Privacy Policy

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This Privacy Policy outlines how Olelo Intelligence, Inc. and its affiliated companies (referred to as “Olelo Intelligence,” “we,” “our,” or “us”) collect, store, use, and disclose the following types of personal data:

  1. Customer Data: This refers to personal data (as defined in Section 1) that we collect, process, and manage on behalf of our business customers (each referred to as a “Customer,” collectively as “Customers”) as part of the Olelo Intelligence products and services outlined in the applicable order forms (the “Platform”).
    We handle Customer Data on behalf of and under the instructions of the respective Customer, in line with our Data Processing Addendum with them. As a result, this Privacy Policy, which details Olelo Intelligence’s privacy and data processing practices, does not apply to the privacy and data processing practices of our Customers. For information about a Customer’s privacy policy and practices, please reach out to them directly.
  2. User Data: This includes personal data related to individuals acting on behalf of our Customers in their interactions with Olelo Intelligence, as well as users of the Platform on behalf of such Customers. Examples include account administrators, users, billing contacts, and authorized signatories (collectively referred to as “Users”). It also encompasses the Customer’s business needs and preferences, as provided to us or identified through our engagement with them.
  3. Prospect Data: This covers data related to visitors of our website (www.olelo-ai.com), participants at our events, and any other prospective customers, users, or partners (collectively, “Prospects”) who interact with our website, online ads, content, emails, integrations, or communications under our control (referred to as the “Sites,” and together with the Platform, the “Services”).

If you are a Customer, User, or Prospect, we encourage you to carefully review this Privacy Policy and ensure you fully understand its contents.

Our Services are tailored for business purposes and are not intended for personal or household use. As such, we treat all personal data covered by this Privacy Policy, including information about visitors to our Sites, as pertaining to individuals acting in their capacity as business representatives, rather than in a personal or private capacity.

You are under no legal obligation to provide us with any personal data. If you prefer not to share your personal data with us or allow it to be processed by us or any of our Service Providers (as defined below), please refrain from providing it to us and avoid interacting with us, our Sites, or using our Services.

  1. Data Collection & Processing

When we refer to “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. This does not include aggregated or deidentified information that is maintained in a form that cannot reasonably be associated with or linked to an individual.

We collect personal data in various ways:

  • Automatically, when an individual interacts with our Services or Sites (e.g., through our website chat feature).
  • Directly, from the individual themselves.
  • From other sources and third parties (such as our Customers and Service Providers), sometimes even before our first direct interaction.

It is important to note that Olelo Intelligence does not collect, use, or disclose sensitive personal data.

Through our Services, we may collect or generate the following types of personal data about individuals:

Types of Personal Data Collected:

  • Usage, login credentials, and device information concerning Users and Prospects:
    • Connectivity, technical, and aggregated usage data (e.g., user agent, IP addresses, approximate location based on IP addresses).
    • Device data (e.g., type, operating system, device ID, browser version, locale, and language settings).
    • Activity logs, session recordings, log-in credentials to the Services, cookies, and pixels installed or utilized on their device.
    • Inferred or presumed data generated from their use of the Services.
  • Contact and business details concerning our Customers, Users, and Prospects:
    • Name, email, phone number, position, workplace, and related business insights.
    • Communications with such individuals (e.g., correspondences, call and video recordings, transcriptions, and analyses thereof).
    • Feedback, testimonials, contractual and billing details.
    • Expressed, presumed, or identified needs, preferences, attributes, and insights relevant to our potential or existing engagement.
  • Personal data contained in Customer Data:
    • This is data provided by our Customers or processed on their behalf and under their instruction.
    • It may include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Customer Data), in accordance with our Data Processing Addendum with them.

For the purposes of the California Consumer Privacy Act (“CCPA”):

In the last 12 months, we may have collected the following categories of Personal Information, as defined in the CCPA:

  • Identifiers
  • Customer record information
  • Internet or other electronic network activity information
  • Professional or employment-related information
  • Geolocation data
  • Commercial information
  • Inferences
  • Audio, electronic, and visual information
  1. Data Uses

We use personal data for the following purposes, relying on the appropriate legal bases:

  • Performance of Contract: To fulfill our contractual obligations and provide our Services.
  • Legal Obligation: To comply with legal and regulatory requirements.
  • Legitimate Interests: To support our business interests, such as improving our Services, understanding user behavior, marketing, and ensuring security.
  • Consent: Where required by law, we rely on your consent for processing personal data.

If you reside in a jurisdiction where consent is the primary legal basis for processing personal data, your acceptance of our Terms of Service and this Privacy Policy constitutes your consent. You may revoke this consent at any time by contacting us a privacy@olelo-ai.com.

Specific Uses of Personal Data:

  1. Customer and User Data:
    • To operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests).
    • To offer assistance, support, and training, and to diagnose or fix technical issues (Performance of Contract; Legitimate Interests).
    • To personalize Services, such as recognizing returning users and tailoring experiences (Performance of Contract; Legitimate Interests).
    • For voice identification (if enabled by the Customer and opted into by Users) to note participation in recorded calls and meetings (Consent).
    • To optimize marketing campaigns, ad management, and sales operations, including contextual and behavioral advertising (Legitimate Interests; Consent).
    • To organize events, contests, and promotions (Legitimate Interests).
  2. Customer, User, and Prospect Data:
    • To analyze how individuals use our Services and improve user experience, including through AI and machine learning (Legitimate Interests).
    • To send service-related and promotional messages (Performance of Contract; Legitimate Interests; Consent).
    • To enhance data security and prevent fraud or illegal activities (Performance of Contract; Legitimate Interests; Legal Obligation).
    • To create aggregated, anonymized, or pseudonymized data for analysis and improvement (Legitimate Interests).
    • To enforce our Terms of Service, resolve disputes, and protect our rights (Legitimate Interests).
    • To comply with legal and contractual obligations (Performance of Contract; Legitimate Interests; Legal Obligation).
    • For any other lawful purpose or with your consent (Legal Obligation; Consent)
  1. Data Location

We and our authorized Service Providers store and process personal data primarily in the United States, as necessary for delivering our Services or as required by law. While privacy laws vary by jurisdiction, we commit to protecting personal data in accordance with this Privacy Policy and industry standards, using appropriate legal mechanisms and contractual terms to ensure adequate protection.

  1. Data Retention

We retain personal data for as long as reasonably necessary to maintain our relationship, provide Services, comply with legal obligations, or protect against disputes. Retention periods are determined based on the type of data, its sensitivity, and applicable legal requirements. For questions about our data retention policy, contact us at privacy@olelo-ai.com.

  1. Data Disclosure

We disclose personal data in the following ways:

  1. Service Providers: Third parties who assist in delivering our Services, such as hosting, analytics, billing, and security providers.
  2. Partnerships: Business partners who help us expand and tailor our Services.
  3. Service Integrations: Third-party services integrated with our Platform, with your consent.
  4. Event Sponsors: Sharing data with sponsors at events or webinars, if you opt in.
  5. Business Customers: Customers have access to data we process on their behalf.
  6. Legal Compliance: Disclosing data to comply with legal requests or protect rights and safety.
  7. Corporate Transactions: Sharing data during mergers, acquisitions, or other business changes.

For the purposes of the CCPA, in the past 12 months, we may have disclosed identifiers, customer records, internet activity, professional information, geolocation data, commercial information, inferences, and audio/visual data to Service Providers, partners, and others for business purposes.

  1. Cookies and Data Collection Technologies

We use cookies, pixels, and similar technologies to improve our Services, track performance, and personalize experiences. Cookies may be session-based (temporary) or persistent (longer-term). Some cookies are essential for functionality, while others are optional and used for analytics or marketing.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these emails. You may opt out of receiving advertising provided by service providers by visiting https://app.retention.com/optout.

You can manage cookie preferences through your browser settings or our “Your Privacy Choices” feature. Note that blocking cookies may affect your experience.

 

  1. Communications

We send service-related communications (e.g., updates, billing notices) and promotional communications (e.g., new features, events). You can opt out of promotional messages by emailing privacy@olelo-ai.com or using the unsubscribe link in communications.

  1. Data Security

We implement measures to protect personal data from unauthorized access or misuse. However, no system is completely secure. For more details, visit our Trust Center at https://www.olelo-ai.com/trust-center/security/.

  1. Data Subject Rights

You have rights under applicable privacy laws, such as the GDPR, CCPA, or LGPD, including the right to access, correct, delete, or restrict the processing of your personal data. To exercise these rights, contact us at privacy@olelo-ai.com.

If your data is processed on behalf of a Customer, we recommend contacting them directly.

  1. Data Controller/Processor
  • Olelo Intelligence acts as a data controller for Prospect Data and certain User Data.
  • Olelo Intelligence acts as a data processor for Customer Data, processing it on behalf of our Customers.

Customers are responsible for ensuring compliance with applicable laws when using our Services.

  1. Opt-Out of Sale/Sharing

Under the CCPA, certain disclosures of internet activity and device information may be considered a “sale” or “sharing” of personal data. To opt out, use the “Your Privacy Choices” feature on our website or set the Global Privacy Control (GPC) in your browser.

  1. Additional Notices & Contact Details
  • Updates: We may amend this Privacy Policy periodically. Changes will be effective upon publication.
  • External Links: We are not responsible for the privacy practices of third-party websites linked to our Services.
  • Children: Our Services are not intended for individuals under 16. We do not knowingly collect their data.
  • Contact: For questions or concerns, email privacy@olelo-ai.com. Our Data Protection Officer (DPO) is Miki Hardisty, CEO.