Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under thefollowing conditions. The following definitions shall have the same meaning regardless ofwhether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application means the software program provided by Rillavoice downloaded by You on any electronic device, named Rillavoice Mobile App
Company (referred to as either "Rillavoice", "We", "Us"or "Our" in this Agreement) refers to Rillavoice, Inc, 95 WallStreet, 505.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: New York, United States
Data Controller, for the purposes of the GDPR (General Data ProtectionRegulation), refers to Rillavoice as the legal person which alone or jointly with others determines the purposes and means of the processing of PersonalData.
Device means any device that can access the Service such as a computer, a cellphone ora digital tablet.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Service refers to the Application or the Website or both.
Service Provider means any natural or legal person who processes the data on behalf of Rillavoice. It refers to third-party companies or individuals employed by Rillavoice to facilitate the Service, to provide the Service on behalf of Rillavoice, to perform services related to the Service or to assist Rillavoice in analyzing how the Service is used. For the purpose of the GDPR, ServiceProviders are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of theService or from the Service infrastructure itself (for example, the duration ofa page visit).
Website refers to Rillavoice, accessible from rillavoice.com
You means the individual accessing or using the Service, or Rillavoice, or other legal entity on behalf of which such individual is accessing or using theService, as applicable.Under GDPR (General Data ProtectionRegulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us withcertain personally identifiable information that can be used to contact oridentify You. Personally identifiable information may include, but is notlimited to:

Email address
First name and last name
Phone number
Bank account information in order to pay for products and/or services within the Service
Usage Data

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

Date of birth
Passport or National ID card
Bank card statement
Other information linking You to an address

Usage Data

Usage Data is collected automatically when using theService.Usage Data may include information such as Your Device'sInternet Protocol address (e.g. IP address), browser type, browser version, thepages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.When You access the Service by or through a mobile device,We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobileInternet browser You use, unique device identifiers and other diagnostic data.We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Third-Party Services

A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with the Rillavoice Service, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. Rillavoice may also develop and offer Rillavoice applications that connect the Service with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Rillavoice. For example, if a single sign-on service is connected with Rillavoice, Rillavoice may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to Rillavoice to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Rillavoice. When a Third-Party Service is enabled, Rillavoice is authorized to connect and access Other Information made available to Rillavoice in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). Rillavoice does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Service.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Rillavoice, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Flash Cookies. Certain features of our Service may use local stored objects (orFlash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

Cookies can be "Persistent" or "Session"Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You closeYour web browser. Learn more about cookies: What Are Cookies?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary/ Essential Cookies
‍Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

Rillavoice may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of theService that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, service sand events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held byUs about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Rillavoice may use Personal Data for the following purposes:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contactYou.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
To manage Your requests: To attend and manage Your requests to Us.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

Rillavoice will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Rillavoice will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Rillavoice's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.Rillavoice will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions
If Rillavoice is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
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Law enforcement
Under certain circumstances, Rillavoice may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
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Other legal requirements
‍Rillavoice may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation·
Protect and defend the rights or property of Rillavoice
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to YourPersonal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the GoogleAnalytics opt-out browser add-on. The add-on prevents the Google AnalyticsJavaScript (ga.js, analytics.js and dc.js) from sharing information with GoogleAnalytics about visits activity.You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their PrivacyPolicy: https://policies.google.com/privacy
‍For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Mixpanel
Mixpanel is provided by Mixpanel Inc.You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
‍For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that maybe of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.We may use Email Marketing Service Providers to manage and send emails to You.

Customer.io
Their Privacy Policy can be viewed at https://customer.io/legal/privacy-policy/

Payments

Square
Their Privacy Policy can be viewed at https://squareup.com/us/en/legal/general/privacy
Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy

We may provide paid products and/or services within theService. In that case, we may use third-party services for payment processing(e.g. payment processors).We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCISecurity Standards Council, which is a joint effort of brands like Visa,Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Rillavoice is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Rillavoice.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Rillavoice.

In any case, Rillavoice will gladly help to clarify thespecific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.

Rillavoice undertakes to respect the confidentiality of YourPersonal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using yourPersonal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data ProtectionAuthority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contactYour local data protection authority in the EEA.

How Rillavoice Helps Customers Maintain Compliance

Our business Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using Rillavoice on the customers’ behalf or at their request have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the business customers, including specifically in the context of an employment relationship. Our business customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services.

Rillavoice helps business Customers maintain compliance with GDPR by allowing...
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AutomaticRedaction of Personal Data from Transcriptions Generated and Stored in Rillavoice. Rillavoice business Customers may choose to have all their transcriptions generated in the Rillavoice software redacted of PersonalInformation such as: Bank account numbers, passwords, emails, telephone numbers. In order to achieve this Rillavoice uses AWS Comprehend. A full explanation and list of the items that can be automatically redacted from the Rillavoice audio and transcription can be found here https://docs.aws.amazon.com/comprehend/latest/dg/how-pii.html‍

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information fromOur servers.If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice onOur Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email at hello@rillavoice.com