(i) about each customer, individual, entity, user or visitor (collectively "you" or "your");
which you provide to Intone when,
(a) accessing Intone's website located at https://www.intone.io/ (hereinafter referred to as "Website"), and/or
(b) using our AI-based desktop software application that enhances English pronunciation and accents in real time (hereinafter referred to as the "Service(s)").
2. Personal Information that Intone Collects from You
2.1 The term "Personal Information", or personal data, means any information about an individual from which that person can be identified. Personal Information does not include data where the identity of the individual has been removed (i.e., anonymous data).
2.2 Intone may collect, use, and store the following Personal Information:
2.2.1 Identity data includes Personal Information that could identify you, such as your full name, company name, age, gender, native language, voice audio recording, accent information and email address;
2.2.2 Contact data which includes data such as billing address/information, email address, and any other data you have provided to us in order for us to be able to provide you with the Services;
2.2.3 Technical data includes your Internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, characteristics of your device (including but not limited to laptop model, laptop name, manufacture, and CPU model), device load, application performance data, information about audio devices (including but not limited to the device name and manufacture), voice recordings from all users (including voice recordings from users who have approved live calls), and other technology on the devices you use to access the Services;
2.2.4 Transaction data which includes details about payments such as amount, currency and time of payment;
2.2.5 Profile data includes your username and password, purchases made by you, your interests, preferences, and feedback; and
2.2.6 Usage data includes information about how and when you use our Website and Services.
2.3 When accessing and using our Services, Intone will need you to provide us with access to your microphone to collect audio recordings of your voice speaking and accent information for the sole purposes of improving the Services we provide to you. Intone uses Jotforms to collect such audio recordings. We do not, however, obtain a voice print or any other information that could be used to identify you from your vocal data.
2.4 To assist you in protecting your Personal Information, Intone encourages you to only provide the necessary information that is required for your use of the Services.
2.5 To help Intone maintain the accuracy of your Personal Information, we encourage you to inform us via email when there are any changes that are required to be made to your Personal Information. Intone will respond to your request as soon as is reasonably practicable and make such corrections as are necessary to ensure the accuracy and correctness of your Personal Information.
3. How Your Personal Information is Collected
3.1 Intone uses various methods to collect Personal Information from and about you including through:
3.1.1 Direct interactions. You may provide us with your identity and contact data by filling in contact us forms and by corresponding with us via email or social media platforms. This includes Personal Information you provide when you:
(a) create a user account;
(b) use the Services;
(c) provide us with your feedback in relation to the Services; or
(d) contact us.
3.1.2 Automated technologies or interactions. As you interact with our Website and Services, we will automatically collect technical data about your browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies. This information is collected automatically and is used only to identify potential cases of abuse, resolve technical issues, optimizing the performance of the Website and Services for a better user experience, and establish statistical information regarding your use of our Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
3.1.3 Metadata. When you use our Website, we may collect metadata that results from such usage including: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), date and time of accessing our Website, and internet protocol address and location. The metadata will be primarily used to improve the quality of the Services Intone provides to you by analysing your usage behaviour in anonymised form and to prevent fraud, misuse of our information technology (IT) systems, as well as to ensure physical and network security. We may also use metadata for other purposes, including online advertising.
3.1.4 Third parties or publicly available sources. We may receive both non-personal and Personal Information about you from various third parties and public sources, such as contact data and transaction data from third party providers of technical, platform and payment, which we may combine with the information we collect from you. This helps us to improve the information's overall accuracy and completeness, and also helps us better tailor our interactions with you.
3.2 In general, the Personal Information you provide to Intone is used to help us communicate with you. For example, Intone uses your Personal Information to (i) make contact with you, (ii) provide you with the Services, and/or (ii) provide customer service and technical support.
4. The Purposes for which Intone Collects Your Personal Information
4.1 Intone collects your Personal Information in order to enter into a contractual relationship with you for the purposes of providing you with the Services. We also collect Personal Information for the following purposes:
4.1.1 providing you with access to the Website and use of the Services as requested by you;
4.1.2 verifying your identity;
4.1.3 respond to, handling, and processing queries, complaints, feedback and requests from you. For example, we may contact you in relation to a question/query you may have submitted to our customer service team;
4.1.4 improving our Services, including by training our machine learning algorithms for voice accent enhancement;
4.1.5 informing you about changes to our Services, software, and any other Service-related notices;
4.1.6 protecting and enforcing our rights and interests as well as the rights and interests of our users and any other third party;
4.1.7 сarrying out any other actions for which we have received your consent;
4.1.8 performing research and analysis about your use of, or interest in, our Services, software, products, and content, or the services, products, and/or content offered by a third party;
4.1.9 to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings involving Intone;
4.1.10 to personalize your use of the Services;
4.1.11 to fulfill our contractual obligations;
4.1.12 managing your relationship with us;
4.1.13 sending you information, promotions, updates, marketing and advertising materials in relation to our Services or that of our third party partners, including providing you with information relating to our Website;
4.1.14 processing payment transactions;
4.1.15 preventing and investigate fraudulent or other criminal activity; and
4.1.16 any other purposes reasonably necessary, ancillary or related to the above specified purposes.
4.2 Wherever possible, Intone aims to obtain your explicit consent to process your Personal Information. We may continue to process your Personal Information on this basis until you withdraw your consent. You may withdraw your consent at any time by sending us an email at email@example.com. However, if you do so, please note that you may not be able to use the Website and make use of the Services further.
4.4 Retention of Personal Information. Intone will only retain Personal Information in an identifiable format for (i) a minimum period of seven (7) years; or (ii) for as long as is reasonably necessary to fulfill the purposes we collected such Personal Information for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When your Personal Information is no longer needed for the purpose for which such Personal Information was collected, we will take reasonable steps to destroy, delete or permanently de-identify your Personal Information.
5. Personal Information that we do not Process
We do not process or collect the following special categories of Personal Information about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and we do not engage in the processing of your genetic data or biometric data for the purposes of uniquely identifying you as a natural person, or process data concerning your health.
6. How Personal Information is Secured and Stored
6.1 Intone uses a third party service provider, namely, Amazon Web Services ("AWS") and Google Cloud Platform ("GCP") to deliver the Website and Services to you. As such, AWS and GCP implements security measures that include encryption, firewalls, password management and secure socket layer technology, which are designed to protect your information from unauthorized access and potential security breaches. You can find out more about: (i) AWS's security measures by clicking here: https://wa.aws.amazon.com/wellarchitected/2020-07-02T19-33-23/wat.pillar.security.en.html; and (ii) GCP's security measures by clicking here: https://cloud.google.com/security.
6.2 We will notify you and any applicable regulator of a breach where we are legally required to do so.
6.3 Any payments made via Intone are processed by our third-party payment processors i.e. the applicable bank making the transfers. Payment information is directly processed and secured by our third-party payment processors and cannot be accessed by Intone. We do not collect or store any payment card/account information, such as credit/debit card numbers, account numbers, or card authentication data, but we may receive information associated with your payment card/account information (e.g., your billing details) from our third-party payment processors.
6.4 You acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while Intone strives to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another registered user on the Website and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts.
7. Advertising and Marketing Mailings
7.1 When you create an account with us, and provide us with your email address, subject to applicable law, we and our third party service providers may send you emails regarding the Services and/or products we offer. You can choose to opt out of receiving emails from us at any time by emailing us at firstname.lastname@example.org. If you wish to opt out with more than one email address, you must submit a separate request for each email address. Every email sent from Intone will include the appropriate 'unsubscribe' link and instructions allowing you to opt out of receiving future emails or to change your contact preferences. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important Service information related to your account. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.
7.2 In the case where our third party service providers are sending you advertisements, we will ensure that your Personal Information may only be accessed in a personally de-identified manner, so that it will no longer function as Personal Information, or information personally identifiable to yourself, unless you provide consent for the same.
8. Sharing Personal Information
8.2 Intone may also share Personal Information with other third parties if Intone has a good-faith belief that access, use, preservation or disclosure of the Personal Information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce our rights, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property or safety of our users or the public as required or permitted by law.
8.3 Intone may share recordings of your voice (without including any of your other Personal Information) with our third party service providers for the purposes of providing the Services, including but not limited for data labeling purposes.
9. Third Party Privacy Policies
10. Your Rights under The European Union's General Data Protection Regulation
For the purposes of complying with the General Data Protection Regulation 2016/679 ("GDPR"), you have certain rights as provided under GDPR and applicable data protection laws in relation to your Personal Information. You have the right to:
(i) Request Access to your Personal Information (commonly known as a 'data subject access request'). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
(ii) Request Connection of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(iii) Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(iv) Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel the processing of your Personal Information will impact on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(v) Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful, but you do not want us to erase the data; where you need us to hold the data even if we no longer require the data as you need the data to establish, exercise or defend legal claims; or you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use your Personal Information.
(vi) Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. 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.
(vii) Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you are a resident in the European Economic Area (EEA) or UK and you believe your Personal Information is being unlawfully processed, you have the right to complain to your local data protection supervisory authority. You can find their contact details here.
If you are a resident in Switzerland, the contact details of the data protection authorities are available here.
You may exercise any of your rights in relation to your Personal Information by written notice to Intone, using the contact details set out below. Should you have any cause for complaint about our use of your Personal Information, please contact us using the details provided below and we will endeavor to solve the problem for you.
You expressly agree that Intone may transfer your Personal Information to countries outside of Europe and the UK. As such, Intone will take appropriate steps to ensure that: (i) Intone will comply with our obligations as provided under the GDPR or any other applicable data protection legislation, in respect of the transfer of your Personal Information while such Personal Information remains in Intone's possession or under our control; and (ii) the recipient/third party of the Personal Information outside of Europe is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the GDPR or any other applicable data protection legislation.
11. Your Rights under the California Consumer Privacy Act and California Privacy Regulation Act
11.1 To the extent that the California Consumer Privacy Act ("CCPA") and California Privacy Regulation Act ("CPRA") is applicable to either Intone or you: both parties agree to comply with all of its obligations under the CCPA and CPRA; and in relation to any communication of 'Personal Information' as defined by the CCPA and CPRA, the parties agree that no monetary or other valuable consideration is being provided for such Personal Information and therefore neither party is 'selling' (as defined by the CCPA and CPRA) Personal Information to the other party.
11.2 The principal rights you have under the CCPA and CPRA include but are not limited to:
11.2.1 Right to access/know. You have the right to request that we provide you with details of the Personal Information (pertaining to you specifically) that we collect, use, disclose and sell. To submit a request, please submit an email request to email@example.com and include 'CCPA Right to Know' in the subject line. In your email, please specify the details you would like to know, and specify the Personal Information you would like to access. You will be asked to provide sufficient information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the Personal Information at issue. We will respond to your request in accordance with the CCPA and CPRA. In the event we deny your request, we will provide you with an explanation.
11.2.2 Right to delete. You may request the deletion of Personal Information that we collect or hold about you. To submit a request to delete Personal Information, email your request to firstname.lastname@example.org and include 'CCPA Request to Delete' in the subject line. Please make sure you specify in your request what Personal Information you would like us to have deleted.
11.2.3 Right to non-discrimination. You have the right not to be denied access to the Services just because you exercised your rights under the CCPA and CPRA. However, should such Personal Information be necessary for us to provide you with the Services, we may not be able to complete the provision of the Services/transaction.
11.2.4 Right to opt out. You may request us to stop collecting your Personal Information ('opt-out') by sending us an email to email@example.com. However, please note that we must wait at least twelve (12) months before asking you to opt back into the collection of your Personal Information, unless you provide us with prior authorization.
11.3 Under CCPA, Personal Information does not include:
11.3.1 publicly available information from government records;
11.3.2 de-identified or aggregated consumer information;
11.3.3 information excluded from the CCPA's scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
11.3.4 Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
11.4 Both parties agree to notify the other immediately if it receives any complaint, notice, or communication that directly or indirectly relates to either party's compliance with the CCPA and CPRA. Specifically, Intone shall notify you within ten (10) business days if we receive a verifiable consumer request under the CCPA and CPRA.
12. Yours Rights under the Australian Privacy Act 1988
Intone has adopted the Australian Privacy Principles as incorporated in the Privacy Act 1988 ("Australian Privacy Act"). As such, the Australian Privacy Act will govern the manner in which we collect, use, disclose, store, secure and dispose of your Personal Information.
If you believe that your privacy rights have been breached under the Australian Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner ("OAIC"). The OAIC can be contacted at either www.oaic.gov.au or by calling 1300 363 992.
You expressly agree to Intone disclosing Personal Information to recipients/third parties located outside of Australia for the following purposes:
(i) to our related body corporates, partnerships and joint venture entities; and
(ii) to our data hosting and Cloud-based information technology (IT) service providers.
Intone shall endeavour to take reasonable steps to ensure that the third party service providers/entities based outside of Australia, do not breach the privacy obligations relating to your Personal Information. As such, we will take appropriate steps to ensure that: (i) Intone will comply with our obligations as provided under the Australian Privacy Act or any other applicable data protection legislation, in respect of the transfer of your Personal Information while such Personal Information remains in our possession or under our control; and (ii) the recipient/third party of the Personal Information outside of Australia is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the Australian Privacy Act or any other applicable data protection legislation.
13. International Transfers of Personal Information
To facilitate our global operations within the APAC regions, and Latin and Central America, Intone may transfer, store, and process your Personal Information with our third party service providers based outside of the country in which you are based/residing in. As such, Data protection and privacy laws in those countries may differ from the laws applicable to your country of residence. Where we transfer, store, and process your Personal Information outside of the country in which you are based/residing in, Intone will ensure that the appropriate safeguards are in place to ensure an adequate level of data protection.
14. Vulnerability Issues
Should you wish to report any vulnerability issues anonymously, you can click on the following link: https://forms.gle/xpYhH3AXkpCd41g69 and complete the form.
15. Personal Information from Children/Minors
We encourage parents and guardians to observe, participate in, and/or monitor and guide their children's online activity. The Website and Services are not directed to children under the age of eighteen (18) years of age and we do not knowingly collect Personal Information from children under the age of eighteen (18). If we discover that a child under eighteen (18) has provided us with Personal Information, you may contact us, and we will promptly delete such Personal Information from our systems.
16. Log Files
We follow a standard procedure of using log files. These files log when visitors visit Intone's Website. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of such log file information is for analyzing trends, administering the Website, tracking users' movement on the Website, and gathering demographic information.
17. Cookies and Web Beacons
17.1 Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. Cookies allow data gathered on one web/mobile app page to be stored until the data is needed for use on another, allowing a website/mobile app to provide you with a personalised experience and the website/mobile app owner with statistics about how you use the website/mobile app so that the website /mobile app can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web/mobile app browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
For more general information on cookies, please read "What Are Cookies".
17.2 The following types of cookies are used on Intone's Website:
17.2.1 strictly necessary cookies / technical cookies: these cookies are required to run the Website and provide you with the Services and may, among others, allow us to identify your hardware and software, including your browser type.
17.2.2 statistical/analytic cookies: these cookies enable us to recognize users, count the number of users, and collect information such as your actions on the Website, including the web pages you visit and the content you retrieve.
17.2.3 performance cookies: these cookies collect information about how users interact on the Website, enabling us to identify errors and test new functionalities to improve its performance.
17.2.4 functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Website, for example by storing your preferences (e.g., language and location).
17.2.5 (third party) tracking/advertising cookies: these cookies collect information about users, sources of traffic, page visits, and the advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal Information. These cookies are also used for statistical and research purposes.
17.4 Intone may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer to (i) track your actions on the Website and when using the Services, by accessing and interacting with the cookies stored on your computer; and (ii) collect statistical information related to operating the Website, the Services or products, utilities, advertisements, or other offerings.
18. Opt-Out Rights
You can stop all collection of Personal Information by Intone by not accessing the Website, and the Services, or by requesting to opt-out via email at firstname.lastname@example.org. Please note that on receipt of your request to opt-out and stop the collection and processing of your Personal Information, Intone will retain your Personal Information for thirty (30) days, after which all your Personal Information and related data will be permanently deleted.
20. Contact Information
Should you have any questions or concerns regarding privacy while using the Website and Services, please send us a detailed message via email to email@example.com and Intone will use its best endeavors to resolve your concerns.