Privacy Policy
Introduction
ambient provides access to a network and community of experts, entrepreneurs, clients and like-minded users (the “Network”), allowing them to seek and provide support, learnings, insights, reviews, guidance and introductions to and from one another. ambient also provides technology and services that support the Network, including member verification, matching and artificial intelligence, machine learning, large language models and other automated and generative technologies (“AI Tools”) (the AI Tools together with the Network, the “Platform”).
This Privacy Policy (the “Policy”) describes how we collect, store, use, transfer, share and otherwise process the Personal Information of our users, visitors and business partners, other individuals who interact with us, and individuals whose Personal Information we obtain from publicly available records or third-party sources (“you” or the “User”), in connection with the Platform, including all related domains, subdomains, products and services (together the “Platform” or the “Services”). This Policy forms part of our Terms of Service (the “Terms”), available at textambient.com/
This Policy does not apply to Third-Party Services (as defined in the Terms), including third-party websites, platforms, add-ons, products, services, integrations and applications that we do not own or control, even if they link to or from the Platform or you choose to integrate or enable them for use with the Platform. Personal Information you share with Third-Party Services is governed by the privacy policies and terms of their providers, which we encourage you to review.
“Personal Information” means any information relating to an identified or identifiable natural person, as defined under Regulation (EU) 2016/679 (“GDPR”), the UK Data Protection Act 2018 (“UK Data Act”), the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and other applicable privacy laws (the GDPR, the UK Data Act, the CCPA, the VCDPA and any other applicable data protection laws, in each case to the extent applicable, the “Law”).
The controller is Glow Tech, Inc., a Delaware corporation with its principal place of business at 115 East 23rd Street, New York, NY 10010 (“ambient”, “we” or “us”).
If you have any questions about this Policy or wish to exercise any of your rights under this Policy or the Law, please contact us at legal@textambient.com.
By using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Platform.
This Policy describes, among other things:
- what Personal Information we collect from you;
- the purposes for which we collect and use your Personal Information;
- the grounds on which the processing is carried out;
- how we use AI Tools;
- how long we process and store Personal Information;
- your rights and how to exercise them;
- to whom we may disclose your Personal Information;
- the countries to which we may transfer your Personal Information.
Personal Information we collect
The table below describes the Personal Information we collect:
| Categories of Personal Information | Category description |
|---|---|
| User Data | This is Personal Information that you provide when you create an account or profile and use the Platform, or that we obtain or generate in connection with providing the Platform to you (“User Data”). It includes, without limitation: Account information: your phone number and the texts you send to and receive from ambient, including your sign-up text, in which you confirm that you are at least eighteen (18) years old and accept the Terms and this Policy; and, from LinkedIn sign-in, your name, the email address on the account and an identifier for the account. Profile and professional information: the information described in the Terms as User Information, such as your biographical information, contact details, job title, employer, professional background, work and education history, skills and qualifications, certifications and licenses, professional accomplishments, areas of expertise and specialized knowledge, links to your professional social media profiles (such as LinkedIn), location, time zone and availability. Participation data: information about your activity in the Network, including the Contributions you request, accept, provide or receive, the topics, needs and requirements you describe when requesting Learnings, recordings or reports of Contributions, metrics related to your Contributions, Lev, feedback, your willingness to take part in Contributions and how you respond to Contribution opportunities. AI-derived data: outputs generated by the AI Tools about you, such as match scores, rankings, screening evaluations and summaries of your interactions and Contributions. Conflicts and compliance information: information you give us about conflicts of interest or other restrictions affecting your participation in Contributions, as required under the Terms, such as relationships with competitors or with current or former employers. Other information you provide: information associated with your interactions with the Platform, including your use of the AI Tools and your communications with our support team. |
| User Content and Generated Content | This is the content you submit to or exchange through the Platform (“User Content”), including your Materials (such as pitch decks, presentations, documents and other files), the Learnings you provide or receive in Contributions (including messages, written responses, reports, annotations and audio or video consultations), and your requests to and other interactions with the AI Tools. It also includes the content generated by the AI Tools from User Content and other information available on the Platform, such as matches, summaries, transcripts and responses (“Generated Content”). |
| Publicly Available and Third-Party Data | This is Personal Information that is available from public sources, such as publicly accessible websites, official registers and records, professional networking platforms (where your profile is publicly visible) and public announcements or media reports, as well as Personal Information we receive from third-party data sources, including data enrichment providers that compile information from public sources, business contact data providers, our partners and our affiliates. It may include your professional profile information and identifiers, employment history, company affiliations, contact details and publicly stated areas of expertise. We use this information, among other things, to verify that you are a founder, to match you well (for example, to avoid matching you with your own company or a recent employer), and to invite prospective users to join the Network. We do not license or resell this information to other organizations. |
| Online Identification Data | This is Personal Information that is collected automatically when you access, visit or use the Platform, including through cookies and similar technologies. It may include URL information, your IP address, server domain, the type of device, operating system and browser you use to access the Services (including browser version, settings, plug-ins and language preferences), your approximate location, the content, users, features and links you view or interact with, your search history and web page interactions on the Platform, and the types of files you share. Where applicable, these technologies help us recognize you, customize or personalize your experience, measure our marketing and analyze how the Services are used. For more details about how we use these technologies and your cookie controls, please see our Cookie Policy, available at textambient.com/ |
| Communication Information | If you communicate with us, including through our social media accounts, we collect your name, contact information, other Online Identification Data and the contents of any messages you send. |
| Social Networking Data | When you sign in with LinkedIn, we receive basic information from your LinkedIn account, such as your name, the email address on the account, and an identifier for the account. We may also collect and process data resulting from our marketing activities on social media and your interactions with them. |
| Partners’ Data | This is Personal Information that you provide as a business partner or as a representative, contact person, employee, or other collaborator of a business partner of ambient. Such data may include your name, e-mail address, telephone number, fax number, IP address and other Personal Information. |
| Professional or work-related data | This is the Personal Information contained in the resumes and job applications we receive or collect in order to evaluate or initiate an employment or collaboration relationship, including your name, e-mail address, telephone number, home address, education and training, professional qualifications, LinkedIn profile, other public social media profiles relevant to our vacancies and any other information included in your application or otherwise made available to us. |
| Data on and from events and surveys | When you participate in our events, podcasts, interviews, webinars, conferences, surveys or similar activities, we collect the Personal Information you provide, such as your name, e-mail address, phone number, location, social media account, job title, company, voice and image. |
| Data from Third Party Technologies | ambient may integrate with third-party products and platforms. Personal Information you share with these third-party products may become accessible to us, and the providers of those products handle it in accordance with their own privacy policies. |
Sensitive information. We do not seek to collect special categories of personal data within the meaning of Article 9 of the GDPR or “sensitive personal information” within the meaning of the CCPA, and we ask you not to include such information in your profile, User Content or Contributions. If such information is nevertheless included in Personal Information we receive, for example in Materials you share or in publicly available information, we will process it only where permitted under Article 9(2) of the GDPR or applicable U.S. state law, such as on the basis of your explicit consent or where necessary for the establishment, exercise or defence of legal claims.
Purpose and basis of processing
When you use or interact with the Services, we use a variety of technologies to process the Personal Information we collect about you for the purposes set out in the table below. The legal basis column applies to you only where the GDPR or the UK Data Act applies, or where the applicable Law otherwise requires the legal basis to be disclosed.
Where we process your Personal Information on the basis of your consent or of a contract, we may continue to process it after the contract ends or after you withdraw your consent if we have a legitimate interest in doing so and the Law permits it.
We process your Personal Information for the following purposes, among others:
| Purpose of processing | Legal basis for the purpose of processing | Type of Data |
|---|---|---|
To provide, maintain and facilitate the Services, including:
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To identify, evaluate, screen, rank and match users of the Network, to propose User Experts to User Beneficiaries for Contributions and introduce users to one another, and to keep track of users’ availability and participation in Contributions |
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To verify that you are a founder (a web search, sometimes a paid business data provider, and staff review of unclear cases), to review disputed ratings, and to review Contributions for quality, credibility and authenticity |
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To assess potential conflicts of interest or breaches of the law |
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For account management and other administrative purposes, including creating and administering your member record |
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To customize our products and Services |
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To send you news about ambient, which you can stop at any time |
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To support and communicate with you for non-marketing purposes, including by sending you e-mails, text messages and other messages about the Platform, your matches and Contributions |
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To operate our business, including by analyzing and monitoring our performance and the use of, and activities on, the Platform |
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To investigate and resolve disputes, to establish, exercise or defend our legal claims, and to enforce the Terms and this Policy |
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To investigate and resolve security issues |
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To understand, diagnose, troubleshoot and resolve faults or other issues relating to the Services, and to provide you with support |
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To de-identify or anonymize Personal Information and to train our AI models. We train only ambient’s own AI models, and we don’t sell or license your Personal Information, or datasets made from it, to other companies, including for their AI |
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For research, improvement and development purposes, including developing new products, content and features, conducting studies, and market and user research |
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To fulfill our contractual obligations to third parties |
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To prevent, detect and investigate fraud (including fraudulent payments and fraudulent use of the Services), abuse, violations of the Terms, unlawful or criminal activity, and unauthorized access to or use of Personal Information or ambient systems and networks; to protect our rights and the rights of others; and to meet legal, governmental and institutional policy obligations, including by monitoring and reviewing Contributions, Materials and related communications |
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To process job and traineeship applications |
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To develop, train, evaluate, fine-tune and improve the AI Tools. We don’t sell or license your Personal Information to other companies for their AI |
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AI Tools, profiling and automated decision-making
This section explains how we use AI Tools to make or support decisions about you. It contains the information required by Articles 13(2)(f) and 14(2)(g) of the GDPR and the UK GDPR and by similar provisions of U.S. state privacy laws.
How we use AI Tools. We rely on AI Tools, including machine learning, large language models and other automated and generative technologies, to identify, evaluate, screen, rank and match users of the Network, to keep member records up to date, to identify Contribution opportunities and present them to you, and to propose User Experts to User Beneficiaries (each as defined in the Terms) and vice versa. This involves profiling, meaning that we automatically assess certain aspects of your professional profile and activity in order to predict which matches and Contributions are likely to be relevant.
Information used. The AI Tools may use your User Data, User Content and Generated Content, Publicly Available and Third-Party Data, Online Identification Data, Communication Information, Social Networking Data and Data from Third Party Technologies.
Possible effects on you. The outputs of the AI Tools can influence whether you are matched with other users or proposed for a Contribution, whether you are asked to help with a request, which Contribution opportunities are shown to you, and other aspects of your participation in the Network.
Human involvement. Our code applies filters and a fit score. Part of the score is meaning similarity between your request and other users’ skills, computed by an AI model. Code decides who is asked, and no AI model picks the match on its own. Our staff decide unclear verifications and review disputed ratings, and users decide whether to request, accept or take part in a Contribution. The ambient you text is an AI agent, and some of its replies are written by AI. If you disagree with a decision about you, such as on verification, you can ask for a person at ambient to review it by emailing legal@textambient.com.
Your rights and the legal bases for this processing are described in the other sections of this Policy.
Collecting your data
Where we request Personal Information directly from you, we ask only for the categories of Personal Information we need for the purposes described above. We collect Personal Information directly from you when you create an account, complete your profile, fill out forms, contact us or otherwise use the Platform. When you chat or take part in a voice or video call with the AI Tools, or take part in a Contribution conducted through the Platform, we collect the audio, video, transcripts and messages generated during the interaction.
If you provide ambient with the Personal Information of your users, employees, customers or other third parties, you must inform them and, where required by the Law, obtain their consent to the processing of their data before disclosing it to ambient. By using the Platform, you represent, warrant and undertake that you have obtained the appropriate consent from each person whose data is uploaded to the Platform. Introductions work differently. If you ask for an introduction, you tell us about the person, or the kind of person, you want to reach. If you help with an introduction, you give us the LinkedIn link of the person you can reach, and we see their name and email address when you email them with ambient on CC. We read their reply to see whether they said yes, and if they did, we introduce them by email. We use this information only to make that introduction. If you are that person and want your information removed, email us at legal@textambient.com. Files can also contain information about other people, so remove names and contact details before you upload.
We may obtain Personal Information from third-party data sources and publicly available information (for example, to verify that you are a founder), and from other third-party sources, including third-party tracking technologies. We may combine information obtained from these sources with other Personal Information we hold about you.
We also collect certain information automatically, through cookies, server logs and similar technologies, as described under Online Identification Data above. In addition, the AI Tools generate inferences and other derived information from your use of the Platform.
Sharing Personal Information
We may disclose, transfer or share your Personal Information with the following categories of recipients, in some cases without notifying you in advance:
| Categories of recipients | Reason for data sharing |
|---|---|
| Service providers | We work with service providers that process Personal Information on our behalf to help us operate the Platform and our business. These include providers of cloud hosting and data storage, database management, e-mail and other communication services, analytics and research, customer support, IT and security, and auditing and compliance services. Our service providers may access Personal Information to the extent needed to perform their services for us. They also include texting providers, sign-in providers and the services we use to verify that users are founders. |
| AI providers | We use third-party artificial intelligence providers, including large language model, speech-to-text, text-to-speech and real-time communications providers, to operate the AI Tools and the chat, voice and video features of the Platform. These providers process User Content, Generated Content, audio, transcripts and other Personal Information to perform services on our behalf. |
| Other users | To operate the Platform, we share limited User Data with other users. Other users see you only as “Node” plus a number, with your stage, B2B or B2C, and industry, plus what you write in a request, and we make the Materials you choose to share through the Platform available to the users with whom you are matched. Your name and phone number are shared with another user only if, after a Contribution rated 4 or 5, you and that user both say yes. For an introduction, the person introduced receives an email from the helping user’s own email address, containing the requesting user’s teaser. If they say yes, we email both of them, which shares the requesting user’s first name and email address with that person, and theirs with the requesting user. We also share the information necessary to arrange, schedule and coordinate Contributions and to enable the users involved to carry out the Contributions they have agreed to. |
| No sale, no advertising | We don’t sell your Personal Information, and we don’t share it for cross-context behavioral advertising. We don’t use advertising pixels or advertising cookies. |
| Law enforcement | We share your Personal Information where we believe in good faith that this is necessary to comply with a legal obligation under applicable law, or to protect our legitimate interests, rights and safety or those of a third party. |
| Buyers of our business | We will share your Personal Information if we sell or negotiate the sale of our business, assets and/or data to a buyer or potential buyer, if we are involved in a corporate transaction (such as a merger, acquisition, financing, reorganization or public offering, including in the course of due diligence for any such transaction), bankruptcy, change of control or any other situation involving the transfer of our business, assets and/or data. |
| Relevant authorities | We will share your Personal Information with governmental and regulatory authorities where required by law, including for legal, tax or accounting purposes, in response to their requests for information or to assist in their investigations. |
| ambient employees and contractors | Our employees, collaborators and contractors may process your Personal Information to ensure that the Services work properly and comply with applicable law. |
| ambient affiliates (if applicable) | We may disclose your contact data to our group affiliates to provide the Services and for the purposes described above. We don’t share your phone number, or your consent to receive texts, with third parties or affiliates for their marketing or promotional purposes, and we don’t share your Personal Information with our affiliates for their own products or marketing. |
| With your consent | We will also disclose your Personal Information where you give us permission or instruct us to do so. |
Data security
We have implemented reasonable and appropriate physical, technical and organizational measures, such as encryption, to protect the Personal Information we collect and to prevent unauthorized access to, and disclosure and misuse of, your Personal Information. For example, uploaded files are virus-scanned, cleaned of hidden data and checked for identifying details before another user sees them. No method of sending or storing information is completely secure, so we can’t guarantee its security, and we can’t stop other users from taking screenshots or photos of what they see. Please don’t send us passwords, financial account numbers, health information or government ID numbers.
Children
To use the Services, you must be at least 18 years old. If we learn that we have collected Personal Information from a person under 18, we will delete it promptly. If you believe that we hold Personal Information about a person under 18, please contact us at legal@textambient.com.
Retention period
We will store and process your Personal Information for the period of time necessary to achieve the purposes described in this Policy and in accordance with our legal and contractual obligations.
We store your data for as long as you use the Platform and for up to three (3) years after you stop using the Services or delete your account (whichever occurs later), unless a longer period is required by law or justified by our legitimate interests, in which case we will store it for that longer period. After that, we will erase the data in accordance with our procedures, which may involve anonymization or destruction.
If you ask us to, we will delete or anonymize your Personal Information so that you can no longer be identified, unless we are permitted or required by law to retain certain Personal Information, including in situations such as the following:
- If there is an unresolved issue related to your account, such as an outstanding claim, complaint or dispute, we will retain the necessary Personal Information until the issue is resolved;
- Where we need to retain Personal Information for our legal, tax, audit and accounting obligations, we will retain the Personal Information required for the period required by applicable law;
- When necessary for our legitimate business interests, such as to prevent fraud or to maintain the security of our users; and
- To enforce our rights and those of third parties.
Your rights under the GDPR and the UK Data Act
You have a number of rights regarding your Personal Information, which you can exercise by sending an e-mail to legal@textambient.com.
Right to information. You have the right to be informed, in a clear and transparent way, about how we handle your Personal Information and what rights you have in this respect. This Policy explains in detail what Personal Information we collect from you and how we handle it.
Right of access. You have the right to access the Personal Information we hold about you at any time.
Right to rectification. You have the right to rectify the Personal Information we hold about you where it is incorrect or out of date and/or to complete such data where it is incomplete.
Right to object. You have the right to object at any time, on grounds relating to your particular situation, to our processing of your Personal Information based on our legitimate interests. Where you object, we will stop processing your Personal Information for those purposes unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.
Right to withdraw consent. Where we rely on your consent, you may withdraw it at any time, for example through our cookie settings or by contacting us. You can also text STOP to stop all texts and leave, START to come back, and HELP for help. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.
Right to object to direct marketing. If Personal Information is processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your Personal Information for direct marketing purposes by clicking the “Unsubscribe” link in any marketing e-mail you receive. If you object to processing for direct marketing purposes, your Personal Information will no longer be processed for such purposes. However, these opt-outs do not apply to communications that relate to your account, our agreements with you, support, security warnings or other administrative and transactional notices, where the primary purpose of such communications is not promotional.
Right to data portability. You have the right to receive the Personal Information you have provided to us in a structured, commonly used and machine-readable format, where our processing is based on your consent or on a contract with you and is carried out by automated means. You also have the right to transmit this Personal Information to another controller and, where technically feasible, to ask us to transmit it directly.
Right to restriction of processing. You have the right to obtain restriction of the processing of your Personal Information in certain cases (for example, where you contest the accuracy of your Personal Information, for the period we need to verify its accuracy).
Right to erasure. In certain cases, you have the right to have your Personal Information deleted (the “right to be forgotten”). When you make such a request, we will assess whether we can delete your data or whether we need to retain certain data to comply with a legal obligation.
Right to complain. If you disagree with the way we handle your Personal Information, you have the right to lodge a complaint. If you have a complaint, we would like to resolve it with you first.
Under the laws of many countries, you also have the right to lodge a complaint with the supervisory authority in the place in which you live or work. A full list of EU supervisory authorities’ contact details is available here. In the UK, you have the right to lodge a complaint with the UK Information Commissioner’s Office.
You also have the right to bring a claim against us before the competent court if you believe that your rights under the GDPR have been violated as a result of our processing of your Personal Information.
You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Response times. We will respond to your request without undue delay and in any event within one month of receipt. Where necessary, taking into account the complexity and number of requests, we may extend this period by up to two further months. In that case, we will inform you of the extension, and the reasons for it, within one month of receiving your request.
Verification of requests. To protect your Personal Information, we may need to verify your identity before acting on a request under this Policy, for example by matching the information you provide with the information we hold or by asking you to confirm the request from the e-mail address associated with your account or by text from your phone number. We will only ask for the information reasonably necessary for this purpose and will not require you to create an account.
Your rights under U.S. state privacy laws (including the CCPA and the VCDPA)
This section applies to residents of U.S. states that grant statutory privacy rights. You can exercise the rights below by sending an e-mail to legal@textambient.com. These rights are subject to verification of your identity and to the exceptions provided by applicable law.
Depending on your state of residence, you may have the right:
- To confirm whether or not ambient is processing your Personal Information and to access such Personal Information, including the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which it was collected, the purposes for which it is processed, and the categories of recipients to whom it was disclosed;
- To correct inaccuracies in your Personal Information;
- To delete Personal Information you have provided to us or that we have obtained about you;
- To obtain a copy of the Personal Information you have previously provided to us, in a portable and readily usable format;
- To opt out of the processing of your Personal Information for the purposes of:
- (i) sale or “sharing” (as defined under applicable U.S. state privacy laws);
- (ii) targeted advertising; and
- (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- To limit the use and disclosure of your sensitive personal information to the purposes permitted by applicable law;
- To appeal a decision regarding a specific request.
Some of these rights are described in more detail below.
Request to opt out/Do Not Track
You have the right to opt out of the sale of your Personal Information and of its sharing for targeted advertising, although we don’t sell or share Personal Information. We do not currently respond to “Do Not Track” browser signals. However, we treat legally recognized opt-out preference signals, such as the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of your Personal Information, as described in the California section below.
Response times and appeals
We will respond to your request without undue delay and in any event within 45 days of receipt. Where reasonably necessary, taking into account the complexity and number of your requests, we may extend this period once by an additional 45 days, in which case we will inform you of the extension, and the reasons for it, within the initial 45-day period.
If we decline to take action on your request, we will inform you without undue delay, and in any event within 45 days of receipt of the request, of the reasons for our decision and of how you can appeal it.
If your request is declined, you can appeal by sending a substantiated notice to legal@textambient.com.
Within 60 days of receiving your appeal, we will inform you in writing of any action taken in response to it, including a written explanation of the reasons for our decision. If we deny your appeal, we will tell you how to contact your state Attorney General to submit a complaint.
Non-Discrimination
Under U.S. state privacy laws, businesses are prohibited from discriminating against you for exercising your rights under the law. This includes actions such as denying you a product or service, offering a lower quality or different level of service, or charging you higher prices. However, the California Consumer Privacy Act (CCPA) allows businesses to offer different levels or qualities of service or charge different prices, provided the business can demonstrate that these differences are reasonably tied to the value the consumer’s personal information brings to the business. This ensures that businesses can adjust their offerings in a way that reflects the value of the Personal Information they collect, without unfairly penalizing consumers for exercising their privacy rights.
California “Shine the Light”
California Civil Code § 1798.83 permits California residents to request information about certain disclosures of personal information to third parties for those third parties’ direct marketing purposes. ambient does not disclose Personal Information to third parties for their own direct marketing purposes. California residents may submit questions about this disclosure by contacting us at legal@textambient.com.
California: Right to Opt Out of the Sale or Sharing of Personal Information
ambient does not sell or share Personal Information, as those terms are defined under the CCPA.
You have the right to opt out of the sale or sharing of your Personal Information at any time by: (a) sending us an e-mail at legal@textambient.com; or (b) enabling a legally recognized opt-out preference signal, such as the Global Privacy Control (GPC), in your browser or device.
Nevada residents
Nevada law allows Nevada residents to direct us not to sell certain covered information that we have collected or will collect about them. Under Nevada law, a “sale” means the exchange of covered information for monetary consideration to a person for that person to license or sell the information to additional persons. We do not currently sell covered information as so defined. You may nevertheless submit a request not to sell your covered information by sending an e-mail to legal@textambient.com.
Transfers to other countries
Transfers from the EU and the UK
ambient is based in the United States. Personal Information we collect in the EU or the UK will therefore be transferred to and processed in the United States (“US”).
Some of our third-party providers may also be based outside the European Union or the UK, in which case their processing of your Personal Information will involve a transfer of data outside these territories. Whenever we transfer your Personal Information outside the EU or the UK, we ensure that at least one of the following safeguards is in place:
- the transfer is to a country that has been deemed to provide an adequate level of protection for Personal Information. For the EU, please see the European Commission’s Adequacy Decisions;
- we have entered into contracts approved for this purpose, such as the European Commission’s Standard Contractual Clauses, which provide the same level of protection for Personal Information as in the EU or the UK; or
- where neither of the above safeguards applies, the transfer is necessary for the performance of our contract with you or you have given your explicit consent to it.
Transfers from the US
Personal Information we collect may be transferred to and processed in the European Union.
Some of our third-party providers may also be based outside the US, in which case their processing of your Personal Information will involve a transfer of data outside the US.
Changes to our Policy
We may change this Policy from time to time. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by texting you, by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. Where permitted by law, your continued use of the Services after this Policy has been updated will constitute your acceptance of the changes. In some cases, you will be given a choice to accept changes to this Policy. If you do not accept the updated Policy, you must stop using the Services.