Date of Last Revision: 22 October 2020 This is the privacy policy (“Privacy Policy”) of the Ai-Media group of companies, Alternative Communications Services, LLC, PostCAP LLC, Access Innovation Holdings Pty Limited (ACN 122 058 708), Access Innovation Media Pty Limited (ACN 105 924 490), Ai-Media Inc, Ai-Media Canada Inc (Co No 1015825-9), Access Innovation Media UK Ltd (Co No 08123694), Ai-Media UK B Ltd (Co No 07292409), Ai–Media SG Pte Ltd (Co No: 201928402d) and Ai-Media NZ Limited (Co No 7389556) (referred to herein as “Ai-Media/ACS,” “we” or “us”). This Privacy Policy also applies to the personal information we collect about:
Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Websites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to third party advertising networks, social networks and data analytics providers. Sources of Personal Information. As further described in the Information We Collect section above, we may collect personal information from the following sources:
- users of our websites, including www.acscaptions.com, postcapllc.comwww.ai-media.tv, www.ai-live.com, www.scribblr.ai, www.visibleclassroom.com, order.ai-media.tv (the “Websites”), our Community Platform web interface (the “Platform”), our “Visible Classroom” application (our “Application”), and our mobile apps (collectively, the “Services”) and other individuals who use our Services;
- our current, former, and prospective clients and business partners;
- attendees and participants at events that we host or sponsor;
- individuals in the context of shareholder communications and meetings, as well as associated corporate actions and regulatory matters;
- job applicants;
- contractors and agents; and
- other individuals that otherwise communicate or interact with us.
- Privacy Act 1988 (Cth) (Australia);
- Data Protection Act 2018 (United Kingdom) and General Data Protection Regulation (EU);
- The Personal Information Protection and Electronic Documents Act (Canada); and
- U.S. federal and state privacy laws, including the California Consumer Privacy Act (California).
- Australia: Level 1, 103 Miller Street, North Sydney, NSW 2060
- USA: Ai-Media Inc, 241 West Federal Street Youngstown OH 44503
- Canada: 3Suite 1302, 13th Floor, 134 Peter Street, Toronto ON M5V 2H2
- EEA/UK: See section 13 for the contact details for our UK office.
- directly from you when you provide it to us or our agents or contractors, or otherwise communicate with or interact with us;
- via our Websites and Services, or when you deal with us online (including through our social media pages);
- from publicly available sources (such as your personal data published on your company or organisation’s websites);
- from third parties (for example, from referees if you apply for a position as an employee or contractor with us); and
- from third party platforms (such as social media platforms that you interact with us through or comment about us on) and lead generation services.
- user names and contact details including name, email addresses, country location, phone number and addresses, date of birth/age. We may combine this with publicly available information (such as social media sites); and
- answers that you provide to questions asked, and other information, in your dealings with us including when emailing, telephoning or on chat transcripts between users and captioners.
- information about your computer, mobile phone or device, such as your IP address, geographical location, browser type, referral source (i.e., the website that led you to our Services), app identifier, advertising ID, and other identifiers, browser type, device type, domain name;
- information about the links you click, pages you view or your other activities within the Services, including the dates and times you access our Services and the duration of your access; and
- we may also use pixels in HTML emails to understand whether individuals read the emails we send to them. Read about how we use cookies on the Cookie Notices that appear on the websites for Ai-Media/ACS, Ai-Live, Ai-Media/ACS Blog, scribblr.ai and Visible Classroom.
- to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us);
- to provide goods or services to you or to receive goods or services from you;
- to contact you about any promotions, competitions or special offers about our services, or those of our business partners;
- to administer rewards, surveys, competitions or other promotional activities or events conducted, sponsored or managed by us or our business partners;
- to enable you to use our apps and other applications that you download;
- to improve our goods and services;
- to verify your identity, address and age or eligibility to participate in a marketing activity;
- to consider you for a position with us (whether as an employee or contractor) or in the context of other relationships with us;
- to address any issues or complaints that we or you have regarding our relationship;
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner;
- improve your browsing experience by personalising our websites;
- to send information to you which we think may be of interest to you by post, email, or other means;
- in support of our internal business operations (such as relating to audits and assessments of our business operations, security controls, financial controls, and compliance with legal obligations, or otherwise relating to the administration of our general business, accounting, record keeping and legal functions);
- to comply with the law or legal proceedings, such as in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements;
- to protect our business operations, secure our network and information technology, assets and services;
- to prevent and detect fraud, unauthorized activities, access and other misconduct;
- where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and
- for other purposes to which you have consented or as may be authorised or required by law.
- our employees, and the related companies within our Group;
- our contractors and other third parties that provide goods and services to us (including website and data hosting providers, and other suppliers);
- our accountants, insurers, lawyers, auditors and other professional advisers and agents;
- third parties that assist us in giving you the services, for example in respect of our Visible Classroom Application we may disclose personal information to the “University of Melbourne” who provide us with a report of users in respect of their teaching/speaking, and third-parties like “TranscribeMe” that assist us with providing transcriptions of lessons;
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
- in the event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors, including related to due diligence conducted prior to such event where permitted by law;
- third parties that require the information for law enforcement or to prevent a serious threat to public safety;
- social media sites, like Facebook, Google, Snapchat or Twitter to show you relevant and “targeted advertising”. To do this, we securely match email addresses with the social media platform via our third-party processor, HubSpot. The email addresses are only decipherable by the social media company if the email address is linked to an account on their site. If you don’t want to see our targeted advertising, you can set ad preferences in your social media companies’ settings, or you can contact us, or depending on the circumstance you can change your cookie settings for our websites; and
- otherwise as permitted or required by law.
- review the information that you have supplied to us;
- request that we correct any errors, outdated information, or omissions in user information that you have supplied to us;
- request that your information not be used to contact you;
- request that your information be removed from any solicitation list that we use; and
- request that your user information be deleted from our records.
- If you are in Australia this will be the Office of the Australian Information Commissioner contactable at www.oaic.gov.au.
- If you are in the UK, this will be the Information Commissioner’s Office, contactable at https://ico.org.uk/.
- where we have your explicit consent;
- where the processing is necessary to perform a contract with you and to provide you with our services or take steps to enter into a contract at your request;
- that it is necessary for the purposes of our legitimate interests, which include conducting direct marketing and other business purposes set out in section 3, which we consider as being reasonably expected and not causing you unwarranted harm. In particular, for personal information that we may have obtained from public sources (such as your personal information published on your company or organisation’s websites) we process that personal information for our legitimate interests in direct marketing, which we would consider to be reasonably expected and not causing unwarranted harm; or
- to comply with our legal obligations.
- with members of the Ai-Media/ACS group of companies where such disclosure is necessary to provide you with our services or to manage our business under an intragroup data transfer agreement;
- to external service providers so that they can provide us with services in connection with the operation of our business, such as data storage services or online platforms for surveys to be conducted; and
- to our contractors that provide captioning/stenography service, in connection with the operation of our business.
- to obtain a copy of your personal information together with information about how and on what basis that personal data is processed;
- to rectify inaccurate personal information (including the right to have incomplete personal data completed);
- to erase your personal information;
- to restrict processing of your personal information if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or your personal information is inaccurate;
- to receive the personal information as data in machine-readable format when we justify our processing on the basis of your consent or the performance of a contract with you;
- to withdraw your consent to our processing of your personal information (where that processing is based on your consent);
- to object to the processing of your personal information (where we are doing so on the basis of legitimate interests) and an absolute otherwise to request that we stop direct marketing communications to you;
- to obtain, or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization; and
- to lodge a complaint with your local data protection authority.
Personal Information Collected | May We Disclose this Information? | Categories of Third Parties to Whom We May Disclose this Information | |
Categories | Description | ||
Identifiers | Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers. | YES |
|
Customer Records | Includes personal information, such as name, account name, user ID, contact information, education and employment information, payment information that individuals provide us in order to purchase or obtain our products and services. | YES |
|
Commercial Information | Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. | YES |
|
Audio, Video and Electronic Data | Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us) and call recordings (e.g., of customer support calls). | YES |
|
Usage Data | Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other services, and our marketing emails and online ads. | YES |
|
Geolocation Data | Includes precise location information about a particular individual or device. | YES |
|
Professional information | Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships). | YES |
|
Education Information | Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates). | YES |
|
Protected Classifications | Includes characteristics of protected classifications under applicable laws, such as disability information and health conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities we host), and information we collect or receive from personnel as part of our diversity and inclusion program. | YES |
|
Inferences | Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may create profiles of your likely interests so that we may send you more relevant marketing emails. | YES |
|
- directly from the individual
- through the Websites, Application and/or Services
- publicly available sources
- our enterprise customers
- our resellers and distributors
- service providers, agents and advisors
- recruiters
- our affiliates and subsidiaries
- internet service providers
- operating systems and platforms
- advertising networks
- social networks
- data analytics providers
- Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell the personal information of anyone that we know to be under the age of 16 years old. California residents may opt out of sales of their personal information by us by using our preference manager (i.e., to opt out of “sales” via third party tags and cookies on our Websites.
- Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
- categories of personal information collected;
- categories of sources of personal information;
- categories of personal information about them we have disclosed for a business purpose or sold;
- categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
- the business or commercial purposes for collecting or selling their personal information; and
- a copy of the specific pieces of personal information we have collected about them.
- Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
- Your full name
- Email address
- Company or university name (if you are an enterprise user)
- Ai-Media/ACS Services you use
- Your state/province and country
- A description of your request