Privacy Policy

Last updated: December 19, 2024.

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

This Privacy Policy applies to Impro.ai’s platform, Sites (as defined below) and services offered by us via your use of our platform to with respect to consultation, training and coaching services (the “Services”), and describes how we collect, store, use, transfer and disclose personal information. In this Privacy Policy, “personal information” means any information about an identifiable individual or information that allows an individual to be identified, as defined from time to time in applicable privacy legislation. Personal information does not include business contact information such as your name, title or position, business address, telephone number, facsimile number or e-mail address. In this Privacy Policy, “personal information” also refers to the following types of information:

  1. User Data: relating to Participants (as defined below) data;
  2. Coaches, Mentors and Participants Data: relating to Coaches, Mentors and Participants who use the Services to provide and receive executive coaching; and
  3. Website Visitors, CRM & Prospects Data: relating to visitors of our website, participants at our events, affiliates, investors, applicant for a position at Impro.ai (“Job Candidates”), or any prospective affiliate or investor, User (as defined below), Coach (as defined below), Participant (as defined below) or Job Candidate who visits or otherwise interacts with any of our websites, applications, online ads, and content, emails or other communications under our control (“Sites”).

 

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
  11. Artificial Intelligence

 

If you are our User (as defined below), Coach (as defined below), Mentor (as defined below), Participant (as defined below), Job Candidate, visitor, affiliate, investor or prospect (“you”) – please read this Privacy Policy carefully and make sure that you fully understand and agree to be bound by it and its terms. BY USING THE SERVICES, ACCESSING THE SITES AND/OR SUBMITTING PERSONAL INFORMATION TO US, YOU AGREE THAT WE MAY COLLECT, USE, MAINTAIN, RETAIN, TRANSFER AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW

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 . If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with certain services, products or information. You are responsible for ensuring the accuracy of the personal information that you submit to us. Inaccurate information will affect your experience when using the Sites or the Services and our ability to contact you as described in this Privacy Policy.

1. Data Collection

We may collect personal information in connection with your use of the Sites or with your use or purchase of our products and Services.

When you use our Sites or Services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Sites or Services. .

When you use our Sites, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Sites. The personal information that we may collect may include:

(a) Information you provide to us when you are:

    1. Registering for an Impro.ai account, you provide us with your name, e-mail address and billing address. By choosing to provide this information, you consent to our processing of that information;
    2. Participating in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials;
    3. Registering or filling in forms on the Sites;
    4. Purchasing any product or service from Impro.ai and/or when you subscribe to a paid service or make a purchase directly from us (rather than through a third-party platforms), you provide us or our payment service provider with information, such as your credit card and debit card numbers (with expiration dates and CVV) or other financial information. We use Transport Layer Security (TLS) encryption technology to encrypt sensitive personal information (such as your payment information) before it travels over the internet. Credit card numbers are never stored on our database or servers; however, we use third-party providers to process any payments made by you and such third-party providers may store your personal information on their databases and/or servers;
    5. Reviewing any product or service from Impro.ai or another user of the Sites;
    6. Participating in our promotions, events or contests and in such instances, we collect the information that you use to register or enter;
    7. Requesting for us to communicate with or otherwise process information of other people and in such instances, we collect the information about others that you give us in order to complete your request. If you provide us with personal information of another individual, you represent to us that you have that individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose that personal information in accordance with this Privacy Policy;
    8. Requesting information or assistance from Impro.ai. This includes information you may provide when you request additional information about Impro.ai’s products and services or sign up to receive Impro.ai’s e-mail newsletters or coupons. Impro.ai may also keep a copy of any communications or correspondence you may send to it, including any e-mail communications; and
    9. Using other features, including Interactive Functions (as such term is defined in the Sites’s Terms and Conditions of Use (the “Terms and Conditions”)) of the Sites that may be offered from time to time, and may require such information in order to utilize the feature (including but not limited to making a User Submission as defined in the Terms and Conditions);

 

(b) Information others provide to us about you. We will apply this Privacy Policy to any personal information received from third parties, unless we have disclosed otherwise. In addition to the information you provide to us directly, we may receive information about you from other parties, for instance:

    1. Other users may provide information about you as they use our products and services. We may also collect information about you from other users if they contact us about you;
    2. Instead of registering for an account with our Sites directly, you may log in to the Sites using sign-in services such as Microsoft and Google. Such sign-in features eliminate the need for you to create a username and password for our Sites and allow you to authenticate your account using your existing social media identity and pre-verified user account. These services will also provide you with the option to share certain personal information with us such as your name and e-mail address. Prior to using any such sign-in services, please review the privacy policies of these social media providers as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of these social media sites; and
    3. We may receive personal information about you from our affiliates or service providers. We may supplement the information we collect about you through the Sites with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google Ad Network and LinkedIn Ads may tell us which ads about Impro.ai you clicked on.

 

(c) Information collected when you use the Sites. When you use our Sites, we collect information about which features you’ve used, how you’ve used them and the devices you used to access our Sites, for instance, we collect information:

(i) About your activity on our Sites (for example, date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on, etc.) and how you interact with other users (for example, users you connect and interact with, time and date of your exchanges, number of messages you send and receive, etc.) and your relationship with such users;

 

(ii) About the device(s) you use to access our Sites including:

    • hardware and software information such as manufacturer, model, IP address, device identification and type, operating system and identifiers associated with cookies or other technologies that may uniquely identify your device or browser (such as, IMEI/UDID and MAC address);
    • information on your wireless and mobile network connection such as, your service provider and signal strength;

 

(iii) From the device(s) you use to access our Sites including your:

    • device-specific and application settings and characteristics, application crashes, advertising IDs (such as Google LLC’s AAID and Apple Inc.’s IDFA), browser type, version and language, time zones, etc.; and

 

(iv) Other information with your consent such as:

    • your photos, images and videos (for instance, if you want to publish a photo, video or streaming on the Sites); and
    • any other personal information that you choose to include in your account, your User Submissions (as defined in the Terms and Conditions) or in other communications to Impro.ai.

 

We may collect personal information even when you are not using the Sites. We may combine personal and non-personal information about you collected by us or by our affiliates, retailers, distributors and other third parties with whom we have a relationship, and we may combine this information with information from external sources.

In obtaining your consent to collect, use, maintain, retain, transfer and disclose your personal information we will use reasonable efforts to inform you of the purpose for which personal information will be collected, used, maintained, retained, transferred or disclosed. The form of consent may vary depending on the circumstances and type of information disclosed. We will take into account the sensitivity of the personal information and your reasonable expectations when determining the appropriate form of consent.

The types of personal information we collect are as follows:

  1. User data – information relating to individuals who purchase the Services on behalf of our corporate customers (“User(s)”) –
    • 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);
    • 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); and
    • 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). 

 

  1. Coach Data – information relating to executive coaches who coach Participants (as defined below) or Mentors (as defined below) via the Services (“Coach(es)”) –
    • User profile information(name, photo, 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 or Mentors. We collect personal information that you share with Participants or Mentors via the Services, which may include a range of personal information such as your voice, picture, portrait, and likeness; 
    • Information you share in coaching sessions.Coaches may host video sessions with Participants or Mentors from time to time. Sessions may be recorded and we will collect personal information provided by you through recorded sessions such as your voice, picture, portrait, and likeness; 
    • 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); and
    • 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). 

 

  1. Mentor Data – information relating to corporate customers’ employees who are coached by Coaches and who themselves mentor Participants via the Services (“Mentor(s)”) –
    • 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 Mentors and Coaches or Participants. We collect personal information that you share with Coaches and Participants via the Services, which may include a range of personal information; 
    • 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 such as your voice, picture, portrait, and likeness;
    • 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); and 
    • Information our corporate customers share about Mentors. Most of the personal information we collect will come directly from the Mentor. However, from time to time, we may receive information from our corporate customers, such as high-level insights into Mentor’s job performance, to help facilitate effective coaching sessions. 

 

  1. Participant Data – information relating to individuals who are coached by Coaches or Mentors via the Services (“Participant(s)”) –
    • 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 or Mentors and Participants. We collect personal information that you share with Coaches or Mentors via the Services, 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 accounts 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 such as your voice, picture, portrait, and likeness;
    • 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); and 
    • 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 a Participant’s job performance, to help facilitate effective coaching sessions. 

 

  1. Website Visitor, CRM & Prospect Data – information concerning our Sites visitors, affiliates, 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– email address, name, your job title, your company/business name, contractual and billing details concerning our Users, including, but not limited to, your company/business address, name of the designated billing staff member, telephone number, email address, User account administrators, billing contacts and User authorized signatories; User needs and preferences, as identified by us or recognized through our engagement with the User; and
    • Information Concerning Our Prospects – contact and business details, cover letter, resume, 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 evaluate the usage of the Sites, we use automated devices and applications provided by third parties, such as Google Analytics. We use these tools to help us improve our products and services, our performance and user experiences. These entities may: (a) use cookies and other tracking technologies which collect information to perform their services; and (b) collect personal information directly through the use of cookies and other tracking technologies. Please go to these third-party websites to learn more about their privacy policies. If you wish to opt out of Google Analytics data collection, please use the Google Analytics Opt-Out Browser Add-On.

We may collect personal information even when you are not using the Sites and/or the Services. We may combine personal and non-personal information about you collected by us or by our affiliates, retailers, distributors and other third parties with whom we have a relationship, and we may combine this information with information from external sources.

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, stores, uses and discloses your personal information to provide services to Users and team members and to operate our business, including for the following purposes:

  • To provide our Services aimed at improving your productivity, adaptability and creativity.
  • To monitor and improve coaching performance of Coaches;
  • To authenticate the identity of our Users, Coaches, Mentors and Participants, and to allow them to access and use our Sites and/or Services;
  • To develop, operate and improve our machine learning technology that generates coaching insights for you and your organization;
  • To communicate regarding the Sites and/or the Services, including concerns or queries corporate customers, Users, Coaches, Mentors or Participants may have.
  • To provide assistance and support to our corporate customers, Users, Coaches, Mentors 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 Sites and/or the Services and to tailor the Sites and/or the Services to you. As noted below, we may also use cookies and related technologies to improve our website and collect statistical information about how the Sites and/or the Services are being used. Please review our Cookie Policy found at https://impro.ai/cookie-policy/;
  • 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 Sites and/or the Services, and thereby increase your engagement and overall satisfaction with the Sites and/or the Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business affiliates;
  • To create aggregated statistical data, inferred non-personal information or anonymized or pseudonymized data (rendered non-personal), which we, our business affiliates 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 Sites and/or the Services, e.g. ‘special categories’ under the GDPR), providing such personal information and using the Sites and/or 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 Privacy Policy. If you wish to revoke such consent, please contact us at pr*****@im***.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 collected, 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 the Sites and/or the 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 of same 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 the Sites and/or the Services and offerings;
  • in order to facilitate your potential restart of services with us;
  • in order to comply with our legal and contractual obligations;
  • 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 of the Sites and/or the Services, 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 pr*****@im***.ai.   

4. Data Sharing

Legal Compliance: In certain 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 the Sites and/or the Services. 

Service Providers: We engage selected third party companies and individuals to perform services complementary to our own (collectively, “Service Providers“). Such Service Providers include cloud-based providers such as Amazon Web Services and Microsoft Azure who 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. Please review the privacy policies of the Service Providers as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of the 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 the Sites and/or the 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 the 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 process personal information on our behalf as ‘data processors’, as further described in Section 9 below. 

Third Party Websites and Services: Our Sites and/or the 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. We do not assume any responsibility for the privacy practices, policies or actions of the operators of such website and third-party services.

We may disclose your personal information to Semrush Holdings, Inc., The Rocket Science Group and TWILIO, INC. and their respective affiliates to:

  • Prevent, detect, mitigate and investigate potentially illegal acts, fraud and/or security breaches, and to assess and manage risk, including to alert you if fraudulent activities have been detected on your account;
  • Store your personal information;
  • Offer you our newsletters and other correspondence;
  • Provide customer service, including to help service your account; and
  • Facilitate the processing of payment cards and payments when you pay for our products or services and we use the services of third-party providers to process your payment.

 

Please review the privacy policies of Semrush Holdings, Inc., The Rocket Science Group and TWILIO, INC. as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of Semrush Holdings, Inc., The Rocket Science Group and TWILIO, INC.

Sharing of personal information with your employer:

We value the confidential relationship established between you as a Participant or Mentor and our Coach or your mentor 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, the volume and types of performance breakthroughs you have realized as a result of the coaching process, the name of the project you are working on with your Coach, relevant dates of said project and amounts earned during said project. With your consent, we may also disclose the name of the project on which you worked with a Coach. 

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.

From time-to-time, we may also provide organizations with an analysis of your strengths, weaknesses, opportunities, and threats; however such analysis be aggregated and will not contain any personal information or identify individual team members in any way.

You hereby acknowledge and agree that our disclosure to your employer In accordance with the above may affect your employment relationship, qualifications, employment position and/or salary and we shall not be responsible for any costs, fees, damages, liabilities, losses or expenses of any kind with respect to same.

If you are a Participant who has engaged with us directly (rather than via your employer), we will not share any information with your employer.

Sharing of data with Coaches: In order to provide our Sites and/or the Services, Coaches may share personal information pertaining to Participants or Mentors they coach 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). Mentors may also share personal information pertaining to Participants who they are mentoring with their own Coach. We do not assume any responsibility for the privacy practices, policies or actions relating to such disclosure.

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, Mentors 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. We may share personal information with our personnel or contractors. 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 Sites and/or the 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 information 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.

We may also display your review(s) of our Services on our Sites.

5. Cookies & Tracking Technologies

To accomplish our business purposes, we may use a browser feature called a “cookie” to collect information when you access the Sites. Please go to https://impro.ai/cookie-policy/ to read our Cookie Policy.

6. Communications

Service Communications: We may send you notifications (through any of the means available to us, including by email, SMS or through our Sites and/or the Services) of changes or updates to our Sites and/or the 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 Sites and/or the 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 Sites and/or 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 pr*****@im***.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 Service Providers 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 Sites and/or 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 pr*****@im***.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 Privacy 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 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 “data 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 Sites and the Services, to the extent that such laws and regulations apply.

Impro.ai is the “data controller” (or “business”) of all the personal information and assumes the responsibilities of a data 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 “data processor” (or “service provider”, as defined by the CCPA). 

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 Sites and/or the. 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 Sites and/or the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Sites and/or the 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 Sites and/or the 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 majority: 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 majority in their local jurisdiction is using the Sites and/or 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 pr*****@im***.ai.  

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 Maetzler Rechtsanwalts GmbH & Co KG (“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 information). 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.   

11. Artificial Intelligence

When providing our products and services, we use third-party software applications that incorporate artificial intelligence technology and such technology may collect, use, maintain, retain, transfer and disclose your personal information. To obtain more information about our use of third-party software applications that incorporate artificial intelligence technology, please review our AI Privacy Notice attached to this Privacy Policy as Appendix A.

 

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 pr*****@im***.ai.  

APPENDIX A

AI PRIVACY NOTICE​

At Impro.ai Inc. (the “Company”, “we”, “us”, “our”), the privacy of its users, consumers, clients, service providers, distributors, retailers, suppliers and other individuals (“you”, “your”) is a top priority. We provide this AI Privacy Notice (the “Notice”) to give you information on how we use and protect your personal information in our use of third-party software applications that incorporate artificial intelligence technology (“AI Tools”). This Notice is supplemental to our Privacy Policy which you can view here.

 

About AI Tools We Use

When we use AI Tools, we upload documents into the AI Tools. Personal information and your confidential information may be contained within the documents we upload to the AI Tools. The AI Tools we use, use language models licensed from Azure OpenAI; a service owned by Microsoft Corporation. We cannot confirm that none of the personal information that the AI Tools process is used to improve Azure OpenAI products. We strongly encourage you to read the privacy policies of Microsoft Corporation to enable you to make an informed decision. We do not assume any responsibility for the privacy practices, policies or actions of the operators of Microsoft Corporation. We are a data controller of your personal information when it is processed while using our AI Tools and Microsoft Corporation is the data processor.

 

How We Protect Your Personal Information

We do not grant the providers of AI Tools access to the personal information that is processed by the AI Tools. Further, have an internal artificial intelligence policy that governs the limited circumstances in which AI Tools are used. We mandate that AI Tools are used only with human supervision and ensure that our staff are trained on privacy laws and methods of protecting personal information before processing any personal information using AI Tools.

We have measures in place to mitigate the use of your personal information in the AI Tools. If you request that we seek approval before using your personal information with the AI Tools, we will abide by such a request to the extent possible; however, you may not be able to use some or all of our products or services if we cannot obtain your consent to use your personal information with the AI Tools.

 

Why We Use AI Tools

In most cases, we process your personal information using AI Tools to improve the efficiency, quality, and speed of our products and services. For this purpose, we rely on our legitimate interest in using the AI Tools. This legitimate interest is to improve the delivery of our products and services to you.

 

What Types of Information We Use to Process Using AI Tools

In using AI Tools, we may process different types of personal information, such as, but not limited to:

(a) Information about you (for example, name, e-mail address and billing address);

(b) Information you share during any coaching sessions (for example, your employment position, your employment duties, etc.); and

(c) Various other types of personal information provided to us when you use our products or services.

 

In certain circumstances we may process other information about you using AI Tools, but we will ensure that we have the necessary lawful basis in place before doing so.

 

Questions or Comments

We welcome questions and comments about this Notice so please feel free to contact the Company’s Privacy Officer at: pr*****@im***.ai.

 

Last updated: December 19, 2024.