Our Privacy Policy

HOW WE USE PERSONAL INFORMATION.

We do not sell your Personal Information.

We may use Personal Information for the following purposes:

To provide, administer, maintain, improve and/or analyze the Services;

To provide you with support services; 

To communicate with you including by discussing with you options to use the Deliberately.ai Platform;

To develop new features and services;

To prevent fraud, criminal activity, or misuses of our services, and to ensure the security of our IT systems, architecture, and networks; and

To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our Affiliates, you, or other third parties.

Aggregated Information: We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. 

DISCLOSURE OF PERSONAL INFORMATION.

In certain circumstances we may share your Personal Information with third parties without further notice to you, unless required by the law, including without limitation in the situations below:

Vendors, Service Providers, and Subprocessors: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors, service providers and subprocessors, including providers of hosting services, cloud service providers, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us. An up-to-date list of our subprocessors is available here and our nominal subprocessors list is here.

Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or Affiliate as part of that Transaction along with other assets.

Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

Affiliates: We may share Personal Information with our “Affiliates,” meaning an entity that controls, is controlled by, or is under common control with Counsel AI. Our Affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

Other Users: certain actions you take may be visible to other users of our services.

REQUEST FOR ACTION.

To request access, deletion, rectification, restriction, or portability of your Personal Information, please contact us at contact@deliberately.ai. We reserve our right to limit our facilitating such requests to that which is required by applicable law.

In order to protect your Personal Information from unauthorized access, deletion, rectification, or restriction we may require you to verify your identity before we will process any request to know or delete Personal Information. If we cannot verify your identity (and, where applicable, proof of residency) to our satisfaction, we will not provide or delete your Personal Information.

You may submit a request to know or delete your Personal Information through an authorized agent. Such an agent must present signed written authority to act on your behalf and must be able to verify your identity (and, where applicable, proof of residency) to our satisfaction.

We will not discriminate against you for making any such request.

SECURITY. 

We take reasonable and appropriate steps to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. We use appropriate technical and organizational measures to protect your personal information which may include: physical access controls, encryption, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. Our staff who may have access to your information are required to keep that information confidential.

DATA RETENTION AND DELETION. 

We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, unless a longer retention period is required or permitted by law. We may also retain your personal information for legitimate business interests, such as to comply with our legal obligations, resolve disputes, and maintain our records. When we no longer need your Personal Information, we will delete it or anonymize it in accordance with our data retention policies and applicable laws, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing, until deletion is possible. 

NO CHILDREN. 

Our websites and services are not directed to anyone under the age of 16. Counsel AI does not knowingly collect Personal Information from anyone under the age of 16. If you have reason to believe that a minor under the age of 16 has provided Personal Information to Counsel AI through our Services please email us at contact@deliberately.ai and we will endeavor to delete that information from our systems.

LINKS TO OTHER WEBSITES. 

Our Services may contain links to other websites not operated or controlled by Counsel AI, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

INTERNATIONAL USERS.

Data Transfers: By using our Services governed by this Privacy Policy, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States, and possibly from your location to other countries where our service providers operate.

Privacy frameworks: We employ appropriate safeguards for cross- border transfers of Personal Information, including compliance with certain privacy frameworks relating to transfer of data. For example, we comply with the European Commission, UK and Swiss adequacy decisions. 

Questions: If you have questions about our privacy practices, you can contact us at contact@deliberately.ai. You may also refer your question to your local data protection authority and we will work with them to resolve your concern.

DATA PRIVACY FRAMEWORK.

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Counsel AI has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  We have similarly certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Commitment to Cooperate. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Counsel AI commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Federal Trade Commission. The Federal Trade Commission has jurisdiction over Counsel AI’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Right to Arbitrate. You may, under certain conditions, invoke binding arbitration for complaints regarding Data Privacy Framework compliance.  More details can be found here.

Accountability for Onward Transfers.  We take responsibility for the processing of personal information we receive and subsequently transfer to a third party. In the case of an onward transfer, Counsel AI remains liable if such a third-party processes personal information in a way that is inconsistent with the Data Privacy Framework Principles, unless we can demonstrate that we were not responsible for the event that gave rise to the damage.

CHANGES TO OUR PRIVACY POLICY. 

We may update this Privacy Policy from time to time. When we do we will post an updated version on this page, unless another type of notice is required by applicable law or contractual agreement. By continuing to use our service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means, you consent to the revised Privacy Policy.

HOW TO CONTACT US. 

If you have any questions about our Privacy Policy or privacy practices, please contact us at contact@deliberately.ai.