Last updated: January 13, 2021

Impro.ai together with its affiliate companies – (“Impro.ai,” “we,” “our” or “us”) recognizes the importance of maintaining the privacy and security of personal data that we collect.

This Privacy Policy applies to Impro.ai’s platform, Sites and services (the “Services”), and describes how we collect, store, use, and disclose the following types of information:

  1. User data relating to individuals who purchase the Services on behalf of our corporate customers, to provide the Services to the corporate customer’s Participants;
  2. Coaches and Participant data relating to Coaches and Participants who use the Services to provide and receive executive coaching;
  3. Website Visitor, CRM & Prospects Data relating to visitors of our website, participants at our events, partners, investors, applicant for a position at Impro.ai, or any prospective partner or investor, User, Coach, Participant or Job Candidate who visits or otherwise interacts with any of our websites, mobile application, online ads, and content, emails or other communications under our control (“Sites”); and

 

Specifically, this Privacy Policy describes our practices regarding –

  1. Data Collection
  2. Data Uses
  3. Data Location & Retention
  4. Data Sharing
  5. Cookies & Tracking Technologies 
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Controller/Processor
  10. Additional Notice & Contact Details  

 

If you are our User, Coach, Participant, Job Candidate, visitor, partner, investor or prospect (“you”) – please read this Privacy Policy carefully and make sure that you fully understand and agree to it. 

You are not legally required to provide us with any personal information, and may do so (or avoid doing so) at your own discretion. If you do not wish to provide us with your personal information, or to have it processed by us or any of our Service Providers (defined in Section 4) as described below, please refrain from accessing, using or registering for our Services.

1. Data Collection

We collect Personal Information that team members and organizations share with us directly or provide by interacting with our platform or our website, or otherwise using the Services. The types of Personal Information we collect are as follows:

1. User data – We collect and generate the following types of personal information relating to individuals who purchase the Services on behalf of our corporate customers (“Users”) –

 

  • User profile information (name, e-mail address, mobile phone number, saved addresses, and, where applicable, hashed password);
  • Business account information (as applicable: company name, industry, account classification and commercial terms);
  • Usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data (like type, OS, device id, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on their device); 
  • Direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer service, user enablement, feedback, support and training purposes). 

 

2. Coach Data – We collect and generate the following types of personal information relating to executive coaches who coach Participants via the Services (“Coaches”) –

 

  • User profile information (name, e-mail address, mobile phone number, saved addresses, and, where applicable, hashed password);
  • Business account information (as applicable: company name, industry, account classification and commercial terms);
  • Information you share through the Services. Most of our coaching is done through our Services, which facilitates communication between Coaches and Participants. We collect Personal Information that you share with Participants through this platform, which may include a range of Personal Information. 
  • Information you share in coaching sessions. You may host video sessions with Participants from time to time. Sessions may be recorded and we will collect Personal Information provided by you through recorded sessions. 
  • Usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data (like type, OS, device id, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on their device); 
  • Direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer service, user enablement, feedback, support and training purposes). 

 

3. Participant Data – We collect and generate the following types of personal information relating to participants who are coached by Coaches via the Services (“Participants”) –

 

  • User profile information (name, e-mail address, mobile phone number, saved addresses, and, where applicable, hashed password);
  • Business account information (as applicable: company name, industry, account classification and commercial terms);
  • Information you share through the Services. Most of our coaching is done through our Services, which facilitates communication between Coaches and Participants. We collect Personal Information that you share with Coaches through this platform, which may include a range of Personal Information, for example family status, as well as information about your personal and professional history, values, vision, hobbies, personality and challenges. You may also share links with us to your social media sites so that we can learn more about you. During the onboarding process we may ask you to complete a survey about your personality and perceived strengths and weaknesses. 
  • Information you share in coaching sessions Our coaching services include video coaching sessions. These sessions may be recorded and we will collect Personal Information provided by you through recorded sessions. 
  • Usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data (like type, OS, device id, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on their device); 
  • Direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer service, user enablement, feedback, support and training purposes). 
  • Information our corporate customers share about Participants. Most of the Personal Information we collect will come directly from the Participant. However, from time to time, we may receive information from our corporate customers, such as high-level insights into Participant’s job performance, to help facilitate effective coaching sessions. 

 

We process certain limited business user data on our corporate customers’ behalf, as their ‘data processor’ (namely, such data which is needed for registering and deregistering users on such corporate customers’ business account); whilst with respect to all other personal information pertaining to our users and processed by Impro.ai, Impro.ai shall act and be deemed as the ‘data controller’. For more information, see Section 9 below.

 

  1. Website Visitor, CRM & Prospect Data: We collect the following types of personal information concerning our website visitors, partners, investors and prospects–

 

  • Usage Information connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data [such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used], session recordings and analytics, and the cookies and pixels installed or utilized on the device; 
  • Business Account Information – contact, contractual and billing details concerning our Users, which may also contain the details of their internal focal persons who directly engaged with us on behalf of the Customer, e.g., the account administrators, billing contacts and authorized signatories on behalf of the Customer; as well as details concerning their needs and preferences, as identified by us or recognized through our engagement with them;
  • Information Concerning Our Prospects contact and business details, our communications with such prospects (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement;

 

We collect the personal information mentioned above either directly, through your interaction with us or with our Sites or Services; or through third-party services, social media, analytics tools, events we organize or participate in, and other business initiatives.  

To the extent that any of the above-mentioned data only pertains to a non-human entity (e.g., the phone number or bank account of a company or business), we will not regard it as “personal information” and this Privacy Policy does not apply to it.

2. Data Uses

Impro.ai generally collects, uses and discloses your Personal Information to provide services to organizations and team members and to operate our business, including for the following purposes:

 

  • We use your Personal Information to provide coaching services aimed at improving your productivity, adaptability and creativity. We may also use your Personal Information to monitor and improve coaching performance.
  • To authenticate the identity of our users, Coaches and Participants, and to allow them to access and use our Services;
  • We use Personal Information to develop, operate and improve our machine learning technology that generates coaching insights for you and your organization. 
  • We use Personal Information to communicate regarding the Services, including concerns or queries corporate customers, Coaches or Participants may have.  We also communicate with Participants at various stages in the coaching process, and may communicate revisions to this Privacy Policy.
  • To provide assistance and support to our corporate customers, Users, Coaches and Participants;
  • We may use your feedback, comments, questions and engagement to understand and analyze the interests, needs and preferences of customers and team members, to improve our Services and to tailor those Services to you. As noted below, we may also use cookies and related technologies to improve our website and collect statistical information about how this website is being used.
  • To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you (as further described in Section 6 below); 
  • To facilitate, sponsor and offer certain events, contests and promotions; 
  • To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  • To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
  • To create aggregated statistical data, inferred non-personal information or anonymized or pseudonymized data (rendered non-personal), which we, our business partners or our corporate customers may use to provide and improve our respective services, or for any other purpose; and
  • To comply with applicable laws and regulations.

If you reside or are using the Services in a territory governed by privacy laws under which consent is the only or most appropriate legal basis for the processing of personal information (in general, or specifically with respect to the types of personal information you expect or elect to process or have processed by, or via the Services, e.g. ‘special categories’ under the GDPR), providing such personal information and using the Services, as well as your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal information for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at privacy@impro.ai.

We will not sell or lease your Personal Information to any third party marketers, or otherwise provide your information to third parties for their own use.

3. Data Location & Retention

Data Location: Given the fact that Impro.ai operates in many jurisdictions worldwide, your personal information may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States, Canada , within the European Union, Israel, and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Impro.ai and its Service Providers are each committed to protect personal information in accordance with this Privacy Policy, reasonable and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.  For data transfers from the EU or the UK we have entered into Standard Contractual Clauses. You can obtain a copy by contacting us as indicated in Section 10 below. 

Data Retention: We will retain your personal information for as long as it is reasonably necessary for us to maintain and broaden our relationship with you, and provide you with our Services and offerings; in order to facilitate your potential restart of services with us; in order to comply with our legal and contractual obligations; and to protect ourselves from any potential disputes; as required by laws applicable to our operations, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use, all in accordance with our contractual terms and data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal information for any particular period, and we are free to securely delete it, anonymize it, or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail privacy@impro.ai.   

4. Data Sharing

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal information, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services. 

Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include cloud-based providers such as Amazon Web Services and Microsoft Azure, may store or process your Personal Information in the United States or other jurisdictions other than Canada, where it may be the subject of laws of the jurisdiction in which it is stored. (collectively, “Service Providers“). 

These Service Providers may have access to your personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of Impro.ai’s Service Providers, please note that such engagement is beyond the scope of the terms applicable to your engagement with Impro.ai, including this Privacy Policy, and will therefore be covered by the Service Provider’s terms and policies. 

Our Service Providers shall be deemed as ‘processors’ in circumstances where Impro.ai assumes the role of ‘controller’; and where Impro.ai acts as the ‘processor’, the Service Provider shall be deemed our ‘sub-processor’, as further described in Section 9 below. 

Third Party Websites and Services: Our Services may also include links to third-party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services. 

Sharing of personal information with your employer

We value the confidential relationship established between you as a Participant and our coach and we will not disclose to your employer any Personal Information you provide through the onboarding process, interactive platform or coaching sessions. The only personal details we will share with your employer will relate to whether you have engaged in the coaching process as well as the volume and types of performance breakthroughs you have realized as a result of the coaching process. 

From time-to-time, we may provide organizations with team-level insights respecting the coaching process and its impact; however, such information will be aggregated and will not contain any Personal Information or identify individual team members in any way, including by implication. 

 

Sharing of data between Coaches: In order to provide our Services, Coaches may share personal information pertaining to Participants with other Coaches (e.g. if a Coach is on an extended leave and is replaced by another Coach or if a Coach is replaced by Impro.ai at a Participant’s request) or with coaching team leaders (who are responsible for the coaching staff).

Protecting Rights and Safety: We may share your personal information with others (for example emergency services) if we believe in good faith that this will help protect the rights, property, or personal safety of Impro.ai, any of our Users, Coaches or Participants, or any members of the general public.

Impro.ai Subsidiaries and Affiliated Companies: We may share personal information internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should Impro.ai or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, your personal information may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal information then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, Impro.ai may share your personal information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have rendered such data non-personal and/or anonymous. We may transfer, share or otherwise use non-personal information at our sole discretion and without the need for further approval.

5. Cookies & Tracking Technologies

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies.” Some last for longer periods and called “Persistent Cookies.” We use both types. 

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services. However, the use of cookies may be subject to additional rules including your consent, as further explained in our Cookie Policy.

Tailored Ads

We use Google AdSense and other third party advertising tools to advertise online. Third party vendors, including Google, may show ads for Impro.ai on websites that you visit across the Internet. We and our service providers, including Google, use cookies to inform, optimize, and serve ads on third party websites based on your past visits to our website. These cookies may also be used to report on ad impressions, other uses of ad services and interactions with these ad impressions and ad services related to visits to our website.

You can choose to opt-out of receiving tailored advertising from Google by visiting Google’s Advertising – Privacy & Terms page.  In Canada, you can choose to opt out of receiving tailored advertising from other advertising services by visiting the Digital Advertising Alliance of Canada’s Opt-Out Tool. If you opt-out of receiving tailored advertising from these third parties, you may still see Impro.ai ads on other websites, but those ads will not be customized by the companies that you opt-out of and Impro.ai may continue to customize your experience on our website using cookies.

6. Communications

Service Communications: We may send you notifications (through any of the means available to us, including by email, SMS or through our platform) of changes or updates to our Services, billing issues, service changes, etc. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to the operation of our Services and your use thereof (like customer support communications).

Promotional Communications: We may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, SMS, mobile notifications or e-mail).

If you do not wish to receive such promotional communications, you may notify Impro.ai at any time by contacting us at privacy@impro.ai, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

7. Data Security

We and our hosting services implement systems, applications and procedures to secure your personal information, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal information. These measures are aimed to provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law, such as the EU General Data Protection Regulation (GDPR), the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), or the California Consumer Privacy Act (CCPA), to request access to, and rectification or erasure of your personal information held with Impro.ai, or to restrict or object to such personal information’s processing, or to port such personal information or to exercise the right to equal services and prices (each to the extent available to you under the laws which apply to you), please contact us at privacy@impro.ai. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the territory applicable to you.

When you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of the data to which your request pertains. Such additional information will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above. 

We may redact from the data which we will make available to you, any personal information or confidential information related to others.

9. Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal information: the “controller” (or the “business” under the CCPA), which determines the purposes and means of processing; and the “data processor” (or the “service provider” under the CCPA), which processes the data on behalf of the controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Impro.ai is the “data controller” of User Data, Coach Data (except for User Profile Information), Participant Data (except for User Profile Information and Information our corporate customers share about Participants), Website Visitor, CRM & Prospect Data (i.e., the relevant Usage Information, Business Account Information, and Information Concerning our Prospects), and other personal information pertaining to our Customers, visitors, and prospects, and assumes the responsibilities of a controller (solely to the extent applicable under the law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “processor”. 

Impro.ai is the “data processor” of Coach User Profile Information, Participant User Profile Information and Information our corporate customers share about Participants. In such instances, our corporate customers shall be deemed the “data controller” of such data, and Impro.ai  will process such data on the corporate customers’ behalf, as its “data processor”, in accordance with its reasonable instructions, and the commercial and data processing agreements executed between Impro.ai and such Users (as applicable). Impro.ai’s Service Providers shall then act as designated sub-processors in these instances. Impro.ai’s Customers will be responsible for meeting any legal requirements applicable to controllers (such as obtaining their consent or establishing other legal basis for processing). 

10. Additional Notices & Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our applicable platforms. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit.

Our Services are not designed to attract children under the age of 16: We do not knowingly collect personal information from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal information stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@impro.ai.  

 

 

EU / UK Representative:

Representation for data subjects in the EU and the UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you are in the EU or the UK and want to contact us via our local representative, Prighter, or make use of your data subject rights, please visit: https://prighter.com/q/12588842987

 

If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or in the UK as applicable to you.

      

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal information held with us, please contact us at privacy@impro.ai.