Privacy Policy

This Privacy Policy describes how Echoes-AI collects, uses, and discloses information, and what choices you have with respect to the information.

Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:

  • organizing it into the sections,
  • providing a series of examples that help illustrate how the policies may be implemented by Echoes-AI, and
  • defining and capitalizing a few terms that are used more than once for simplicity and brevity.

When we refer to "Echoes-AI", we mean the Echoes-AI entity that acts as the controller or processor of your information, as explained in more detail in the " Identifying the Data Controller and Processor" section below.

Applicability of This Privacy Policy

This Privacy Policy applies to Echoes-AI's online workplace productivity tools and platform, including the associated add-ons to third-party platforms (collectively, the "Services"), echoes.io and other Echoes-AI websites (collectively, the "Websites") and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Echoes-AI. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Echoes-AI's business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Echoes-AI platform ( "Third Party Services"), or any other third party products, services, or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the "Customer Agreement"), including the processing of any messages, files, or other content submitted through Services accounts (collectively, "Customer Data"). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement ( "Customer") controls their instance of the Services (their "Echoes-AI Workspaces") and any associated Customer Data. If you have any questions about specific Echoes-AI Workspace settings and privacy practices, please contact the Customer whose Echoes-AI Workspace you use. If you have an account, you can check your Echoes-AI Workspace for contact information of its owner owner(s) and administrator(s). If you have received an invitation to join an Echoes-AI Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect and Receive

Echoes-AI may collect and receive Customer Data and other information and data ("Other Information") in a variety of ways:

  • Customer Data. Customers or individuals granted access to an Echoes-AI Workspace by a Customer ( "Authorized Users") routinely submit Customer Data to Echoes-AI when using the Services.
  • Other Information. Echoes-AI also collects, generates, and/or receives Other Information:
    • Echoes-AI Workspace and Account Information. To create or update an Echoes-AI account or an account within another Echoes-AI Workspace, you or your Customer (e.g., your employer) supply Echoes-AI with an email address, phone number, password, domain, and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Echoes-AI (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
    • Usage information.
      • Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Echoes-AI logs the Echoes-AI Workspaces, channels, rooms, groups, people, features, content, and links you interact with, the types of files shared, and what Third Party Services are used (if any).
      • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences, and cookie data.
      • Device information. Echoes-AI collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, and unique device identifiers. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
      • Location information. We receive information from you, your Customer, and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Echoes-AI may also collect location information from devices in accordance with the consent process provided by your device.
    • Cookie Information. Echoes-AI uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
    • Third Party Services. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Echoes-AI Workspace. Once enabled, the provider of a Third Party Service may share certain information with Echoes-AI. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Echoes-AI. When a Third Party Service is enabled, Echoes-AI is authorized to connect and access Other Information made available to Echoes-AI in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
    • Contact Information. In accordance with the consent process provided by your Echoes-AI Workspace, any contact information that an Authorized User chooses to import (such as an address book from a device) may be collected when using the Services.
    • Third Party Data. Echoes-AI may receive data about organizations, industries, Websites visitors, marketing campaigns, and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to legal entities, zip codes, or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
    • Additional Information Provided to Echoes-AI. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity, or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Echoes-AI.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, "Information"). However, certain Information is collected automatically and, if some Information, such as Echoes-AI Workspace setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Echoes-AI in accordance with Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and as required by applicable law. Echoes-AI is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Echoes-AI Workspace, assign roles and configure settings, access, modify, export, share, and remove Customer Data and otherwise apply its policies to the Services.

Echoes-AI uses Other Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Echoes-AI uses Other Information:

  • To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User's request.
  • As required by applicable law, legal process, or regulation
  • To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
  • To develop and provide search, learning, and productivity tools and additional features. Echoes-AI tries to make the Services as useful as possible for specific Echoes-AI Workspaces and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
  • To send emails and other communications. We may send you service, technical, and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Echoes-AI. These are marketing messages so you can control whether you receive them.
  • For billing, account management, and other administrative matters. Echoes-AI may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Echoes-AI may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as "Personal Data."

Data Retention

Echoes-AI will retain Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Echoes-AI Workspace level or other level. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Echoes-AI may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Echoes-AI to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share and Disclose Information

This section describes how Echoes-AI may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Echoes-AI does not control how they or any other third parties choose to share or disclose Information.

  • Customer’s Instructions. Echoes-AI will solely share and disclose Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and in compliance with applicable law and legal process.
  • Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Echoes-AI Workspaces. For example, an Authorized User's email address may be displayed with their Echoes-AI Workspace profile.
  • Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Echoes-AI Workspace activity, or accessing or modifying your profile details.
  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
  • Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Echoes-AI may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Echoes-AI and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
  • Corporate Affiliates. Echoes-AI may share Other Information with its corporate affiliates, parents, and/or subsidiaries.
  • During a Change to Echoes-AI's Business. If Echoes-AI engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Echoes-AI's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Echoes-AI customer the average amount of time spent within a typical Echoes-AI Workspace.
  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Echoes-AI or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With Consent. Echoes-AI may share Other Information with third parties when we have consent to do so.

Security

Echoes-AI takes security of data very seriously. Echoes-AI works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process, and store, and the current state of technology. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Statement. Given the nature of communications and information processing technology, Echoes-AI cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Age Limitations

To the extent prohibited by applicable law, Echoes-AI does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to This Privacy Policy

Echoes-AI may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Echoes-AI will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Identifying the Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the "controller" and "processor" of information. In general, Customer is the controller of Customer Data. In general, Echoes-AI is the processor of Customer Data and the controller of Other Information. Echoes-AI Inc., a US company based in New York, NY is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Echoes-AI Workspaces established for Customers worldwide.

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance. Please check your Echoes-AI Workspace(s) for Customer contact information.

To the extent that Echoes-AI's processing of your Personal Data is subject to the General Data Protection Regulation, Echoes-AI relies on its legitimate interests, described above, to process your data. Echoes-AI may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Echoes-AI's use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Echoes-AI's use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority.

EU-US Privacy Shield

Echoes-AI complies with the EU-U.S. Privacy Shield Framework (“Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal informationtransferred from the European Union to the United States.Echoes-AIhas certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles.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/

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

General. We rely on our Privacy Shield certification to transfer Personal Data that we receive from the EU to Echoes-AI in the U.S. and we process such Personal Data in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles“), as described below.

Notice and Choice. This Privacy Policy provides notice of the Personal Data collected and transferred under the Privacy Shield and the choice that you have with respect to such Personal Data. It also provides information about other Privacy Shield Principles that are set forth below.

Accountability for Onward Transfers. As a Privacy Shield Organization, Echoes-AI is responsible for the processing of Personal Data it receives under the Privacy Shield and subsequentlytransfers to a third party acting as an agent on its behalf. These third-party agents are contractually obligated to maintain the confidentiality of your Personal Data consistent with the terms of this Privacy Policy and provide at least the same level of protection as required by the Privacy Shield Principles, as well as comply with applicable data protection laws. Where Echoes-AI has knowledge that an agent is using or disclosing Personal Data in a manner contrary to this Privacy Policy or the Privacy Shield Principles, Echoes-AI will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of Personal Data of EU individuals received pursuant to the EU-US Privacy Shield Framework, Echoes-AI is potentially liable, unless Echoes-AI proves that it is not responsible for the event giving rise to the damage.

Data Integrity and Purpose Limitation. We take reasonable steps to ensure that Personal Data is reliable for its intended use, and that it is accurate, complete and current for as long as we retain it. Our data retention practices are described in the “Data Retention” section of this Privacy Policy.

Access. EU users have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Please see the “Your Rights” section above for more information on the rights of users in the EU.

Recourse, Enforcement, Liability. In compliance with the Privacy Shield Principles, Echoes-AI commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Echoes-AI at: help@echoes.io

Echoes-AI has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: www.privacyshield.gov/article?id=ANNEX-I-introduction .

We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Framework.

Opt-Out

Individuals may have the right to limit the use and disclosure of their personal information as required by the Privacy Shield’s Principles, such as whether your personal information is disclosed to a third party or used for purposes materially different from the purpose for which the personal information was originally collected or subsequently authorized by you. If you wish to limit the use and disclosure of personal information in accordance with the Privacy Shield Principles, please contact us at help@echoes.io.

Contacting Echoes-AI

Please also feel free to contact Echoes-AI if you have any questions about this Privacy Policy or Echoes-AI's practices, or if you are seeking to exercise any of your statutory rights. You may contact us at help@echoes.io.

Effective: May 1, 2019

Updated: July 14, 2020