PRIVACY POLICY
Effective as of
December 2019.
This “Privacy Policy” describes the privacy practices of
True AI, LLC and our subsidiaries and affiliates
(collectively, “Daily AI”, “we”, “us”, or “our”) in
connection with the www.DailyAI.com website (the “Site”),
the True AI mobile application (the “App”), and any other
website or mobile application that we own or control and
which posts or links to this Privacy Policy (collectively,
the “Services”), and the rights and choices available to
individuals with respect to their information.
1. Personal Information We Collect
Information you provide to us. Personal
information you
provide to us through the Services or otherwise includes:
a. Business and personal contact
information, such as your first and last name,
email and
mailing addresses, phone number, professional license
identification (e.g. real estate license or loan officer
number), professional title and company name.
b. Content you choose to upload to
the Services, such as text and images along with
the
metadata associated with the files you upload.
c. Profile information, such as
your username and password that you may set to establish
an online account with us.
d. Feedback or correspondence,
such as information you provide when you contact us with
questions, feedback, or otherwise correspond with us
online.
e. Demographic Information, such
as your city, state, country of residence,
postal code,
and age.
f. Financial information, such as
your financial account numbers or payment card
information.
g. Precise geolocation
information, such as when you authorize our
mobile
application to access your location.
h.Transaction information, such as
information about payments to and from you and other
details of products or services you have purchased from
us.
i.Usage information, such as
information about how you use the Services and interact
with us, including information associated with any
content you upload to the websites or otherwise submit
to us, and information you provide when you use any
interactive features of the Services.
j.Marketing information, such as
your preferences for receiving communications about our
activities, events, and publications, and details about
how you engage with our communications.
k. Other information, that we may
collect which is not specifically listed here, but which
we will use in accordance with this Privacy Policy or as
otherwise disclosed at the time of collection.
Information we obtain from social
media platforms: As part of the Services, you
will have the option to connect you email (e.g. Gmail and Outlook) as well as their corresponding
calendar applications to your Account. If you choose to connect your email and calendar to your Account
we may collect, store, and analyze information from such platforms and will treat such information in
accordance with this Privacy Policy.
If you choose to login to the Services via a
third-party
platform or social media network, or otherwise connect
your account on the third-party platform or network to
your account through the Services, we may collect
information from that platform or network. For example,
this information may include your Facebook username,
user ID, profile picture, cover photo, and networks to
which you belong (e.g., school, workplace). You may also
have the opportunity to provide us with additional
information via the third-party platform or network,
such as a list of your friends or connections and your
email address. You can read more about your privacy
choices in the “Third party platforms or social media
networks” portion of the “Your Choices” section.
Information we obtain from
other third parties: We may receive personal
information
about you from third-party sources. For example, a
business partner may share your contact information with
us if you have expressed interest in learning
specifically about our products or services, or the
types of products or services we offer. We may obtain
your personal information from other third parties, such
as marketing partners, publicly-available sources and
data providers. We partner with Ellie Mae, Inc., and
collect certain information form Ellie Mae’ s Encompass
Platform, such information may include information about
you and/or your business dealings.
Cookies and Other Information
Collected by Automated Means:
We, our service providers, and our business partners may
automatically log information about you, your computer
or mobile device, and activity occurring on or through
the Services, including but not limited, your computer
or mobile device operating system type and version
number, manufacturer and model, device identifier (such
as the Google Advertising ID or Apple ID for
Advertising), browser type, screen resolution, IP
address, the website you visited before browsing to our
website, general location information such as city,
state or geographic area; information about your use of
and actions on the Service, such as pages or screens you
viewed, how long you spent on a page or screen,
navigation paths between pages or screens, information
about your activity on a page or screen, access times,
and length of access; and other personal information.
Our service providers and business partners may collect
this type of information over time and across
third-party websites and mobile applications.
On our webpages, this information is collected using
cookies, browser web storage (also known as locally
stored objects, or “LSOs”), Flash-based LSOs (also known
as “Flash cookies”), web beacons, and similar
technologies, and our emails may also contain web
beacons. In our mobile application, we may collect this
information directly or through our use of third-party
software development kits (“SDKs”). SDKs may enable
third parties to collect information directly from our
App.
A “cookie” is a text file that websites send to a
visitor‘s computer or other Internet-connected device to
uniquely identify the visitor’s browser or to store
information or settings in the browser. Browser web
storage, or LSOs, are used for similar purposes as
cookies. Browser web storage enables the storage of a
larger amount of data than cookies. A “web beacon,” also
known as a pixel tag or clear GIF, is typically used to
demonstrate that a webpage was accessed or that certain
content was viewed, typically to measure the success of
our marketing campaigns or engagement with our emails
and to compile statistics about usage of our websites. A
SDK is third-party computer code that we may incorporate
into our mobile applications that may be used for a
variety of purposes, including to provide us with
analytics regarding the use of our mobile applications,
to integrate with social media, add features or
functionality to our App, or to facilitate online
advertising.
We may also use Flash LSOs on our website to
collect and
store information about your use of our website. Unlike
cookies, Flash LSOs cannot be removed or rejected via
your browser settings. If you do not want Flash LSOs
stored on your computer or mobile device, you can adjust
the settings of your Flash player to block Flash LSO
storage using the tools contained in the Website Storage
Settings Panel. You can also control Flash LSOs by going
to the Global Storage Settings Panel and following the
instructions. Please note that setting the Flash Player
to restrict or limit acceptance of Flash LSOs may reduce
or impede the functionality of Flash applications that
we may use in connection with our website.
Please see the “Targeted online advertising” section for
information about how to exercise choice regarding the
use of browsing behavior for purposes of targeted
advertising.
Referrals
Users of the Service may have the opportunity to refer
business partners or other contacts to us. If you are an
existing user, you may only submit a referral if you
have permission to provide the referral’s contact
information to us so that we may contact them.
2. How We Use Your Personal Information
We use your personal information for the
following purposes and as otherwise described in this
Privacy Policy or at the time of collection:
To operate the Services. We use
your personal information to:
- provide, operate and improve the Services;
- provide information about our products and
services;
- facilitate your to login to the Services via
third-party identity and access management
providers, such as Facebook;
- enable security features of the Service, such as
by sending you security codes via email or SMS,
and remembering devices from which you have
previously logged in;
- communicate with you about the Services,
including by sending you announcements, updates,
security alerts, and support and administrative
messages
- provide support and maintenance for the
Services;
- to respond to your requests, questions and
feedback.
For research and development.
We analyze use of the Services to analyze and improve
the Services and to develop new products and services,
including by studying user demographics and use of the
Services.
To send you marketing and
promotional communications. We may send you
Daily
AI-related marketing communications as permitted by law.
You will have the ability to opt-out of our marketing
and promotional communications as described in the Opt
out of marketing section below.
To display advertisements. We work
with advertising partners to display advertisements on
the Services or elsewhere online. These advertisements
are delivered by our advertising partners and may be
targeted based on your use of the Services or your
activity elsewhere online. To learn more about your
choices in connection with advertisements, please see
the section below titled “Targeted online advertising.”
To comply with law. We use your
personal
information as we believe necessary or appropriate to
comply with applicable laws, lawful requests, and legal
process, such as to respond to subpoenas or requests
from government authorities.
For compliance, fraud prevention, and
safety. We may use your personal information and
disclose it to law enforcement, government authorities,
and private parties as we believe necessary or
appropriate to: (a) protect our, your or others’ rights,
privacy, safety or property (including by making and
defending legal claims); (b) enforce the terms and
conditions that govern the Services; and (c) protect,
investigate and deter against fraudulent, harmful,
unauthorized, unethical or illegal activity.
With your consent. In some cases
we
may specifically ask for your consent to collect,
use or share your personal information, such as when
required by law.
To
create anonymous, aggregated or de-identified data.
We
may create anonymous, aggregated or de-identified data
from your personal information and other individuals
whose personal information we collect. We make personal
information into anonymous, aggregated or de-identified
data by removing information that makes the data
personally identifiable to you. We may use this
anonymous, aggregated or de-identified data and share it
with third parties for our lawful business purposes,
including to analyze and improve the Services and
promote our business.
Other Users
of the Services and the Public. We may provide
functionality
that enables you to disclose personal information to other
users of the Services or the public. For instance, you may
be able to maintain a user profile with information about
yourself that you can make available to other users or the
public. You may also be able to submit content to the
Services (such as comments, reviews, surveys, blogs, photos,
and videos), and we will display your name, username, and a
link to your user profile along with the content you submit.
[We may make available settings through the [My Account]
page that enable you to exercise choice regarding certain
information that is displayed publicly or to other users.]
We do not control how other users or third parties use any
personal information that you make available to such users
or the public.
Professional advisors.
We may disclose your personal
information to professional advisors, such as lawyers,
bankers, auditors and insurers, where necessary in the
course of the professional services that they render to us.
For
compliance, fraud prevention and safety. We may
share your
personal information for the compliance, fraud prevention
and safety purposes described above.
Business
transfers. We may sell, transfer or otherwise share
some or
all of our business or assets, including your personal
information, in connection with a business transaction (or
potential business transaction) such as a corporate
divestiture, merger, consolidation, acquisition,
reorganization or sale of assets, or in the event of
bankruptcy or dissolution.
3. Your Choices
In this section, we describe the rights
and choices available to all users.
Access or Update Your Information.
If
you have registered for an account with us, you may
review and update certain personal information in your
account profile by logging into the account.
Opt out of marketing communications.
You may opt out of marketing-related emails by
following the opt-out or unsubscribe instructions at
the bottom of the email, or by contacting us at
___@DailyAI. com. You may continue to receive
service-related and other non-marketing emails. If
you receive marketing text messages from us, you may
opt out of receiving further marketing text messages
from us by replying STOP to our marketing message.
You may also text STOP to [SHORTCODE].
Cookies & Browser Web
Storage. We may allow service providers and
other third
parties to use cookies and similar technologies to track
your browsing activity over time and across the Services
and third party websites. Most browsers let you remove
or reject cookies. To do this, follow the instructions
in your browser settings. Many browsers accept cookies
by default until you change your settings. Please note
that if you set your browser to disable cookies, the
Site or App may not work properly. Similarly, your
browser settings may allow you to clear your browser web
storage.
Privacy settings and
location data. We make available certain privacy
settings on the Services, including options to control [
]. Users of the App also have the choice whether to
allow us to access your precise location data. Your
device settings may provide the ability for you to
revoke our ability to access location data.
Targeted online advertising. Some
of the business partners that collect information about
users’ activities on or through the Services may be
members of organizations or programs that provide
choices to individuals regarding the use of their
browsing behavior or mobile application usage for
purposes of targeted advertising.
Users may opt out of receiving targeted advertising on
websites through members of the Network Advertising
Initiative by clicking here or the Digital Advertising
Alliance by clicking here. Users the App may opt out of
receiving targeted advertising in mobile apps through
participating members of the Digital Advertising
Alliance by installing the AppChoices mobile app,
available here, and selecting the user’s choices. Please
note that we also may work with companies that offer
their own opt-out mechanisms and may not participate in
the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide
functionality to limit our, or our partners’, ability to
engage in ad tracking or targeted advertising using the
Google Advertising ID or Apple ID for Advertising
associated with your mobile device.
If you choose to opt-out of targeted advertisements, you
will still see advertisements online but they may not be
relevant to you. Even if you do choose to opt out, not
all companies that serve online behavioral advertising
are included in this list, so you may still receive some
cookies and tailored advertisements from companies that
are not listed.
Do Not Track. Some Internet
browsers may be configured to send “Do Not Track”
signals to the online services that you visit. We
currently do not respond to “Do Not Track” or similar
signals. To find out more about “Do Not Track,” please
visit http://www.allaboutdnt.com.
Choosing not to share your
personal information. Where we are required by
law to
collect your personal information, or where we need your
personal information in order to provide the Services to
you, if you do not provide this information when
requested (or you later ask to delete it), we may not be
able to provide you with our Services. We will tell you
what information you must provide to receive the
Services by designating it as required at the time of
collection or through other appropriate means.
Third-party platforms or social
media networks. If you choose to connect to the
Services
via a third-party platform or social media network, you
may have the ability to limit the information that we
may obtain from the third-party at the time you login to
the Service using the third-party’s authentication
service or otherwise connect your account. Subsequently,
you may be able to control your settings through the
third-party’s platform or service. If you withdraw our
ability to access certain information from a third-party
platform or social media network, that choice will not
apply to information that we have already received from
that third-party.
4. Other sites, mobile applications and services
The Services may contain links to other
websites, mobile applications, and other online services
operated by third parties. These links are not an
endorsement of, or representation that we are affiliated
with, any third party. In addition, our content may be
included on web pages or in mobile applications or
online services that are not associated with us. We do
not control third party websites, mobile applications or
online services, and we are not responsible for their
actions. Other websites, mobile applications and
services follow different rules regarding the
collection, use and sharing of your personal
information. We encourage you to read the privacy
policies of the other websites, mobile applications and
online services you use.
5. Security practices
The security of your personal information is
important
to us. We employ commercially reasonable and
appropriate
organizational, technical and physical safeguards
designed to protect the personal information we
collect.
However, security risk is inherent in all internet
and
information technologies and we cannot guarantee the
security of your personal information.
6. International data transfers
We are headquartered in the United States and have
service providers in other countries, and your
personal
information may be transferred to the United States
or
other locations outside of your state, province, or
country where privacy laws may not be as protective
as
those in your state, province, or country.
7. Children
The Services are not directed to, and we do not
knowingly collect personal information from, anyone
under the age of 13. If a parent or guardian becomes
aware that his or her child has provided us with
information without their consent, he or she should
contact us.
8. How to Contact Us
Please direct any questions or
comments about this Policy or privacy practices to
[email address]. You may also write to us via postal
mail at:
Daily AI, LLC
Attn:
[Address]
9.Information for California Residents
Under California Civil Code section
1798.83, California residents are entitled to ask us
for a notice identifying the categories of personal
customer information which we share with our
affiliates and/or third parties for marketing
purposes, and providing contact information for such
affiliates and/or third parties. If you are a
California resident and would like a copy of this
notice, please submit a written request to us via
email at [Insert mailing address and email address].
You must put the statement "Your California Privacy
Rights" in your request and include your name,
street address, city, state, and ZIP code. We are
not responsible for notices that are not labeled or
sent properly, or do not have complete information.
Additionally, if you are a California resident, you
have the following rights:
Information. To request
that we disclose the following information about
our collection and use of your personal
information during the past 12 months:
- The categories of personal information that
we have collected about you;
- The categories of sources from which
personal information is collected;
- The business or commercial purpose for
collecting or selling personal information;
- The categories of third parties with whom we
share your personal information;
- Whether we have disclosed your personal
information for a business purpose, and if
so, the categories of personal information
received by each category of recipient; and
- Whether we have sold your personal
information, and, if so, the categories of
personal information received by each
category of recipient.
Access. To request a copy of the
personal information that we have collected about
you during the past 12 months.
Deletion. To request that we delete
personal information about you that we have
collected from you.
Opt out of sales. To direct us not to
sell your personal information if we do, and if you
are under 16 years of age, we are required to ask
for affirmative authorization from you (or it you
are under 13, your parent or guardian) to sell your
personal information before we do so.
Nondiscrimination. To exercise
your
rights described above free from discrimination,
such as denial of goods or services; price/rate
increases for goods or services (including through
grants of discounts/benefits or imposing penalties);
decreases in service quality; or suggesting that
such discriminatory acts may occur if you exercise
your rights. However, a difference in price or
service quality is not discriminatory if reasonably
related to the value to our business of the personal
information we are unable to use due to the exercise
of your rights, and we may offer you certain
financial incentives that can result in different
prices, rates or service quality.
Financial incentive program
disclosures. Receive a clear description of
the
material terms of any program involving financial
incentives for the collection, sale or deletion of
your personal information, and decide if you want to
consent to be entered in it (you can revoke this
consent at any time).
10. How to exercise your rights
You may exercise the rights described
above as follows:
Right to opt out of sales
You may exercise your right to opt out of sales of
your personal information by visiting the following
web page:Do Not Sell My Personal Information
Right to information, access and
deletion
You may exercise the
information, access and deletion rights described
above by submitting a verifiable request to us by:
Only you, or a person registered
with the California Secretary of State that you
authorize to act on your behalf, may make a
verifiable request related to your personal
information.
The verifiable request must:
- Provide sufficient information that
allows us to reasonably verify you are a
California resident about whom we
collected personal information or their
authorized representative; and
- Describe your request with sufficient
detail that allows us to properly
understand, evaluate, and respond to it.
These rights are not absolute,
are subject to exceptions, and we may be
required or permitted by law to decline your
request.
Personal information that we collect, use and share
The chart below provides
information
that we are required to give you under California
law about the categories of personal information
that we have collected, used and shared in the 12
months preceding the last update of this Privacy
Policy. See our Privacy Policy for a description of
the sources of the personal information we collect,
as well as the business and commercial purposes for
which we collect, use and share this information.
Category* |
Do we collect this info? |
Do we share this info with third parties for
business purposes?** |
Do we “sell” this info?*** |
Identifiers |
Yes |
Yes |
No |
Online identifiers |
Yes |
Yes |
No |
CA Customer Records Categories
|
Yes |
Yes |
No |
Protected Classification Characteristics |
Yes |
Yes |
No |
Commercial Information |
Yes |
Yes |
No |
Biometric Information |
No |
No |
No |
Internet or Network Information |
Yes |
Yes |
No |
Geolocation Data |
No |
No |
No |
Sensory Information
|
No |
No |
No |
Professional or Employment Information |
Yes |
Yes |
No |
Education Information |
No |
No |
No |
Inferences
|
Yes |
Yes |
No |
Other Personal Information |
Yes |
Yes |
Yes |
*For a description of these categories, see the
definition of Personal Information in Section
1798.140(o)(1) of the California Consumer Privacy Act.
** See the section of our Privacy Policy titled How We
Share Your Personal Information for a description of the
business purposes for which we disclose your personal
information and the categories of third parties to which
we disclose it.
*** Our use of your personal information in a manner
that constitutes a “sale” under California law is for
analytics, marketing and advertising purposes.