Last modified November 15, 2017

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Sentient Technologies USA LLC (“Sentient Technologies”) is committed to protecting the privacy of individuals who visit the Websites (“Visitors”) and individuals who register to use the Services (“Customers”) as defined below. This Privacy Policy describes Sentient Technologies’ privacy practices in relation to the use of the Websites.

1. Websites covered

This Privacy Policy covers the information practices of websites that link to this Privacy Policy, including https://www.sentient.ai, and other Sentient Technologies websites (the “Websites”) as well as our Ascend and Aware services (the “Services”). This Privacy Policy describes how Sentient Technologies collects, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access and correction of your personal information.

2. Information collected

When expressing an interest in obtaining additional information about the related applications and Services offered by Sentient Technologies or registering to use the Services, Sentient Technologies may require you to provide personal contact information, such as name, company name, address, phone number, and email address. Sentient Technologies may also ask you to provide additional information, such as company annual revenues, number of employees, or industry. The information described in this paragraph is referred to collectively as “Website User Data.”

In addition, when you visit the Websites, Sentient Technologies and its partners may collect certain information by automated means, such as cookies or similar technologies (“Website Navigational Information”). A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We also may use third-party website analytics tools (such as Omniture or Google), that collect information about visitor traffic on our sites. The information we may collect by automated means includes: standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on Websites (such as the Web pages viewed and the links clicked) to analyze trends in the aggregate and administer the site.

3. Use of information collected

Sentient Technologies uses Website User Data to perform the services requested. For example, if you fill out a “Contact Me” Web form, Sentient Technologies will use the information provided to contact you about your interest in the Services.

Sentient Technologies may also use Website User Data for marketing purposes. For example, Sentient Technologies may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding Sentient Technologies and its partners, such as information about promotions or events.

Sentient Technologies uses credit card information solely to check the financial qualifications of prospective Customers and to collect payment for the Services.

Sentient Technologies uses Website Navigational Information to operate and improve the Websites. Sentient Technologies may also use Website Navigational Information alone or in combination with Website User Data to provide personalized information about Sentient Technologies usage.

4. Website Navigational Information

Cookies and IP Addresses

Sentient Technologies uses commonly-used information-gathering tools, such as cookies or similar technologies, to collect Website Navigational Information. This section describes the types of Website Navigational Information that may be collected on the Websites and how this information may be used.

Cookies – When you visit the Websites, Sentient Technologies’ servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser.

Sentient Technologies uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate the Websites, but the functionality and features of the Services may be affected, and you may not be able to successfully use the Services. Similarly, if you disable JavaScript, some features of the Websites may not function properly, and some areas of the Websites may not function at all.

If you have chosen to identify yourself to Sentient Technologies, Sentient Technologies uses session cookies containing encrypted information to be able to uniquely identify you. Each time you log into the Services, a session cookie containing an encrypted, unique identifier that is tied to your account is placed your browser. These session cookies allow Sentient Technologies to uniquely identify you when you are logged into the Services and to process your online transactions and requests. Session cookies are required to use the Services.

Sentient Technologies uses persistent cookies that only Sentient Technologies can read and use to identify browsers that have previously visited the Websites. When you purchase the Services or provide Sentient Technologies with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that Sentient Technologies places on your Web browser. Sentient Technologies is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, Sentient Technologies does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Websites, but you will not be able to successfully use the Services.

Sentient Technologies may use information from session and persistent cookies in combination with Website User Data to provide you with information about Sentient Technologies and the Services.

Sentient Technologies may share certain information that it collects using cookies with third parties. For example, Sentient Technologies may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Websites, such as Google Analytics or Omniture. Sentient Technologies may also contract with third-party advertising networks that collect IP addresses and other information from the Websites, from emails, and on third-party Websites. Ad networks follow your online activities over time by collecting Web Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps Sentient Technologies manage and track the effectiveness of its marketing efforts. Third parties, with whom Sentient Technologies may partner to provide certain features on the Websites or to display advertising based upon your Web browsing activity, may use Flash cookies to collect and store information. The information that Sentient Technologies may share with third parties described in this paragraph, however, does not include any personally identifiable information. If you wish to opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.

To learn how to opt out of certain cookies using your browser settings click here.

IP Addresses – When you visit the Websites, Sentient Technologies collects your IP addresses to track and aggregate non-personal information. For example, Sentient Technologies uses IP addresses to monitor the regions from which Customers and Visitors navigate the Websites.

Do Not Track – Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Websites visited by the user about the user’s browser DNT preference setting. Sentient Technologies does not currently commit to responding to browsers’ DNT signals with respect to the Websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Sentient Technologies takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Sharing of Information Collected

Service Providers

Sentient Technologies uses third parties who provide services on our behalf to help with our business activities such as managing our credit card processing. Our contracts with these companies prohibits them from using your information for any other purpose.

Compelled Disclosure

Sentient Technologies reserves the right to use or disclose information provided if required by law, such as to comply with a subpoena, or if Sentient Technologies reasonably believes in good faith that use or disclosure is necessary to protect Sentient Technologies’ rights, protect your safety or the safety of others and/or to comply with a judicial proceeding, court order, government request or legal process.

Sale to a Third Party

If Sentient Technologies, or substantially all of its business or assets, is acquired by a third party, Website User Data would be one of the assets that is transferred or acquired by the successor or acquirer. You will be notified via email and/or a prominent notice on our website of any change in (i) ownership; (ii) uses of your personal information; and (iii) choices you may have regarding your personal information.

6. International transfer of information collected

To facilitate Sentient Technologies’ global operations, Sentient Technologies may store, transfer and access Website User Data around the world, including the United States and other countries in which Sentient Technologies has operations.

Sentient Technologies participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

Sentient Technologies is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Sentient Technologies complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Sentient Technologies is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

7. Communications preferences

Sentient Technologies offers Customers and Visitors who provide contact information a means to choose how Sentient Technologies uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of Sentient Technologies’ marketing emails. Additionally, you may send a request specifying your communications preferences to support@sentient.ai. Customers cannot opt out of receiving transactional emails related to their account with Sentient Technologies or the Services.

8. Correcting and updating your information

Upon request Sentient Technologies will provide you with information about whether we hold any of your personal information. Customers may update or change their registration information by editing their user or organization record. You can update your information on the accounts page. For additional information not accessible from the accounts page, you can make a request to support@sentient.ai. Requests to access, change, or delete this information will be handled within 30 days.

9. Data retention

Sentient Technologies retains the information we receive as described in this Privacy Statement for the length of time needed to fulfill the purposes outlined in this Privacy Statement or as needed to comply with our legal obligations, resolve disputes and enforce our agreements.

10. Customer Data

As part of using our Services, Customers may submit electronic data or information to the Services (“Customer Data”) which may include personal information. The use of information collected through our Services shall be limited to the purpose of providing the service for which the Customer has engaged Sentient Technologies. Sentient Technologies generally has no direct relationship with the individuals to whom Customer Data may pertain, which we process on the behalf of our Customers. Any uses of Customer Data by Sentient Technologies are done so pursuant to Sentient Technologies’ Master Services Agreement (MSA). If personal information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the Customer (or his/her organization) directly. If an authorized Customer requests that we update or remove the data in question and the Customer has no ability to do so via use of the Services, we will acknowledge their request within 30 days. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.

We will retain personal data we process on behalf of our Customers for as long as needed to provide services to our Customer. Sentient Technologies will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

11. Security

The security, integrity and confidentiality of your information are extremely important to us. Sentient Technologies uses commercially reasonable administrative, technical, and physical security measures that are designed to protect Website User Data, but unfortunately, no security measures are perfect or impenetrable. If you have any questions about the security of your personal information, you can contact us at privacy@sentient.ai.

12. Children’s Guidelines

Sentient Technologies does not knowingly collect information from children under the age of 13. If Sentient Technologies becomes aware that it has collected information from a child, it will immediately delete that information.

13. Changes to this Privacy Statement

Sentient Technologies reserves the right to change this Privacy Statement. Sentient Technologies will provide notification of the material changes to this Privacy Statement through the Websites at least thirty (30) business days prior to the change taking effect. We encourage you to periodically review this page for the latest information on our privacy practices.

14. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Websites should be directed to privacy@sentient.ai or by mailing Sentient Technologies Privacy, Suite 2300, 1 California St, San Francisco, CA 94111.