Proactor Privacy Policy

This privacy policy (“Policy”) informs you of our practices when handling your Personal Information through the Services (both as defined below). In this Policy,We are a company registered in Wyoming. Our registered address is: 30 N Gould St Ste R Sheridan, WY 82801.We are the data controller under the applicable privacy laws. This Privacy Policy (“Privacy Policy”) is designed to inform you of our policies and procedures regarding the collection, use, and disclosure of information we receive when you access and use our website (“Website”), services, software, mobile applications, content, and all other products and services that www.proactor.ai (together with its subsidiaries and affiliates, “Proactor.ai,” “we,” “our,” or “us”) directly or indirectly owns, controls, or provides (collectively referred to as “Services”). Proactor.ai values user privacy highly and endeavors to use personal information solely as outlined in this Privacy Policy. By using the Services, you hereby represent and warrant that you have read, understood, and agreed to this Privacy Policy and the Terms of Service, and that you are over the age of 18. If you do not agree with this Privacy Policy, please do not use, install, or access the Services. Please read this Privacy Policy carefully to understand your rights regarding personal information and how we will collect, use, and process your personal information. If you do not agree with this Privacy Policy, our Terms of Service, or any part of them, you should not access or use any part of our Services or otherwise provide your personal information to us. If you change your mind in the future, you must stop using our Services, and you may exercise the rights related to your personal information as outlined in this Privacy Policy. **1. Definition of Personal Information** In this Privacy Policy, “Personal Information” refers to any information that can directly identify you or, when combined with other information, can identify you. For example, your name, email address, and recorded content may all constitute Personal Information. **2. Information We Collect** When you use Proactor.ai’s Services, you may directly provide us with the following information: - **Account Information**: Includes your name, email address, password, and other profile information. - **Usage Information**: Includes feedback, help requests, and preferences you provide while interacting with the Services. - **Recorded Content**: Includes audio recorded through Proactor.ai in various scenarios, text generated from real-time transcription, AI-generated summaries, key takeaways, and to-do lists. - **Payment Information**: When you use paid Services, we may collect payment information (limited to non-PCI payment data). - **User Content**: We collect personal data (“Content”) that you provide when you input information into our Services, including content you upload, such as files and images, depending on the features you use. - **Other Information You Provide**: If you are a customer, vendor, or prospective customer, we may process limited Personal Information in the context of our business relationship with you, such as when you place an order, request a demo, participate in our events or surveys, or provide information to verify your identity or age (collectively, “Other Information You Provide”). Such Personal Information may include your name, company, job title, email address, phone number, address, order details, and applicable credit registration and credit limits. When you use our Services, Proactor.ai may automatically collect certain technical information, including: - **Device Information**: Such as your device type, operating system, browser type, and unique device identifiers (e.g., IP address). - **Log Data**: We collect information your browser or device automatically sends when using our Services, including your Internet Protocol address, browser type and settings, request date and time, and how you interact with our Services. - **Usage Data**: We collect information about your use of the Services, such as the type of content you view or engage with, the features you use, actions taken, and your time zone, country, access dates and times, user agent and version, type of computer or mobile device, and computer connection. - **Network and Browsing Information**: Including pages you visit, visit duration, clickstream data, and more. - **Cookies and Tracking Technologies**: Used to identify your device, analyze Service usage, and enhance user experience. You may control cookies through your browser settings, though disabling them may impact certain functionalities. - **Network and Internet Information**: Including but not limited to URLs, Internet Protocol addresses, bounce rates, deceptive usage, active (TCP/IP) ports, session initiation numbers, clickstream, location information, and network/Wi-Fi access points. **3. How We Use Cookies and Similar Technologies** We may use various tracking technologies on the Website, such as cookies, web beacons, and local shared objects. These technologies may collect information about your device, browsing habits, and Website usage, including your browser type, search preferences, and information about ads displayed to or clicked by you. This information enables us to continually improve our Services. However, you may choose to disable some of these technologies through settings on your device or browser, though this may affect your ability to fully utilize the Website. Note that these technologies may include unique identifiers stored on your device or in emails we send you. We are committed to protecting your privacy and will only use this information in compliance with applicable laws and regulations. **4. How We Use the Information We Collect** Proactor.ai may use your information for the following purposes: - **Account Setup**: We use your registration information, device information, and information received from third parties (such as your username, email address) to set up your account so you can use our services. We do this based on our contract and pre-contractual obligations to provide you with an account to use the services. - **Provide Services**: We use the content of real-time recordings to provide you with personalized AI advice, key takeaways, to-do lists, and other services. - **Improve Services**: We use information automatically collected or generated when you use the service, as well as information about your device, such as the device manufacturer, model, operating system, and available storage space on the device, to analyze service usage and improve our services. We train our proprietary AI technology on de-identified recordings. We also train our technology on transcriptions to provide more accurate services, which may include personal information. This helps us improve and develop our services and conduct research, such as developing new product features. - **User Account Management**: Used to verify your identity, manage your account, and provide enhanced security features. - **AI Memory Feature**: In appropriate scenarios, AI may use previous recording content to provide accurate follow-up responses. - **Internal Analytics**: Analyzing user behavior and usage patterns to optimize service features and user experience. - **Prevent Fraud, Illegal Activities, or Abuse**: To ensure the security of our systems and services and prevent fraud or misuse of our services. - **Marketing and Communication**: With your consent, we may send you service updates, promotional activities, and other information. - **Legal Requirements**: To comply with legal obligations or respond to requests from law enforcement, we may use or share information as necessary. **5. Third Parties with Whom We Share Personal Information** We may disclose Personal Information provided by you or collected automatically on the Website or through our Services to the following third-party categories, where necessary and in compliance with applicable laws and regulations: - **Other users** who see your Personal Information (such as your username and email) and any other information you choose to share with them through the Services. - **Cloud service providers** who we rely on for compute and data storage, including Amazon Web Services, based in the United States. - **Service Providers**: Such as payment processors, web hosting, and data storage providers who assist us in delivering and developing the Services. - **Data labeling service providers** who provide annotation services and use the data we share to create training and evaluation data for Proactor’s product features. - **Artificial intelligence service providers** that provide backend support for certain Proactor product features. - **Analytics providers** who provide analytics, segmentation and mobile measurement services and help us understand our user base. We work with a number of analytics providers, including Google LLC, which is based in the U.S. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. - **Payment processors**, such as Stripe. These payment processors are responsible for the processing of your Personal Information, and may use your Personal Information for their own purposes in accordance with their privacy policies. More information is available here: https://stripe.com/gb/privacy. - **Public Authorities**: Such as law enforcement, if legally required or necessary to protect our or third parties’ rights. - **Our Subsidiaries and Affiliates**, or any subsequent owners, co-owners, or operators of our Website and/or Services, and their advisors in connection with corporate mergers, acquisitions, reorganizations, or sales of substantially all of our stock and/or assets, or bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy. We are committed to protecting user privacy and will only disclose Personal Information to third parties when necessary and in compliance with relevant laws and regulations. We will also enforce strict contractual and data processing agreements with third parties to ensure they only use Personal Information for the specific purposes outlined by us and to safeguard the privacy and security of any Personal Information they receive. **6. Links to Other Websites** Occasionally, the Services may link to external websites. These websites may contain offers and promotions from third parties. We provide these links to help you find information, products, or services that may be useful or of interest to you. We are not responsible for the content on these websites or what they offer, nor can we guarantee these websites will always function properly. The presence of links to other sites does not imply endorsement or partnership with those who operate or promote these websites. The terms and conditions and privacy policies of any website controlled, owned, or operated by third parties will tell you how to use that website. Using these sites operated by others is at your own risk. Proactor.ai expressly disclaims any responsibility for anything that may occur due to your use of or viewing of websites or other content linked in the Services. You agree that Proactor.ai is not responsible for any possible occurrences if you click on links within the Services. **7. User Control and Privacy Management** Proactor.ai provides various ways for you to manage your privacy rights: - **Accessing and Modifying Information**: You may access, update, or delete your account information and personal data, or request us to delete or update your information by contacting us. - **Recording Management**: You have the ability to delete past recording content. - **Privacy Requests**: You can submit requests regarding access, deletion, or restriction of processing of personal information by contacting us. **8. Security Measures** We understand the importance of privacy and security of personal information to our users and have prioritized it. We implement commercially reasonable technical, managerial, and organizational measures aimed at protecting personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or email transmission is fully secure or error-free. Therefore, you should take particular care when deciding what information to send to the Services. Additionally, we assume no responsibility for any attempts to circumvent any privacy settings or security measures on the Services or third-party websites. **9. Your Rights** In certain circumstances, you have the following rights regarding the personal information we hold about you: - **Access**: You have the right to access the personal information we hold about you and to obtain an explanation of how we use this information and with whom we share it. - **Correction**: You have the right to correct any inaccurate or incomplete personal information we hold about you. - **Deletion**: You have the right to request the deletion or removal of your personal information. - **Objection to Processing**: When we rely on legitimate interests or process your personal information for direct marketing purposes, you have the right to object to the processing of your personal information. - **Restriction of Processing**: In certain circumstances, you have the right to block us from processing your personal information, except for storage purposes. - **Withdrawal of Consent**: You have the right to withdraw any consent you have previously given to us. We will apply your preferences going forward, but this will not affect the legality of processing based on your consent before its withdrawal. Please note that before responding to any request to exercise these rights, we will ask you to verify your identity. Additionally, we may need further information (for example, why you believe the information we hold about you is inaccurate or incomplete) and there may be valid legal reasons for us to deny your request. If this is the case, we will notify you. We encourage you to first contact us by email, so we have an opportunity to resolve your issue directly before you take further steps. **10. California Residents** Section 1798.83 of the California Civil Code requires certain businesses that share customer personal information with third parties for direct marketing by the third party to respond to California customer inquiries regarding such practices. We currently do not share or disclose your personal information with third parties for direct marketing. If we change this practice, we will implement an opt-out policy as required by California law. Additionally, except for certain exemptions, California residents have the following rights concerning personal information we may collect about them: - **Right to Know**: You have the right to request that we disclose: - The categories of personal information we collect about you. - The categories of personal information we sold or disclosed for a business purpose. - The categories of sources from which we collect personal information about you. - The business or commercial purposes for collecting or selling your personal information. - The categories of personal information that were sold or disclosed, if any, and the categories of third parties to whom personal information was sold (by category of personal information for each party who sold personal information). - Specific pieces of personal information we have collected about you. You may submit a request to know using one of the methods described in “Methods for Submitting Consumer Requests and Our Responses to Requests” below. Our response may be delivered electronically or by mail. Within 12 months, we are only required to respond to two requests to know. We do not sell, and have not in the past 12 months sold, personal information about California residents. Therefore, we have not included a “Do Not Sell My Personal Information” link on our website. If our practices change, we will update this Privacy Policy and take any additional steps needed to comply with applicable laws. However, we do disclose personal information for business purposes, as described in the section titled “Third Parties with Whom We Share Personal Information” above. - **Right to Deletion**: You have the right to request that we delete any personal information we have collected about you. Upon receiving a verified request for deletion of personal information, we will do so unless otherwise required or permitted by law. You may submit a request for deletion using one of the methods described in “Methods for Submitting Consumer Requests and Our Responses to Requests” below. - **Authorized Agent**: You may designate an authorized agent to make a request on your behalf. You must provide the authorized agent with written permission to submit the request on your behalf, and we may require you to verify your identity directly with us. Alternatively, an authorized agent authorized under the Probate Code sections 4000-4465 may submit a request on your behalf. **Methods for Submitting Consumer Requests and Our Responses to Requests** You can submit access and deletion requests about your personal information by: - Sending an email to proactorai@gmail.com with the subject line “Personal Information Request.” After receiving your request, we may ask for additional information to verify your identity. Any additional information you provide will be used solely for identity verification purposes and not for any other purpose. We will confirm receipt of your request within 10 days of receipt. Depending on our ability to verify your identity, we will respond to your request within 45 days of receipt. If we need additional time (up to 90 days), we will notify you in writing with the reason and extension period. To protect your privacy and the security of your personal information, we may verify your request by requiring account verification or identity information submission (e.g., a driver’s license or other photo identification). Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. Our response will also explain any reasons we cannot comply with the request (if applicable). We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine a request warrants a fee, we will explain why we made that decision and provide a cost estimate before completing your request. - **Right to Non-Discrimination**: You have the right not to be discriminated against for exercising your California privacy rights. Unless permitted by the CCPA, we will not: - Deny you goods or services. - Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. - Provide you with a different level or quality of goods or services. - Suggest that you may receive different prices or rates for goods or services or a different level or quality of goods or services. **11. International Transfer of Personal Information** Proactor.ai is based in the United States. Therefore, personal information collected on the Services and Website may be transferred to our offices in the United States. Additionally, we may partner with third-party service providers in the United States and other countries to support our business operations. Consequently, personal information may be transferred to and stored on servers located outside the country or region where the information was originally collected and may be accessed from those countries. In all such cases, we use, transfer, and disclose personal information solely for the purposes described in this Privacy Policy and in compliance with applicable laws. #### Transfer Responsibilities: - **Transfer to Third-Party Controllers**: When transferring personal information to a third party acting as a controller, Proactor.ai may establish contractual agreements to ensure data is processed solely for limited and specific purposes consistent with individual consent. Such contracts may stipulate that the recipient provides a level of protection consistent with Proactor.ai policies and that, should the third party determine it can no longer fulfill this obligation, it must notify Proactor.ai. Following such a determination, the third-party controller may cease processing or take other reasonable and appropriate measures to remediate the issue. - **Transfer to Third-Party Agents**: When transferring personal information to a third party acting as an agent, Proactor.ai may: (i) transfer such data only for limited and specific purposes; (ii) ensure the agent is obligated to provide at least the same level of privacy protection; (iii) take reasonable steps to ensure effective processing consistent with Proactor.ai obligations; (iv) require the agent to notify Proactor.ai if the agent determines it can no longer provide the same level of protection; (v) upon receiving such notice, take reasonable steps to stop and remediate unauthorized processing; and (vi) provide relevant privacy terms upon request within the contract with the agent. #### Choices: - **Opt-Out Mechanism**: Proactor.ai may provide individuals with the opportunity to opt out of having their personal information disclosed to a third party or used for purposes that are materially different from the purpose originally collected or subsequently authorized by the individual. An opt-out mechanism should be provided, although such mechanisms may not always be applicable. - **Exceptions**: When disclosing to a third party acting as an agent per Proactor.ai instructions, opting out may not be required. However, Proactor.ai will generally enter into contracts with such agents. - **Opt-In for Sensitive Information**: For sensitive information, Proactor.ai may obtain the individual’s explicit consent (opt-in) before disclosing it to a third party or using it for purposes other than those originally collected or subsequently authorized. Additionally, Proactor.ai may treat any personal information received from third parties as sensitive information as long as it is identified and treated as such. **12. Payment Information** Proactor.ai uses third-party payment processors (such as Stripe) to process payments. Your credit card details are transmitted directly from your browser to these payment processors. Proactor.ai will only see the type of payment card, the last four digits of your credit or debit card number, and the billing address. Please refer to Stripe's Terms of Service and Privacy Policy for more information on how they use and store your personal information. **13. Children's Privacy** We do not knowingly collect, retain, or use personal information from children under the age of 18, and no part of our Services is directed toward children. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us so that we can delete such information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information on our Website and/or Services without permission. If you discover that a child under the age of 18 has provided us with personal information in violation of this Privacy Policy, you may alert us at proactorai@gmail.com. We will take reasonable steps to delete that information as promptly as possible. **14. Deleting Your Account or Raising Questions** You may delete your Proactor.ai account at any time from your account settings. If you cease using our Services, your account and associated personal information will be retained unless you actively delete the account from the account settings. If we receive a request to delete an account, we will make commercially reasonable efforts to delete your records and personal information within 30 days of the request, although we cannot guarantee deletion will always occur within this timeframe. However, if applicable law requires us to retain that information, we will do so in compliance with the “Data Retention” section above, and we will take steps to pseudonymize it. **15. Cross-Border Data Transfers** To facilitate our global operations, Proactor.ai may transfer, store, and process your information outside your country of residence with partners and service providers. The laws of these countries may differ from the applicable laws in your country of residence. When we transfer, store, and process your personal information outside the European Economic Area or the United Kingdom, we ensure that appropriate safeguards are in place to provide a sufficient level of protection, such as by adhering to standard contractual clauses. For more information on the relevant safeguards, please contact us. **16. Data Retention** We regularly review and enhance our security and privacy policies. As we update and expand our Services, this Privacy Policy may change. We will strive to notify you of these changes by email; however, we disclaim any liability if notification is not provided. We also encourage you to periodically review this Privacy Policy. Your continued use of the Services after any changes to this Privacy Policy will indicate your acceptance of those changes. **17. Contact Us** If you have any concerns or questions regarding this Privacy Policy, please contact us at proactorai@gmail.com. ### APPENDIX Proactor.ai has created this Data Privacy Framework Principles Notice (“Notice”) to describe our standards and procedures for handling Personal Information in accordance with the Data Privacy Framework (“DPF”) Principles. This Notice supplements our Policy. Unless specifically defined in this Notice, the terms in this Notice have the same meaning as in our Policy. In case of conflict between the Policy and this Notice, this Notice prevails. In case of conflict between this Notice and the Principles, the Principles will govern. #### How we obtain Personal Information We obtain and Process Personal Information from the European Union (“EU”), United Kingdom (“UK”) (and Gibraltar), or Switzerland in different capacities: - As a data controller, we collect and Process EU, UK and Swiss Personal Information directly from individuals, either via our publicly available website https://Proactor.ai and www.proactor.ai or through our mobile applications, or in connection with our customer relationships. - Where we provide our Services in connection with an enterprise agreement, we may obtain and process EU, UK, and Swiss Personal Information on behalf of and at the instructions of our enterprise customers. In that context, such customers are the data controllers and we encourage you to read their privacy policies. Proactor.ai commits to subject to the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”), all Personal Information received from the EU, the UK (and Gibraltar), or Switzerland in reliance on the DPF Principles (which includes both types of activities). #### Data Privacy Framework Principles 1. Notice. Our Policy in combination with this Notice describes our privacy practices. When providing our Services as a Data Processor, our customers determine the categories of Personal Information we Process and the purposes of the processing. Accordingly, our customers are responsible for providing notice to individuals. Please see our customers’ privacy policies for more information. 2. Data Integrity and Purpose Limitation. Any Personal Information we receive may be processed by Proactor.ai for the purposes indicated in our Policy or as otherwise notified to you. We will not process Personal Information in a way that is incompatible with these purposes unless subsequently authorized by you. We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. Individuals are encouraged to keep their Personal Information with Proactor.ai up to date and may contact Proactor.ai as indicated below or in the Policy to request that their Personal Information be updated or corrected. We will adhere to the DPF Principles for as long as we retain the Personal Information collected under DPF Principles. When providing our Services as a data processor, we process and retain Personal Information as necessary to provide our Services as permitted in our agreements, or as required or permitted under applicable law. 3. Accountability for Onward Transfer of Personal Information. Proactor.ai may transfer Personal Information as described in the Policy. When providing our Services as a data processor, we disclose Personal Information as provided in our agreement with customers. We remain responsible for the processing of Personal Information received under the DPF Principles and subsequently transferred to a third party acting as an agent if the agent Processes such Personal Information in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage. 4. Security. Proactor.ai takes reasonable and appropriate precautions, taking into account the risks involved in the Processing and the nature of the Personal Information, to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. 5. Access and Choice. If we intend to use your Personal Information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if we intend to disclose it to a third party acting as a Data Controller not previously identified, we will offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt in where sensitive information is involved. Where appropriate, you have the right to access to the Personal Information we maintain about you and to correct, amend or delete that information when it is inaccurate or has been processed in violation of the DPF Principles by sending a written request as indicated in “Contact Us” below. We will review your request in accordance with the DPF Principles, and may limit or deny access to Personal Information as permitted by the DPF Principles. When providing our Services as a Data Processor, we only Process and disclose the Personal Information as specified in our agreements. Our customers control how Personal Information is disclosed to us and Processed, and how it can be modified. Accordingly, if you want to request access, or to limit use or disclosure of your Personal Information, please contact the company to whom you submitted your Personal Information and that uses our Services. If you provide us with the name of the company to whom you provided your Personal Information and who is our customer, we will refer your request to that customer and support them in responding to your request. 6. Recourse, Enforcement and Liability. We conduct an annual self-assessment of our practices regarding Personal Information intended to verify that the assertions we make about our practices are true and that such practices have been implemented as represented. If you have any questions or concerns, we encourage you to first write to us as indicated below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the DPF Principles. **Contact Us** If you have any questions, concerns or complaints regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us:proactorai@gmail.com.