://allaboutcookies.org/.
(iii) The lawful bases we rely on for processing personal information are (if and when applicable, for example in the UK):
(a) The data subject has given consent to the processing of his or her personal data;
(b) Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
(c) Processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
(d) Processing is necessary for the purposes of our legitimate interests, and those interests are not overridden by the interests, rights or freedoms of data subjects.
2. CUSTOMER INFORMATION
2.1 Oosto has a contractual relationship with the Customer. In the context of Oosto’s Services, the customer may decide to purchase a license in which Oosto may be exposed to the information that the Customer uploads and shares to the platform (at the customer’s sole discretion), which includes images, videos, recordings, and other kinds of information (such as the watchlist), which in certain countries may be considered Personal Data (“Customer Information”).
2.2 To the extent that Oosto has access to such Customer Information, Oosto is processing the Customer Information on behalf of the applicable customer. Therefore, the customer is the responsible party for the security, integrity, and authorized collection, transfer, usage, and storage of Customer Information in the context of the Services and also for obtaining consents, permissions, and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Information.
2.3 Customer Information is not regulated by this Privacy Notice, and this paragraph is provided only for transparency purposes. If you have any questions related to the Customer Information, please contact the customer directly.
3. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION
3.1 Security. We have implemented and maintain reasonable technical, organizational, and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
3.2 Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, (iii) for internal analysis purposes, for example when the data is used to strengthen the security or to improve the functionality of our Service, (iv) we are legally obligated or allowed to retain this data for longer time periods, and/or (v) if we reasonably believe there is a prospect of litigation relating to your information or dealings.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
We share your information as follows:
4.1 The information Oosto gathers is shared with our partners and other third parties.
4.2 We also share information with our affiliated companies about you.
4.3 We use third party service providers to process your information for the purposes outlined above, including, without limitation:
(i) With cloud service providers for hosting purposes;
(ii) With websites and web content creation platforms in order to help us manage our Website;
(iii) With email providers, marketing, CRM, data enrichment, analytics and business intelligence, other similar tool providers;
(iv) With artificial intelligence tools and features;
(v) With analytic companies, in order to help us understand and analyze information we collect in accordance with this Notice; and
(vi) Payment processors.
4.4 To the extent necessary, with regulators, courts, banks, or competent authorities, to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws), and requests of law enforcement, regulatory, and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Oosto, our Website and Services, customers, employees, property, and the public. We may use or disclose the information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
4.5 We may use or disclose the information we collect in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this Notice, or as otherwise required by law.
4.6 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares, or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose, or assign your information in connection with the foregoing events.
4.7 We may disclose information with our lawyers and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests.
4.8 Where you have otherwise provided your consent to us for sharing or transferring your information.
5. U.S. PRIVACY RIGHTS
5.1 The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals residing in certain U.S. states, including Texas (some of which only apply to individuals protected by specific laws):
(i) You have the right to confirm whether we process your personal information.
(ii) You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
(iii) You have the right to correct inaccuracies in your personal information. We will promptly correct any information found to be inaccurate.
(iv) You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
(v) You have the right to opt-out of personal information processing for: targeted advertising; sales; or profiling in furtherance of decisions that produce legal or similarly significant effects. The personal information we collect is not used for sales, automated decision-making, and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Oosto by contacting Oosto directly or by following the instructions through the unsubscribe options in our email messages.
(vi) You have the right to require consent to process sensitive personal information.
5.2 The exact scope of these rights may vary by state. You or an authorized agent may submit a request. To exercise any of these rights please follow the procedure listed in Section 6. If we deny your rights request, you have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at the information provided in this Privacy Notice.
5.3 You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our Services or limiting the quality of our Services. However, limiting use of, or deleting, your personal information may restrict the purposes or uses that rely on that information.
6. YOUR PRIVACY RIGHTS
The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals outside the United States (some of which only apply to individuals protected by specific laws):
(i) You have the right to withdraw consent to the processing, where consent is the basis of processing.
(ii) You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
(iii) You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
(iv) You have the right to object to unlawful data processing under certain conditions.
(v) You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
(vi) You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
(vii) You have the right to data portability of personal information concerning you that you provided to us in a structured, commonly used, and machine-readable format, subject to certain conditions.
(viii) The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Oosto by contacting Oosto directly or by following the instructions through the unsubscribe options in our email messages.
6.2 You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
6.3 Marketing emails – opt-out: You may choose not to receive marketing emails of this type by sending a single email with the subject “BLOCK” to [email protected]. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.
In order to run our business and provide our Website and Services to you, we transfer personal data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your personal data by implementing at least one of the following safeguards: (i) making sure the destination country has been deemed to provide an adequate level of protection for personal data; and/or (ii) by executing implement data onward transfer instruments such as data processing and protection agreements.
8. USE BY CHILDREN.
We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
9. INTERACTION WITH THIRD PARTY PRODUCTS.
We enable you to interact with third-party websites, mobile software applications, and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
10. ANALYTIC TOOLS/COOKIES
- The Website may use a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Notice, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
- The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see Hotjar’s privacy Notice at https://www.hotjar.com/legal/policies/privacy/. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out/.
- We reserve the right to remove or add new analytic tools, cookies, pixels, and other tracking technologies.
11. OUR CALIFORNIA DO NOT TRACK NOTICE.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.
12. CONTACT US.
If you have any questions, concerns, or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].
