Privacy Policy

Last Updated [9/07/2017]

Welcome, and thank you for your interest in VoiceBase, Inc. (“VoiceBase”), and the VoiceBase Service, as described in the VoiceBase Terms of Use. This Privacy Policy is incorporated into and is subject to the VoiceBase Terms of Use.

This Privacy Policy describes what information we gather from you, how we use and disclose that information, and what we do to protect it. By using the VoiceBase Service, you expressly consent to the information handling practices described in this policy.

Privacy Shield:

Voicebase’s participation in the Privacy Shield applies to all personal data that is sent to the EU instance of the Voicebase API and is received from the European Union, European Economic Area, and Switzerland.

VoiceBase complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. VoiceBase has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this 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 page, please visit https://www.privacyshield.gov/

Voicebase’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Voicebase remains responsible and liable under the Privacy Shield Principles if a third-party agent that it engages to processes the personal data on its behalf do so in a manner inconsistent with the Principles, unless Voicebase proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, VoiceBase commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VoiceBase at: eu-privacy@voicebase.com

Voicebase has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

As further explained in the Privacy Shield Principles, a binding arbitration option may also be made available to you in order to address residual complaints not resolved by any other means. Voicebase is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Information Collection:

VoiceBase is committed to providing you with notice and choice regarding the information we collect and how we use and share that information. Through our VoiceBase Service, we may collect the following information about you:

• User-Provided Information: You may provide to VoiceBase what is generally called “personally identifiable” information or “personal information” (such as your name, e-mail address, postal mailing address, home/mobile telephone number, payment account information, or demographic information) when using the VoiceBase Service, such as when you register for the site, create a profile, upload recordings, or interact with other users of the VoiceBase Service through communication features such as posting comments. We refer to this information as “Personal Data.”

We do not generally collect “sensitive” Personal Data, including Personal Data about personality and private life, racial or ethnic origin, nationality, political opinions, membership of political parties or movements, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, genetic code, addictions, sexual life, property matters or criminal record (including information about suspected criminal activities). You are not required to provide any Sensitive Personal Data to use any of our services.

If you choose to provide us with unsolicited sensitive Personal Data, you consent to our using such data subject to applicable law as described in this Privacy Policy. For sensitive Personal Data, VoiceBase aims to give individuals the opportunity to provide affirmative and express (opt-in) consent to the disclosure of the data to a non-agent third party or to the use of the data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Sensitive Personal Data is also afforded all protections we provide to Personal Data generally.

• Cookies and other Automatically Collected Information: When you use the VoiceBase Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. VoiceBase may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the VoiceBase Service. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the VoiceBase Service, you may not be able to utilize the features of the VoiceBase Service to their fullest potential.

When you use the VoiceBase Service or open one of our HTML emails, we may automatically record certain information from your web browser by using different types of technology, including standard log files, “clear gifs” or “web beacons.” This “automatically collected” information may include your Internet Protocol address (“IP Address”) or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after the VoiceBase Service, the pages you view on the VoiceBase Service, and the dates and times that you visit the VoiceBase Service.

• Information from Other Sources: We may also obtain information, including Personal Data, from third parties and sources other than the VoiceBase Service, such as advertisers. If we combine or associate information from other sources with Personal Data that we collect through the VoiceBase Service, we will treat the combined information as Personal Data in accordance with this Privacy Policy.

• Collection by Third Parties: In addition to the data VoiceBase collects on its own behalf, VoiceBase may make it possible for third parties to collect certain technical data about you. For instance, we may also implement third party content, such as advertising, on the VoiceBase service that uses “clear gifs” or “web beacons”, which allow the third party content provider to read and write cookies to your browser in connection with your viewing of that third party content displayed on the VoiceBase Service. This information is collected directly by the third party, and VoiceBase does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s own data collection, use, and disclosure policies.

Information Use:

VoiceBase uses the information you provide or that we collect to develop, operate, maintain, enhance, and provide all of the features and services found on the VoiceBase Service now and in the future. We adhere to the data protection principle of “data integrity” and will take reasonable steps to ensure that all Personal Data we collect, retain, or use is relevant to its intended use, accurate, complete, and current.

We will use your email address to contact you for administrative purposes, for customer service purposes, to address intellectual property infringement, rights of privacy, or defamation issues, or regarding User Submissions that you have posted to the VoiceBase Service.

VoiceBase uses the information that you provide or that we collect to understand and analyze the usage trends and preferences of our users, to improve the way the VoiceBase Service works and looks, and to create new features and functionality.

VoiceBase may use automatically collected information and cookies to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use the VoiceBase Service; (b) provide customized third party advertisements, content, and information; (c) monitor and analyze the effectiveness of the VoiceBase Service and third party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities.

VoiceBase may use your email address or other Personal Data to send i) messages about the VoiceBase Service, such as when you receive a message, comment, or request from another user, ii) promotional messages related to the VoiceBase Service and the activities of third parties we work with, and iii) messages on behalf of other users who think you may be interested in the VoiceBase Service or certain content available on the VoiceBase Service. Generally, you have the ability to opt-out of receiving any such communications, either through links provided in the messages, or by updating your account preferences through the VoiceBase Service.

Information Disclosure and Onward Transfer:

Our users’ privacy is very important to us, and we are not in the business of selling Personal Data. We do, however, disclose Personal Data about you in a variety of circumstances in connection with developing and maintaining the VoiceBase Service and operating our business, or in circumstances where you explicitly permit or request that we transfer information.

For example:

VoiceBase works with third party service providers in the U.S. and other jurisdictions to provide website development, hosting, maintenance, transcription, and support as well as other business services for us. To the extent it is necessary for these service providers to complete their work, these third parties may have access to or process Personal Data about you. These disclosures are generally made under terms comparable to this policy, and the recipients are limited to using the information the purpose for which it was provided.

The VoiceBase Service enables users to communicate in a variety of ways. Any Personal Data that you voluntarily choose to include in a publicly accessible area on the VoiceBase Service, such as a recording that you upload and share, your public profile page or in a comment, posting or other User Submission, will be available to other users who access that content. Once you make Personal Data available to others any of these ways, it may be collected and used by the recipients without restriction.

VoiceBase may disclose automatically collected and other aggregate non-personally-identifiable information with interested third parties, to assist such parties in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on the VoiceBase Service.

VoiceBase may also disclose information if required to do so by law or in the good-faith belief that such action is necessary or useful to comply with state and federal laws (such as U.S. Copyright law), to respond to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.

VoiceBase works to promote a safe and reliable service for all users. We reserve the right to disclose information that we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect VoiceBase and others from fraudulent, abusive, predatory, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the VoiceBase Service; or to protect or vindicate the rights, property, or personal safety of VoiceBase, our users, or others.

We reserve the right to disclose, transfer or assign information about our users, including Personal Data, to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Personal Data Access and Correction:

You may, of course, decline to share certain Personal Data with VoiceBase, in which case VoiceBase may not be able to provide to you some or all of the features and functionality found on the VoiceBase Service. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the VoiceBase Service. Please note that while your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. Please note also that once you have publicly shared information, it may be re-shared by other users, and your subsequent modification or removal of that information will not necessarily affect all copies previously propagated by others.

To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Third Party Services:

The VoiceBase Service contains links to Web sites and services provided by third parties. Any Personal Data you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies, if any, governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on the VoiceBase Service. We encourage you to learn about third parties privacy and security policies before providing them with Personal Data.

Our Commitment to Data Security:

VoiceBase employs certain physical, managerial, and technical safeguards to help protect the integrity and security of Personal Data. We cannot, however, ensure or warrant the security of any information you transmit to VoiceBase, and you do so at your own risk. Please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If VoiceBase learns of a data security incident affecting Personal Data, then we may attempt to notify you electronically so that you can take appropriate protective steps. VoiceBase may post a notice through the VoiceBase Service if a security breach occurs.

International Visitors:

The VoiceBase US Instance processes and stores data within the United States. The VoiceBase EU Instance processes and stores data within the EU. If you choose to use the VoiceBase US Service from the European Union or other regions of the world, then please note that you may be transferring Personal Data outside of those regions to the United States for storage and processing and by providing Personal Data to VoiceBase you consent to that transfer, storage, and processing.

Enforcement:

VoiceBase may conduct compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy. Any employee that VoiceBase determines is in violation of this Privacy Policy may be subject to disciplinary action up to and including termination of employment.

Dispute Resolution:

Questions or concerns regarding the use or disclosure of Personal Data should be directed to VoiceBase at the address given below. VoiceBase will investigate and attempt to resolve disputes regarding use and disclosure of Personal Data by reference to the principles contained in this Privacy Policy.
If you are unsatisfied with the way we have responded to any concerns about our handling of Personal Data, the matter may be dealt with through the U.S. Council for International Business (USCIB). Additionally, VoiceBase’s compliance with this Privacy Statement is regulated at a federal level in part by the U.S. Federal Trade Commission.

Your California Privacy Rights:

A business subject to California Civil Code section 1798.83 is required to disclose to its customers, upon request, the identity of any third parties to whom the business has disclosed “personal information” regarding that customer within the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing via email to: [Privacy@voicebase.com]. Please note that California businesses are only required to respond to a customer request once during the course of any calendar year.

Changes and Updates to this Privacy Policy:

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which may be revised from time to time at VoiceBase sole discretion, as provided in the VoiceBase Terms of Use. If we modify the Privacy Policy, we will make it available through the VoiceBase Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the VoiceBase Service for the first time after such material changes are made. Our amended Privacy Policy will automatically take effect 30 days after it is made available through the VoiceBase Service, except that (i) we will not, without your consent, use previously collected Personal Data in a manner inconsistent Privacy Policy in effect when we received that information, and (ii) if you do not agree with any changes to the Privacy Policy, you may terminate your account ceasing use of the VoiceBase Service. Your continued use of the VoiceBase Service after revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.

Contact Us:

Please contact VoiceBase with any questions or comments about this Privacy Policy, Personal Data we hold that relates to you, our collection, use and disclosure practices, or your choices regarding your Personal Data by email: [Privacy@voicebase.com].

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