Privacy – Infergram

INFERGRAM PRIVACY POLICY

Last Updated: November 20th, 2024

This Privacy Policy describes how Phocys Labs, Inc. (“Infergram,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you visit our websites, including phocyslabs.com and infergram.com, (“Sites”) as well as when you use our products and services, including our software client, mobile applications, and chatbot (collectively, our “Services”), or when you otherwise interact with us, such as through our customer support channels or on social media pages. This Privacy Policy does not apply to products and services that link to a different privacy policy. Additionally, this Privacy Policy does not apply to any third-party applications or software that integrate with the Services. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy. For information on how third parties that integrate our Services use your information, please review the third parties’ disclosures.

We may change this Privacy Policy from time to time. We will notify you by revising the date at the top of this policy, if we make any changes. If we make material changes to this Privacy Policy, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information

Use of Information

Disclosures of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Data Retention

Your Choices

Additional Disclosures for Individuals in Certain U.S. States

Additional Disclosures for Individuals in Europe

COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us or use our Sites and Services. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you create an account, participate in a meeting or use another product or service that integrates our Services (e.g., Zoom, Google Meet, Microsoft Teams, Slack, and Cisco Webex), provide feedback, make a purchase, communicate with us via third-party platforms, such as LinkedIn, Twitter, and Facebook, request customer support, explicitly opt into our collection of specific data from you or otherwise communicate with us. The types of personal information that we may collect include your name, username, email address, postal address, phone number, account login information for our accounts and accounts on video conferencing platforms, profile photo, your image and/or voice, social media profile ID, user presentations, text chat communications, feedback on our Services, hashed payment card value and other payment-related information, like your billing address, and any other information you choose to provide.

Information We Collect Automatically During Interactions with Us

When you access or use our Services or otherwise interact with us, we automatically collect, or process on behalf of our customers, certain information, including:

Meeting Information: Certain features and integrations of our Services will collect meeting details, including the names of invitees and participants, the meeting subject and description, meeting audio and visual files from a user’s video and audio input and output, meeting location, and any included meeting access details, like the meeting ID. Except where the meeting chat and notifications are disabled, unavailable or unsupported, we notify users in the video conference that the meeting is being measured and data is being collected, and we provide details on why, along with an opt-out option. We provide notice giving meeting attendees an opportunity to opt out of collection of meeting information, except where meeting chat and notices have been disabled or are unsupported.

Transactional Information: When you purchase our Services, we collect information about the transaction, such as Service details, purchase price, and the date of the transaction.

Activity, Device and Usage Information: We collect information about your activity on our Services and how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers and hashed email address, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services. If you download any of our mobile apps, we may access information you have stored on your mobile device operating system. For example, with your permission, we may access calendar information from your mobile device’s calendar.

Approximate Location Information: We collect your approximate location information from calendar invitations as well as from your IP address, as described below.

Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and other tracking technologies we use, and the choices available to you, see the Your Choices section below.

Information Collected via Google Account Integration: When you create a new account, if you consent to connect your Google account to your Infergram account, we may, either now or in the future, collect your Google user data via Google’s Workspace APIs that we may use for developing, improving, or training personalized AI and/or ML models, including (i) Google account information (email address and name); (ii) Google Calendar data, including event titles, descriptions, dates/times, and guest lists; (iii) Gmail data, including email messages (subject, body, recipients, senders, and other metadata) and settings; (iv) Google Docs content, specifically anything that users add to the meeting notes documents that Infergram generates automatically; (v) Google Drive content more broadly (including any Docs, Slides, or other files stored in the user’s Google Drive); and (vi) Google Chat data, including chat messages, metadata, and settings. Any user data collected via Google Workspace APIs may be transferred to third party AI tools in connection with the Services. We do not, and do not permit third party AI tools to, use user data collected via Google Workspace APIs to develop, improve, or train generalized/non-personalized AI and/or ML models. We do not sell user data collected via Google Workspace APIs to third parties.

Information We Collect from Other Sources

We also obtain information about you from other sources. For example, we may collect information from the video conferencing platforms you use, from third-party data brokers who provide us with audio and visual data sets, or from other users, such as when they refer our Services to you. We may also collect personal information from third parties who use our Services to provide their own products and services or that integrate our Services into their products and services, such as those that integrate our Services into the social media filters they offer.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. Examples of information we may derive or infer include the following:

Analytics: We use audio and visual information to score user’s affect and behavior during meetings and to produce analytics, like users’ individual talk times;
Demographics: We also use audio and visual information, as well as other information like language, to infer certain demographic characteristics about users, which we use to improve our models and increase the accuracy of their output. We also infer users’ role during a meeting, such as the client or team manager;
Company Affiliation: We use users’ names and email addresses to identify them during meetings and to infer company affiliation, which enables us to compile metrics on each company’s participation during a meeting;
Meeting Characteristics: We use meeting scheduling information to infer characteristics of a scheduled meeting, such as identifying its type or purpose; and
Approximate Location: We use IP addresses to infer users’ approximate location.

USE OF INFORMATION

We use the information we collect to analyze users’ participation during meetings, including monitoring and scoring user sentiment and engagement. We also use the information we collect to:

When you create a new account, we will ask your consent to connect your Google or Microsoft account to your Infergram account, thereby providing us with access to your calendar. The calendar integration checks your schedule and determines which meetings to add our services to. When integrating with your Google or Microsoft calendar, Infergram stores calendar event titles, times, attendee information, and video conferencing access links. Calendar event timing and video conferencing access links are used to automatically include Infergram Dashboard on your calendar events. Calendar event titles and attendee information are used to customize and compute Infergram Dashboard’s analytics for attendees. This data (including but not limited to all Google user data referenced above in the “Information Collected via Google Account Integration” section) is stored in an encrypted database and is not shared with third parties other than as described in the “Disclosures of Information” section below. Third-party AI tools are not permitted to use any user data collected via Google Workspace APIs to develop, train, or improve generalized/non-personalized AI/ML models.
Monitor and analyze trends, usage, and activities in connection with our Services and generate reports with our analysis, including real-time reports and alerts;
Make inferences and derive information about users and their organizations, including for purposes of compiling metrics about an organization’s or user’s participation in a meeting, as described above in Information We Derive;
Provide, maintain, and improve (consistent with your account settings) our Services, including maintaining user accounts with us and using information to train and improve our models within our Services;
Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
Respond to your comments and questions and provide customer service;
Communicate with you about products, services, and events offered by Infergram and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
Personalize your experience with us, including by tracking your preferences on our Services;
Send you technical notices, security alerts, and support and administrative messages;
Debug to identify and repair errors in our Services;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Infergram and others;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.

DISCLOSURES OF INFORMATION

In certain circumstances, we disclose (or permit others to directly collect) information about you. We disclose personal information as otherwise described in this Privacy Policy and in the following ways:

Infergram Users. We disclose information with other users, including sharing real-time reporting and analytics with other meeting participants, as well as additional reporting after the meeting.
Vendors and Service Providers. We make available personal information available to our vendors, service providers, and consultants who perform services on our behalf, such as companies that assist us with web hosting, data storage, data analytics, payment processing, fraud prevention, customer service, AI tools, and marketing and advertising. We may also allow users within an organization to access user data.
For Marketing Purposes. If you provide a review, testimonial, or feedback about our Services, or post content in another public area of our Services, the public/other users of our Services may be able to see this information, or we may share this information publicly.
Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We may disclose information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
To Protect the Rights of Infergram and Others. We may disclose information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Infergram, our users, the public, or others.
Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Corporate Transactions. We may disclose personal information in connection with, or during negotiations of certain corporate transactions, including, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Consent. We make your personal information available to third parties when we have your consent or you intentionally direct us to do so.
Aggregated Data. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law.

TARGETED CONTENT DELIVERY AND ANALYTICS

We engage others to provide analytics services and perform related services across the web and in mobile apps. To do so, these entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by Infergram and others to, among other things, analyze and track data, determine the popularity of certain content and deliver content targeted to your interests on our Services and other websites, and better understand your online activity. You can opt out of cookie-based content delivery on our website by clicking the “Cookie Settings” button below and following the prompts. Your opt-out choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you visit our website from a new device or browser, or if you clear your browser’s cookies.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Infergram is based in the United States, and we may process your information in other jurisdictions. Therefore, we, and those that perform work for us, may transfer your information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We provide adequate safeguards for the transfer of information in accordance with applicable law, such as by obtaining your consent, relying on the adequacy decisions from relevant regulatory bodies, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at privacy@infergram.com.

DATA RETENTION

We store information we collect for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. We store your audio and video information, including information derived therefrom, in accordance with our internal policies, but in no case for longer than 2 years. For paid accounts, we will store your data until you (i) stop paying, or (ii) request that we delete some or all of your data.

YOUR CHOICES

In-Meeting Choices

During a meeting, you (as a host or meeting participant) can remove Infergram from the meeting by disabling or canceling the application, and as a host you can remove the Infergram from the meeting for any participant in the same way you would remove any other meeting participant from the meeting.

Account Information

You may update and correct certain account information at any time by logging into your account or emailing us at privacy@infergram.com. If you wish to delete your account, review the “How to Delete My Account” instruction or email us at privacy@infergram.com with your account information, but note that we may retain certain information as required by law or for our legitimate business purposes.

Infergram uses cookies and similar tracking technologies to analyze use of our Services and how consumers are interacting with our marketing communications. You can usually adjust your browser settings to remove or reject all or some browser cookies. You may also adjust certain cookie settings using the consent management tool on our Services. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Do Not Sell My Personal Information

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‍Communications Preferences

You may opt out of receiving promotional emails from Infergram by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS RESIDING IN CERTAIN U.S. STATES

Numerous states, including California, Colorado, Connecticut, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Privacy Laws”). If you are a resident of one of these states and to the extent Infergram is subject to the State Privacy Laws, this section applies to you.

Other Details About our Information Practices

We collect personal information directly from you (for example, when you place an order on our Services), automatically when you access or use our Services, and from third-party sources, each described in more detail in the Collection of Personal Information section above.
We do not collect information that is considered “sensitive” under State Privacy Laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
We do not knowingly sell personal information about consumers under the age of 16.

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Your Privacy Rights

Opt Out of Sales, Sharing, and Targeted Advertising

As described in the Targeted Analytics section above, we process personal information to understand and improve your experience with our Services and to serve you advertisements on non-Infergram properties. Some of these activities may be considered “sales” or “sharing” of your personal information under the State Privacy Law that applies to you. You can opt out of cookie-based content targeting by clicking the “Cookie Settings” button below and following the prompts. You will need to renew your opt-out choice if you visit our website from a new device or browser or if you clear your cookies because your opt-out choice will be linked to your browser only. If you reside in California, you can also opt out of web-based content targeting by visiting our website with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control.

Do Not Sell My Personal Information

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Access, Deletion, Correction

Depending on your state of residence, you may have the right to request access to, or deletion or correction of, your personal information. To make such a request with respect to your personal information, login to your account and make the desired corrections or deletions. If you do not have an account or were a meeting participant, please reach out to the meeting host to request deletion of a meeting report. Please contact us at privacy@infergram.com if you have further questions or need assistance.

Appeals

If we deny your request, you may have the right to appeal our decision by contacting us at privacy@infergram.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents

If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or signed permission from the individual who is the subject of the request.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

To exercise any of the rights listed, above, please contact us at:

Phocys Labs, Inc.

PO Box 14391

Van Nuys, CA 91409

‍Email: privacy@infergram.com

‍Telephone: (323) 325-5522‬

‍ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing

When we process your personal data as described above, we do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the Services you requested).

When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).

To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Subject Requests

Please see the Your Privacy Rights section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email your request to privacy@infergram.com.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you have any questions about this Privacy Policy, please contact us at privacy@infergram.com.

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INFERGRAM PRIVACY POLICY

Last Updated: November 20th, 2024

CONTENTS

Collection of Information

Use of Information

Disclosures of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Data Retention

Your Choices

Additional Disclosures for Individuals in Certain U.S. States

Additional Disclosures for Individuals in Europe

COLLECTION OF INFORMATION

Information You Provide to Us

Information We Collect Automatically During Interactions with Us

When you access or use our Services or otherwise interact with us, we automatically collect, or process on behalf of our customers, certain information, including:

Meeting Information: Certain features and integrations of our Services will collect meeting details, including the names of invitees and participants, the meeting subject and description, meeting audio and visual files from a user’s video and audio input and output, meeting location, and any included meeting access details, like the meeting ID. Except where the meeting chat and notifications are disabled, unavailable or unsupported, we notify users in the video conference that the meeting is being measured and data is being collected, and we provide details on why, along with an opt-out option. We provide notice giving meeting attendees an opportunity to opt out of collection of meeting information, except where meeting chat and notices have been disabled or are unsupported.

Transactional Information: When you purchase our Services, we collect information about the transaction, such as Service details, purchase price, and the date of the transaction.

Activity, Device and Usage Information: We collect information about your activity on our Services and how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers and hashed email address, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services. If you download any of our mobile apps, we may access information you have stored on your mobile device operating system. For example, with your permission, we may access calendar information from your mobile device’s calendar.

Approximate Location Information: We collect your approximate location information from calendar invitations as well as from your IP address, as described below.

Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and other tracking technologies we use, and the choices available to you, see the Your Choices section below.

Information Collected via Google Account Integration: When you create a new account, if you consent to connect your Google account to your Infergram account, we may, either now or in the future, collect your Google user data via Google’s Workspace APIs that we may use for developing, improving, or training personalized AI and/or ML models, including (i) Google account information (email address and name); (ii) Google Calendar data, including event titles, descriptions, dates/times, and guest lists; (iii) Gmail data, including email messages (subject, body, recipients, senders, and other metadata) and settings; (iv) Google Docs content, specifically anything that users add to the meeting notes documents that Infergram generates automatically; (v) Google Drive content more broadly (including any Docs, Slides, or other files stored in the user’s Google Drive); and (vi) Google Chat data, including chat messages, metadata, and settings. Any user data collected via Google Workspace APIs may be transferred to third party AI tools in connection with the Services. We do not, and do not permit third party AI tools to, use user data collected via Google Workspace APIs to develop, improve, or train generalized/non-personalized AI and/or ML models. We do not sell user data collected via Google Workspace APIs to third parties.

Information We Collect from Other Sources

Information We Derive

We may derive information or draw inferences about you based on the information we collect. Examples of information we may derive or infer include the following:

Analytics: We use audio and visual information to score user’s affect and behavior during meetings and to produce analytics, like users’ individual talk times;
Demographics: We also use audio and visual information, as well as other information like language, to infer certain demographic characteristics about users, which we use to improve our models and increase the accuracy of their output. We also infer users’ role during a meeting, such as the client or team manager;
Company Affiliation: We use users’ names and email addresses to identify them during meetings and to infer company affiliation, which enables us to compile metrics on each company’s participation during a meeting;
Meeting Characteristics: We use meeting scheduling information to infer characteristics of a scheduled meeting, such as identifying its type or purpose; and
Approximate Location: We use IP addresses to infer users’ approximate location.

USE OF INFORMATION

We use the information we collect to analyze users’ participation during meetings, including monitoring and scoring user sentiment and engagement. We also use the information we collect to:

When you create a new account, we will ask your consent to connect your Google or Microsoft account to your Infergram account, thereby providing us with access to your calendar. The calendar integration checks your schedule and determines which meetings to add our services to. When integrating with your Google or Microsoft calendar, Infergram stores calendar event titles, times, attendee information, and video conferencing access links. Calendar event timing and video conferencing access links are used to automatically include Infergram Dashboard on your calendar events. Calendar event titles and attendee information are used to customize and compute Infergram Dashboard’s analytics for attendees. This data (including but not limited to all Google user data referenced above in the “Information Collected via Google Account Integration” section) is stored in an encrypted database and is not shared with third parties other than as described in the “Disclosures of Information” section below. Third-party AI tools are not permitted to use any user data collected via Google Workspace APIs to develop, train, or improve generalized/non-personalized AI/ML models.
Monitor and analyze trends, usage, and activities in connection with our Services and generate reports with our analysis, including real-time reports and alerts;
Make inferences and derive information about users and their organizations, including for purposes of compiling metrics about an organization’s or user’s participation in a meeting, as described above in Information We Derive;
Provide, maintain, and improve (consistent with your account settings) our Services, including maintaining user accounts with us and using information to train and improve our models within our Services;
Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
Respond to your comments and questions and provide customer service;
Communicate with you about products, services, and events offered by Infergram and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
Personalize your experience with us, including by tracking your preferences on our Services;
Send you technical notices, security alerts, and support and administrative messages;
Debug to identify and repair errors in our Services;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Infergram and others;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.

DISCLOSURES OF INFORMATION

Infergram Users. We disclose information with other users, including sharing real-time reporting and analytics with other meeting participants, as well as additional reporting after the meeting.
Vendors and Service Providers. We make available personal information available to our vendors, service providers, and consultants who perform services on our behalf, such as companies that assist us with web hosting, data storage, data analytics, payment processing, fraud prevention, customer service, AI tools, and marketing and advertising. We may also allow users within an organization to access user data.
For Marketing Purposes. If you provide a review, testimonial, or feedback about our Services, or post content in another public area of our Services, the public/other users of our Services may be able to see this information, or we may share this information publicly.
Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We may disclose information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
To Protect the Rights of Infergram and Others. We may disclose information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Infergram, our users, the public, or others.
Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Corporate Transactions. We may disclose personal information in connection with, or during negotiations of certain corporate transactions, including, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Consent. We make your personal information available to third parties when we have your consent or you intentionally direct us to do so.
Aggregated Data. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law.

TARGETED CONTENT DELIVERY AND ANALYTICS

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

DATA RETENTION

YOUR CHOICES

In-Meeting Choices

Account Information

Do Not Sell My Personal Information

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‍Communications Preferences

ADDITIONAL DISCLOSURES FOR INDIVIDUALS RESIDING IN CERTAIN U.S. STATES

Other Details About our Information Practices

We collect personal information directly from you (for example, when you place an order on our Services), automatically when you access or use our Services, and from third-party sources, each described in more detail in the Collection of Personal Information section above.
We do not collect information that is considered “sensitive” under State Privacy Laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
We do not knowingly sell personal information about consumers under the age of 16.

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Your Privacy Rights

Opt Out of Sales, Sharing, and Targeted Advertising

Do Not Sell My Personal Information

‍

Access, Deletion, Correction

Appeals

Authorized Agents

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

To exercise any of the rights listed, above, please contact us at:

Phocys Labs, Inc.

PO Box 14391

Van Nuys, CA 91409

‍Email: privacy@infergram.com

‍Telephone: (323) 325-5522‬

‍ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing

When we process your personal data as described above, we do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the Services you requested).

To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

Data Subject Requests

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you have any questions about this Privacy Policy, please contact us at privacy@infergram.com.

INFERGRAM PRIVACY POLICY

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