BESPO.AI PRIVACY POLICY
Last Updated: February 18, 2024
In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, BespoAI Inc. (together, “BespoAI”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) when you make use of, or interact with, our mobile software application (the “App”).
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 Policy carefully, so you can fully understand our practices in relation to personal information. “Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.
Table of contents:
1. What personal information we collect, why we collect it, and how it is used
2. How we protect and retain your personal information
3. How we share your personal information
4. Additional information regarding transfers of personal information
5. Your privacy rights
6. Use by children
7. Interaction with third party products
8. Analytic tools/ Cookies
9. Contact us
Great content inspires, provides insight, and makes us feel. It’s central to the human experience.
We celebrate the uniqueness of people by creating technologies that make the best bespoke content, for each individual. We believe that the next leap in content will be done by algorithms, so we strive to build the best ones by taking big technical swings, guided by products and users.
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. 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 App 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
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Personal information we collect |
Why is the personal information collected and for what purposes? |
Legal basis (GDPR only, if applicable) |
Third parties with whom we share your personal information |
Consequences of not providing the personal information |
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When you make use of, or interact with, our App |
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When you access your account |
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● Email address ● Password ● Phone number |
● To allow you to access the App ● To provide you with the services ● To verify your identity |
● Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject before entering into a contract. ● Legitimate interest (e.g. to allow you to access the App) |
● GCP ● AWS |
● Cannot allow you to access the App ● Cannot provide you with the services ● Cannot verify your identity |
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When an account or profile is created by you |
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● Email address ● Password ● Full name ● Phone Number (optional)
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● To create your account on our App ● To provide you with the services |
● Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject before entering into a contract. ● Legitimate interest (e.g. to create your account) |
● GCP ● AWS |
● Cannot create your account ● Cannot provide you with the services |
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When you make use of the App |
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● Your actions with the App, such as: o topics of interest that you choose o search queries o creations o browsing and streaming history o your library ● inferences (such as our understanding of your interests and preferences based on your App usage) |
● To optimize the results of the App suggestions and/or other services ● To personalize your account |
● Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject before entering into a contract. |
● GCP ● Mongodb ● AWS ● Mixpanel |
● Cannot optimize the results of the App suggestions and/or other services ● Cannot personalize your account |
Finally, please note that some of the abovementioned personal information will
be used for detecting, taking steps to prevent, and prosecution of fraud or
other illegal activity, to identify and repair errors, to conduct audits, and
for security purposes. Personal 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. In certain cases, we may or will anonymize or
de-identify your personal information and
further use it for internal and external purposes, including, without
limitation, to improve the services and for research purposes. “Anonymous
Information” means information which does not enable identification of an
individual user, such as aggregated information about the use of our services.
We may use Anonymous Information and/or disclose it to third parties without
restrictions (for example, in order to improve our services and enhance your
experience with them).
2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION
2.1. 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 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.
2.2. 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, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We share your information as follows:
3.1. The information BespoAI gathers is shared with our partners and other third parties.
3.2. We also share information with our affiliated companies about you.
3.3. We use third party service providers to process your information for the purposes outlined above, including, without limitation:
3.3.1. With cloud service providers for hosting purposes;
3.3.2. With app content creation platforms in order to help us manage our App;
3.3.3. With email providers, marketing, CRM, other similar tool providers;
3.3.4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy; and
3.4. 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 BespoAI, our App, customers, employees, property, and the public.
3.5. 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.
3.6. Where you have otherwise provided your consent to us for sharing or transferring your information.
4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
4.1. Internal transfers: Transfers within the BespoAI group will be covered by an internal processing agreement entered into by members of the BespoAI group (an intra-group data processing agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred to.
4.2. External transfers: Where we transfer your personal information outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your personal information.
4.3. Transfer mechanisms: When BespoAI engages transfers of personal information, it relies on Adequacy Decisions adopted by the European Commission based on Article 45 of the GDPR (for example, when we access personal information from Israel), Standard Contractual Clauses laid down by the European Commission, or any other approved transfer mechanism. BespoAI continually monitors the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the level of protection guaranteed by the GDPR.
5. YOUR PRIVACY RIGHTS
5.1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
5.2. You can exercise your rights by contacting us at privacy@bespo.ai. 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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.3. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@bespo.ai. If you terminate your account, any association between your account and personal information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
5.4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@bespo.ai. 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.
6. 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 privacy@bespo.ai.
7. 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.
8. ANALYTIC TOOLS/COOKIES. We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.
9. 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 privacy@bespo.ai.
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