Clarifai Data Privacy Policy

About This Privacy Policy

We start by telling you more about who we are and give a general overview of the information this Privacy Policy is intended to cover.

Personal Data We Collect Via Our Services

Next, we go into detail about the Personal Data we collect and how we use this data. For example, we are always striving to improve our services and your experience, and we collect certain Personal Data for these purposes. We may also sometimes use this data to comply with our legal obligations or to prevent violations of our contractual terms and policies.

Personal Data We Collect About Candidates

This section expands on the Personal Data we collect about Clarifai employment candidates, which we use in connection with our recruitment efforts.

How We Share and Transfer Personal Data We Collect

Here, we describe our practices regarding how Personal Data we collect is shared with our service providers and other third parties. For example, we may share your Personal Data with our payment processors as necessary to process your payment. This section also explains how we use information collected about you, through the use of cookies, to improve and customize your Clarifai experience. Finally, we address our age requirements for use of our Services. 

Your Privacy Rights

Your privacy rights may differ based on where you are located. In this section, we set out in detail special rights you may have in your jurisdiction and how to exercise those rights. We also describe the measures we take to ensure that transfers of Personal Data from Europe to the United States comply with applicable laws and regulatory frameworks (such as the GDPR).

Other Information

The final section of this Privacy Policy includes important information about controlling your Personal Data and notifications, updates to this Privacy Policy, and our contact information. If you have any questions or comments regarding this Privacy Policy or its substance, you can contact our privacy team at privacy@clarifai.com.

By using or accessing the Services in any manner you acknowledge that you have read and understand the practices and policies outlined in this Privacy Policy, including our collection, use and sharing of your Personal Data in the following ways. If you do not agree with this Privacy Policy, please do not access and use the Services. Your use of Clarifai’s Services is subject to the Terms of Service and this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service. If you have any questions, feel free to contact us at privacy@clarifai.com.

About This Privacy Policy

Who We Are

Clarifai, Inc. (“Clarifai,” “we,” or “us”) offers a full-lifecycle deep learning artificial intelligence platform for computer vision, natural language processing and more. We help organizations transform unstructured images, video, text and other electronic data into structured data at a significantly faster and more accurate rate than humans would be able to do on their own. You can find out more about us here.

If you are located in the European Economic Area ("EEA"), United Kingdom or Switzerland, the data controller of your Personal Data is Clarifai, Inc.

What This Privacy Policy Covers

This Privacy Policy describes how we collect, use and share your Personal Data for our business purposes, including:

• when you visit, use or interact with any of our websites (including https://www.clarifai.com/), social media pages or public forums (such as our blogs), eBooks or other publications, or when you receive marketing or sales communications from us or attend one of our webinars, conferences or other events (collectively referred to as our "Marketing Activities")
• when you access or use our Services as an authorized user ("Service User"), for example as an individual customer or an employee of a customer that has provided you with access to our Services
• when your Personal Data is included in the content that we process in connection with the Services ("Content")
• when you apply for a job or other role with us as an applicant or candidate ("Candidate")

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations.

This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. Similarly, this Privacy Policy may not apply to the Personal Data that we process as a data processor or service provider on behalf of our customers in the course of providing our Services. We are not responsible for the privacy practices of our customers or other third parties, which may differ from those described in this Privacy Policy.

Personal Data We Collect Via Our Services

This Section applies to the Personal Data that we collect and process in connection with our Marketing Activities and to the Personal Data of Service Users and individuals whose Personal Data may be included in Content.

Sources of Personal Data

We collect Personal Data about you from:

• You
  • when you provide such information directly to us, such as:
    • when you create an account and use our Services
    • when you send us Personal Data (including images, videos and text, and geolocation or other metadata attached to such Personal Data)
    • when you send us an email, ask for help from support, or otherwise contact us
  • when Personal Data is automatically collected when you use the Services, such as:
    • through Cookies (defined below)
    • if you use certain applications and software we make available (such as our SDKs and APIs), we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services
  • when you add annotations that include Personal Data about you to the data you send to us by using our models and algorithms
• Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
  
  • Service Users. Service Users may provide Personal Data about you when they use our Services:
    • when Service Users send Content to us when they use our Services and send us Personal Data about you, including, for example, images, videos, audio and text, and geolocation or other metadata attached to such Personal Data
    • if Service Users use certain applications and software we make available (such as our SDKs and APIs), we may receive and collect information transmitted from their computing device for the purpose of providing them the relevant Services, and the information may include Personal Data about you
    • when Service Users add annotations that include Personal Data to the Content they send to us when they use our Services by using our models 
  • Service providers. For example, we may use analytics of service providers to analyze how Service Users interact and engage with the Services, or third parties this may help us provide Service Users with customer support. We may also receive your Personal Data from third parties that provide us with sales leads.
  • Social networks and other platforms connected to the Services. If you are a Service User and provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service (e.g., Github or Google), you understand some content and/or information in those accounts may be transmitted into your account with us.
  • We utilize datasets from third party data providers and publicly available sources to provide and improve our Services, some of which may contain your Personal Data (such as images or videos of individuals).
• Us, when we add annotations that include Personal Data to the Content that Service Users send to us when they use our Services, by using our models and algorithms to make predictions about, or by adding tags that describe that Content.

Categories of Personal Data We Collect

The following table details the categories of Personal Data that we collect and have collected via our Services. For each category of Personal Data, the table also sets out the categories of sources and the third parties with whom we share that Personal Data.

Category of Personal Data	Examples of Personal Data Collected	Source	Third Parties With Whom We Share Data for Business Purposes
Contact Data/Identifiers	First and last name Email Company name Job title and function Phone number Location Password	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Social Network and other Connected Platform Data	URLs of publicly available accounts on social networks such as LinkedIn Online Identifiers Social media profile IDs Credentials from other online services you use to access the Services, such as email address, full name and profile image from when you sign into our Service using Google Sign-In	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Payment Information	Credit card number Debit card number Billing address	You	Service providers
Device/IP Information	IP address Browser	You Third parties	Service providers
Web Analytics	Browsing history Search history Geographic information Length of visit Pageviews Referral source adIDs Forms submitted Content downloaded	You Third parties	Service providers
Biometric Data	Images and videos and information relating to images or videos, such as patterns associated with images or videos for facial recognition purposes	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Other Visual Information	Data may include other types of information which may constitute Personal Data (e.g. an image of a car with a license plate).	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Geolocation and other metadata	Geolocation and other metadata which may constitute Personal Data.	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Predictions and Tags	You or a Service User may use our models and algorithms to make predictions about data that you or a Service User sends to us, or to add tags to such data. These predictions and tags may contain Personal Data, including age, gender or other demographic data, identifiers, biometric data or geolocation data.	You Third parties	Service providers Parties you or a Service User sharing your Personal Data with us authorizes, accesses or authenticates
Inferences, Predictions and Tags Generated by Us	We may infer new Personal Data from data we collect, including using automated means to generate information about your characteristics (such as using our models and algorithms to make predictions about age, gender and other demographics biometric data or geolocation data). We may also add tags constituting Personal Data to describe data we collect.	Generated by us	Service providers

 

How We Use Your Personal Data

We use the Personal Data described above in the context of our Services and to provide and improve our Services for our customers. Our business or commercial purposes for collecting this Personal Data include:

• To provide the Services to customers and Service Users to perform our contract with you or where we don't have a contract with you, in reliance on our legitimate interests, for example:
  • to operate and provide our Services and to tailor our Services to your needs and preferences,
  • to provide you with the content, products or services you access and request, and
  • to register, administer and maintain your account.
• To secure the Services in reliance on our legitimate interests, for example:
  • to track use of our Services (including our websites) for the purposes of maintaining the safety and security of our Services, including verifying accounts and activity, and investigating suspicious activity, and
  • to enforce our terms and policies, in reliance on our legitimate interest in promoting the safety and security of our Services, systems and applications and in protecting our rights and the rights of others.
• To improve and develop the Services in reliance on our legitimate interests, for example:
  • to analyze trends to identify opportunities for the development and promotion of the Services and to improve our Services,
  • to use data, often in a de-identified form, to develop new features, capabilities or products, improve the experience for Service Users, assess capability requirements and identify customer opportunities,
  • to train and improve our machine learning models and algorithms, and
  • to improve our internal operations and systems and for staff training purposes.
• For our marketing purposes, for example:
  • to conduct marketing research to improve the effectiveness of our marketing campaigns,
  • to send you marketing communications in accordance with your preferences, including product recommendations and other non-transactional communications (e.g. marketing newsletters, telemarketing calls, SMS, or push notifications), and
  • to display advertising and relevant offers to you on our website and third-party websites, based on your activities and interests.
• To communicate and stay in touch with you, for example:
  • to respond to and handle inquiries about our products and services, such as if you email us or fill out a web form or request support,
  • to send you information related to our Services such as notifications, expiration and renewal notices, technical notices and service updates, security alerts and administrative messages,
  • to provide customer support, troubleshoot and diagnose product problems, and
  • to plan, promote, manage and host events or webinars for which you have registered or that you attend, including sending related communications to you.
• For other legitimate business purposes, for example:
  • to update, expand, and analyze our records,
  • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity,
  • to identify usage trends and determine the effectiveness of our promotional campaigns, and
  • to expand our business activities.
• To comply with our legal obligations, for example:
  • to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to the extent this requires the processing or disclosure of your Personal Data,
  • to protect our rights and property, including to prevent misuse or abuse of our Services,
  • to create and submit reports as required by applicable law or regulation, and
  • to defend your or our interests in actual or threatened legal proceedings, or regulatory, administrative, or legislative inquiries or investigations.

Personal Data We Collect About Candidates

This Section applies to the Personal Data of Candidates that we collect, use and share in connection with our recruitment efforts.

Sources of Personal Data

We collect Personal Data about you from:

• You
• when you provide such information directly to us, such as:
• when you apply for a job with us,
• when you send us Personal Data voluntarily in the course of the recruitment process, including during interviews and assessment exercises, and
• when you send us an email or otherwise contact us.
• Third Parties that provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
  • References. We may obtain references about you from Third Parties.
  • Background checks. We may obtain Personal Data about you from background checking agencies and other external database holders (for example criminal background checks, credit reference agencies and professional / other sanctions registries).
  • Employees, academic institutions and training providers. We may obtain other background information provided or confirmed by former employees, academic institutions and training or certification providers.
  • Service providers. For example, we may use recruitment or executive search agencies to help identify and source Candidates for roles.
  • Public and social media network data. We may obtain further information about you from publicly available sources, including social media networks you use or other information available online.

Categories of Personal Data We Collect

The following table details the categories of Personal Data that we collect and have collected about Candidates. For each category of Personal Data, the table also sets out the categories of sources and the third parties with whom we share that Personal Data.

Category of Personal Data	Examples of Personal Data Collected	Source	Third Parties With Whom We Share Data for Business Purposes
Contact Data/Identifiers	First and last name Email Company name Job title and function Phone number Location Password	You Third Parties	Recruitment agencies or career portals involved in your recruitment) Background checking or other relevant screening providers and relevant local criminal records checking agencies Services providers
Social Network and other Connected Platform Data	Publicly available information from social networks you use, such as LinkedIn.	You Third Parties	Recruitment agencies or career portals involved in your recruitment) Background checking or other relevant screening providers and relevant local criminal records checking agencies Services providers
Employment Information	Employment history – such as previous employer, job title/positions References provided by referees Background information – such as academic/professional qualifications, job qualifications, education, training, details included in your CV/résumé, employment references, language skills. Nominated referees – name, contact details, employer, job role. Immigration/visa status. Other information you voluntarily provide throughout the process, including through assessment centers and interviews.	You Third Parties	Recruitment agencies or career portals involved in your recruitment) Background checking or other relevant screening providers and relevant local criminal records checking agencies Services providers

 

How We Use Your Personal Data

We use the Personal Data described above in the context of our recruitment efforts and to consider your application for a job or role at Clarifai. Our purposes for collecting this Personal Data include:

• to consider your application and suitability for a job or role with Clarifai, for example:
• to receive, review and reply to your application,
• to verify the information that you provide to us and check your references,
• to carry out background checks in compliance with our legal obligations,
• to assess your suitability for the job or role that you have applied for,
• to arrange and conduct interviews and recruitment exercises, and
• to inform you about the status and outcome of your application.
• to consider you for current and future opportunities. We may contact you from time to time, for example, regarding current and future opportunities or to invite you to events we organize or sponsor. You can opt-out of these communications at any time.
• for other legitimate business purposes, for example:
• to update, expand, and analyze our records,
• to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity,
• to identify trends and determine the effectiveness of our promotional recruitment efforts, and
• to expand our business activities.
• to comply with our legal obligations, for example:
• to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to the extent this requires the processing or disclosure of your Personal Data,
• to create and submit reports as required by applicable law or regulation, and
• to defend your or our interests in actual or threatened legal proceedings, or regulatory, administrative, or legislative inquiries or investigations.

How We Share and Transfer Personal Data We Collect

This Section describes our practices regarding the sharing and transfer of Personal Data that we collect.

How We Share Your Personal Data

We use your Personal Data for a variety of purposes, where permitted by applicable law:

In certain circumstances, we may disclose your Personal Data to the following categories of service providers and other parties:

Categories of Third Parties With Whom We Share Personal Data	Business Purpose for Sharing Data
Service Providers
Payment Processors	Our payment processing partner (currently Stripe, Inc.) collects your voluntarily provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy (https://stripe.com/legal) for information on its use and storage of Personal Data
Security and Fraud Prevention Consultants	Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity
Hosting, Technology and Communications Providers; Fulfillment Providers; Data Storage Providers; Analytics Providers; Staff Augmentation Personnel	Performing operational services (such as hosting, billing, fulfillment, data storage, security, web service analytics) and/or make certain services, features or functionality available to our users Debugging to identify and repair errors that impair existing intended functionality. Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider, such as HubSpot Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality or safety of our services
Parties You or a Service User Sharing Your Personal Data With Us Authorizes, Accesses or Authenticates
Other Users	Any information that a user may share with other users is not in any way private. We recommend that you carefully consider whether to disclose any Personal Data in any information you share with other users. What is shared may be seen and/or collected by other third parties and may be used by others in ways we are unable to control or predict.
Social Media Services	We will share your Personal Data if you intentionally interact with any social media service through the Services.

Business Transfers
All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices

Government Requests; Legal Process

Sometimes, we may be required to hand over information to government authorities or as part of a legal process (like a lawsuit or arbitration). If we are permitted to do so, we will notify you of the requirement to disclose your Personal Data or the applicable Customer that provided us with such information of any such requirement before we comply. We intend to defend our Customers’ rights against unlawful search and seizure. However, we also refuse to support criminal activity.

More Information Regarding Automatic Collection of Personal Data and Cookies

The following sections provide additional information about how we collect your Personal Data.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile identifiers, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base, and operate and improve our Services. For example, we use Cookies to tailor the Services by tracking navigation habits, measuring performance, customizing user experiences with the Services and for analytics and fraud prevention. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option and there is currently no industry consensus as to what constitutes a Do Not Track signal. For these reasons, our Services, like many web service site operators, do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you and remember your preferences.

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, how long visitors are viewing pages on the Services, mouse clicks, mouse movements, scrolling activity, and text typed into the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/. We also use analytics services such as those provided by Hotjar and HubSpot.

Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can score leads and provide you with web and email content that we believe is relevant to you.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your device. Although you are not required to accept Clarifai’s Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/, or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union (“EU”).

Personal Data of Children; Age Requirement

The Services are not directed to or intended for use by children under 18, and children under 16 are prohibited from using the Services. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18; if you are a child under 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data.

If you use the Services on behalf of another person, regardless of age, you agree that Clarifai may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

Your Privacy Rights

This Section describes the rights and choices you have with respect to your Personal Data. Please note that your rights will depend on where you are located and applicable privacy and data protection laws. These may include, for example, the right to access your Personal Data, request correction or deletion of your Personal Data, object or opt-out to our processing of your Personal Data or request portability of your Personal Data. We will respond to any requests we receive in accordance with our obligations under local privacy and data protection laws. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@clarifai.com.

California Resident Rights

If you are a California resident, you have the additional rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If we are processing your Personal Data as a service provider on behalf of a customer, you should contact  that entity to address your rights with respect to such data.

• Exercising the right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
• Exercising the right to opt-out from a sale:
• Exercising the right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months.
• Right to opt-out of sharing of cross-context behavioral advertising.

Right to Non-discrimination

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Submitting a request by following the instructions found here.
• Emailing us at: privacy@clarifai.com

Shine the Light Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@clarifai.com.

International Transfers

We are a global business. We may transfer your Personal Data to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from officials (such as law enforcement or security authorities). For more information about these rights, or to submit a request, please email us privacy@clarifai.com.

European Rights

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland (collectively, "Europe"), you may have additional rights under applicable data protection laws with respect to your Personal Data, as outlined below.
Note that we may use your Personal Data on behalf of our Customers in connection with our provision of certain Services to our customers, in which case we are the data processor of your Personal Data. If we are the data processor of your Personal Data (i.e., not the data controller), please contact the relevant Clarifai Customer (as the data controller) to address your rights with respect to such data.

Personal Data Processing Grounds

The “How We Use Your Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the "legitimate interest" of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity” where we have a contract with you, for example, because we need to process the data to perform our obligations to you under our Terms of Use with you or to take steps prior to entering an employment contract with you, where you are being considered for employment. 

• Contact data
• Social network and other connected platform data
• Payment information
• Device/IP information
• Web analytics
• Employment Information (if you are a candidate)

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

• Contact data/ identifiers
• Device/IP information
• Web analytics
• Social network data
• Biometric data
• Textual data
• Visual information
• Geolocation and other metadata
• Predictions, tags and inferences
• We may also de-identify or anonymize Personal Data to further our legitimate interests.
• Employment Information (if you are a candidate)

Examples of these legitimate interests include:

• Operation and improvement of our business, products and Services
• Marketing of our products and Services
• Provision of customer support or correspondence with you
• Training and improving our machine learning models and algorithms
• Protection from fraud or security threats
• Compliance with legal obligations or enforcement of legal terms
• Completion of corporate transactions
• To determine your qualifications for employment with Clarifai and to reach hiring decisions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.

Other Processing Grounds: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest. 

Data Subject Rights

You have certain rights with respect to your Personal Data in certain circumstances, including those set out below. For more information about these rights, or to submit a request, please email us at privacy@clarifai.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if we are unable to identify your Personal Data or your request is manifestly unfounded or excessive. In those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to verify your identity and the nature of your request.

• Access: You can request information about the Personal Data we process about you and request a copy of your Personal Data. As a Service User, you can access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. As a Service User, you can also correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note that if you withdraw your consent this does not affect the lawfulness of our processing of your Personal Data before this time.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes or to train our models and algorithms.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Clarifai's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of EU supervisory authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data outside Europe

a. Wherever Clarifai transfers Personal Data outside Europe, we take measures to ensure such transfers are made in compliance with applicable data protection laws, including the General Data Protection Regulation ("GDPR"). These measures include implementing standard contractual clauses adopted by the European Commission and UK authorities with our Customers and service providers, and implementing additional safeguards as necessary.

Although we do not rely on it as a transfer mechanism under the GDPR, Clarifai has certified to the EU-U.S. Privacy Shield Framework set forth by the United States Department of Commerce regarding the collection and use of Personal Data transferred from the EU, and to the Swiss-U.S. Privacy Shield Framework set forth by the United States Department of Commerce regarding the collection and use of Personal Data transferred from Switzerland. For more information about the Privacy Shield Program, and to view Clarifai’s certification, please visit https://www.privacyshield.gov. Clarifai is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU or Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Clarifai’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Please contact us at privacy@clarifai.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through: JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/ for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov/.

We may be required to disclose Personal Data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Other Information

Controlling Your Personal Data & Marketing Communications

If you are Service User, you can modify certain Personal Data or account information by logging in and accessing your account. If you wish to close your account, please email our support team at support@clarifai.com. Clarifai will use reasonable efforts to deactivate your account and the related information at your request as soon as reasonably possible. If you wish for further deletion of your Personal Data, you will need to clearly state that you are requesting deletion of all of your Personal Data, and not just deletion of your account. Please note, however, that Clarifai reserves the right to retain information from deactivated or deleted accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law.

You can also opt-out of marketing communications at any time by clicking on the "opt-out" or “Manage Preferences” link in the email communication or by emailing us at privacy@clarifai.com.

You must promptly notify us if any of your account data is lost, stolen or used without permission.

Data Retention

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide Services to you or the Service User that provided us with your Personal Data. In some cases we retain Personal Data for longer, for example if we retain your Personal Data to train our models and algorithms, to improve our Services, or if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, and as otherwise permitted or required by applicable law, rule or regulation, or if you or the Service User that provided us with your Personal Data have given us express consent to retain Personal Data for longer. We may also further retain information in an anonymous or aggregated form where that information would not identify you personally.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to any material changes by placing a notice on the https://www.clarifai.com/ website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, then your use of the Services is subject to the Privacy Policy in effect at the time.

Contact Information

If you have any questions/comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such use, please do not hesitate to contact us at:

Email: privacy@clarifai.com