Effective Date: 4 November, 2024
Last Updated: 16 December, 2024
Introduction
At Ethos Artificial Intelligence Limited (“Ethos”, “we,” “us,” or “our”), we value your privacy and are committed to protecting your Personal Data, which is information that identifies or can, in combination with other information, reasonably identify you (“Personal Data”). This Privacy Policy explains how we collect, use, disclose, and safeguard your Personal Data when you interact with us, whether through our website, mobile applications, products, or services (collectively, “Services”), or if your Personal Data has been obtained through publicly available sources.
This Privacy Policy applies to:
Visitors to our website.
Users of our products and services.
Individuals who communicate or interact with us in any capacity.
Individuals whose Personal Data has been obtained from publicly available sources.
The purpose of this Privacy Policy is to:
Clearly explain how and why we process your Personal Data.
Inform you of your rights under applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR).
This Privacy Policy does not apply to third-party websites, services, or applications that we do not control, even if they link to or from our Services (“Third-Party Services”).
By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms outlined here, please discontinue use of our Services.
Our Role in Handling Your Personal Data
The role we play in processing your Personal Data depends on the nature of our relationship with you and the services we provide.
1. When We Act as a Data Controller
We are a data controller when we determine the purposes and means of processing your Personal Data (“data controller”). This typically applies in scenarios where:
We collect your data directly, such as when you use our website, create an account, or contact us.
We decide how your data is used, such as for marketing, account management, or service improvements.
As a data controller, we are responsible for ensuring compliance with applicable data protection laws, including the UK GDPR and the EU GDPR.
2. When We Act as a Data Processor
We are a data processor when we process Personal Data on behalf of another organization (the “data processor”). This typically applies in scenarios where:
We provide services to a business customer, and that customer determines the purposes and means of the data processing.
We handle data only according to the instructions provided by the data controller.
As a data processor, we adhere to the instructions of the data controller and implement appropriate safeguards to protect the data.
1. Who We Are
We are Ethos Artificial Intelligence Limited, a technology company. Our registered office is located at:
Ethos Artificial Intelligence Limited
c/o Cogency Global, 6 Lloyd's Avenue
London, EV3V 3AX
United Kingdom
For privacy-related matters, you can contact us at:
Email:support@askethos.com
2. What Personal Data We Collect
We may collect the following categories of Personal Data, including, but not limited to the specific pieces of Personal Data described in each of them:
Customer Content. Messages, text, files, audio or video content, or any other content submitted through the Services (the “Customer Content”).
Services Data. Personal Data that is not Customer Content and is provided, received, obtained or generated by and in connection with our providing the Services (the “Services Data”):
Account Information. To create or update an account, you must supply Ethos with an email address, phone number, password, domain, and/or similar account details. We may also receive your email address and name from other organisations with whom our platform has integrations (e.g., Slack).
Professional Information. You may provide or Ethos may obtain information about your job title or work history, employer, and other work details.
Billing Information. To purchase a paid version of the Services, you may provide Ethos (or its payment processors) with billing details such as credit card information, account and banking information, and/or billing address.
Marketing and Communications Data. Ethos may obtain marketing information, including your preferences in receiving marketing from us and our third parties, and your communication preferences.
Cookie Data. Ethos may use a variety of cookies and similar technologies on our Websites and Services to help us collect Services Data. For more details about how we use these technologies, as well as your options and opt-out opportunities, please see our Cookie Policy below.
Log Data and Metadata. Our servers automatically collect information when you access or use our Websites or Services and record this information in log files. Further, metadata is generated by your use of the Websites or Services to provide additional context about your use thereof. Such data may include but is not limited to:
Internet Protocol (IP) addresses
The address of any web page you visited before using the Website or Services
Browser type, settings, plugins used and language preferences
The content, users, features, and links you view or interact with on the Websites and Services
Types of files shared and any Third-Party Services that you use.
Device Data. We also collect information about the devices used to access the Services, including the type of device, operating system, device settings, application IDs, unique device identifiers, and crash data.
Location Data. We receive information from you to approximate your location, including any addresses you submit or your IP address.
Third-Party Data. We may receive data from affiliates, partners, or other third parties and use it to improve the usefulness of the Services and Website. Such data may be aggregated to generate insights and resources, such as marketing performance or databases of contacts and customers.
Email Performance Data. Ethos may use a ‘clear image’ in email communications in order to track engagement and performance metrics. If you wish to disable this tracking, you can do so by turning off images in the email within your email client.
Third-Party Services Data. You may choose to use Third-Party Services in connection with the Websites or Services. “Third-Party Services” means any platform, add-on, service, product, app or integration not provided by us that you choose to integrate or enable for use with the Website or Services. We may access and exchange Customer Content and Services Data with such Third-Party Services in accordance with our agreements with the relevant Third-Party Services and any permissions granted by you.
Contact Data. In accordance with the relevant consents provided, we process any contact information that you upload or input into the Services.
Additional Data Provided to Ethos. Services Data also includes and data input, uploaded, or provided by you or otherwise associated with your interaction with the Websites, Services, including your use of any artificial intelligence tools, communications with our customer support team, or interactions with our social media accounts.
Other Sources Data. Ethos may receive information about you from public sources, organisations, partners and potential partners, and our affiliates.
Publicly Available Data. Personal Data that is available from publicly available sources, including but not limited to publicly available websites, official registries or records, professional networking platforms (where settings are set to “public”), and media announcement or other similar public announcements (the “Publicly Available Data”).
You are not under any statutory or contractual obligation to provide any Personal Data. However, certain Personal Data is collected automatically through your use of the Websites and Services. In addition, if certain Personal Data, such as account setup details, is not provided, we may be unable to provide the Services.
3. How We Collect Your Personal Data
We collect your Personal Data through:
Direct Interactions: When you fill out forms, contact us, or use our services.
Automated Technologies: Cookies, server logs, and other tracking technologies.
Third Parties: Partners, advertisers, or public sources.
4. Legal Bases for Processing Your Personal Data
We process your Personal Data under the following lawful bases:
Consent: When you have explicitly agreed to the processing.
Contractual Necessity: To fulfill our contractual obligations to you.
Legal Obligation: To comply with applicable laws.
Legitimate Interests: For purposes such as improving services or fraud prevention.
5. How We Use Your Personal Data
Customer Content. When we act as a processor of Customer Content that is Personal Data, we use the Personal Data solely in accordance with the instructions provided in the contract. Otherwise, we use this Personal Data for the legitimate business purposes listed below, unless prohibited or restricted by law.
Services Data and Publicly Available Data. Ethos uses Services Data and Publicly Available Data for the purposes of our legitimate interests in operating the Services, Websites, and our business, which are specified below.
Purposes. Ethos uses Customer Content, Services Data, and Publicly Available Data for the following specific purposes:
To provide, update, maintain, and protect our products, Services, Websites, and business.
To develop and improve products, Services, and Websites, including AI features.
To comply with applicable law, legal process or regulation, or other regulatory purposes.
To support and communicate with you.
To conduct market and user research.
For billing, account management, and other administrative matters.
To investigate and prevent security issues and abuse, including fraud prevention.
If Personal Data is aggregated, anonymized or pseudonymized so that it can no longer reasonably be associated with an identified or identifiable natural person, Ethos may use it for any purpose permissible under applicable law.
6. Disclosure of Your Personal Data
Ethos may share or disclose Personal Data as follows:
Third Parties: We share Personal Data as necessary to facilitate agreed-upon communications or other contractual arrangements on our Services.
Entities and Authorized Users: Owners, administrators, other Entity representatives and personnel, and other authorized users may be able to access, modify, or restrict access to Personal Data. This may include, for example, your employer using Service features to export logs of your activity or accessing or modifying your profile details.
Subprocessors: We may engage third parties as subprocessors to process Personal Data. These third parties may, for example, provide us necessary services like virtual computing and storage services, IT support, and payment processing. Please see more information on our subprocessors at askethos.com/subprocessors.
Third-Party Services: You may choose to enable Third-Party Services. When enabled, Ethos may access and exchange Customer Content with the providers of Third-Party Services on your behalf. Third-Party Services are not owned or controlled by Ethos, and may have their own policies and practices for its collection, use, and sharing of data. You are responsible for reviewing the relevant policies and terms of all Third-Party Services.
Third-Party Developers and Partners: We may share Personal Data with developers, partners, and other contractors and external parties to assist in the development and maintenance of the Websites and Services.
Corporate Affiliates: Subject to and in compliance with applicable law, Ethos may share Personal Data with its corporate affiliates, parents, and/or subsidiaries for business continuity purposes.
Safety and enforcement: We may disclose Personal Data if we believe it is reasonably necessary to increase safety, protect the property or rights of Ethos and its users, or to enforce our rights under contract or prevent illegal activity or harm.
Linked Users: Customer Content (including Personal Data) such as your account and profile as well as your usage information may be displayed to other users linked to your account or organisation on the Ethos platform. The level of access depends on the relative access permissions of any organisation you are a part of.
Corporate changes: If Ethos engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Ethos’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, some or all Personal Data may be shared or transferred, in accordance with applicable law and agreements.
Legal compliance: We may disclose Personal Data if we reasonably believe disclosure is required by any applicable law, regulation, or legal process.
7. International Data Transfers
We may transfer your Personal Data to recipients located outside the United Kingdom (UK) to provide our Services or comply with legal obligations. When we transfer your Personal Data internationally, we are committed to ensuring that it is protected in a manner consistent with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR).
Transfers Within the EEA
For transfers of Personal Data to countries within the European Economic Area (EEA), we rely on the European Commission’s adequacy decisions, confirming that these countries ensure an adequate level of protection for your Personal Data.
Transfers Outside the UK and EEA
For transfers of Personal Data to countries outside the UK and EEA that are not subject to an adequacy decision, we may rely on any of the lawful mechanisms for transfers, including:
Standard Contractual Clauses (SCCs) or UK International Data Transfer Agreement: We may implement the UK Addendum to the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Agreement, ensuring appropriate safeguards for your Personal Data.
Binding Corporate Rules (BCRs): For intra-group data transfers, we may rely on approved Binding Corporate Rules where applicable.
Derogations: In specific circumstances, we may rely on derogations under Article 49 of the UK GDPR, such as where the transfer is necessary for the performance of a contract or with your explicit consent.
Additional Safeguards
To further secure your Personal Data during international transfers, we may do the following:
We may conduct transfer impact assessments (TIAs) where necessary to evaluate risks and ensure compliance with data protection laws.
We may implement technical and organizational measures, such as encryption, to protect your Personal Data during and after transfer.
8. Data Retention
Ethos will retain Customer Content and Personal Data in accordance with your instructions and as required by applicable law. We may retain Services and Publicly Available Data for as long as necessary for the purposes described in this Privacy Policy, including to pursue legitimate business interests, and for purposes of audits, compliance with legal obligations, and dispute resolution.
9. Your Privacy Rights
Depending on where you reside and the applicability of the law, you may have certain rights with respect to your Personal Data. Below are some of the rights you may have.
UK/EU GDPR
If you reside in the UK or EU, you may have the following rights, with some limitations:
Access: Request a copy of your Personal Data.
Rectification: Correct inaccurate or incomplete data.
Erasure ("Right to Be Forgotten"): Request deletion of your data.
Restriction: Limit how we process your data.
Data Portability: Obtain your data in a portable format.
Objection: Object to certain processing, including direct marketing.
You also have the right to make a complaint with the supervisory authority in the jurisdiction in which you reside. The contact information for the supervisory authority in the UK is:
https://ico.org.uk/make-a-complaint/
To exercise your rights, please contact us at support@askethos.com.
Please note that we may request that you provide us with additional information in order to confirm your identity before you may exercise any of the rights.
Exercising Your Rights for Personal Data We Process on Behalf of a Data Controller
In certain circumstances, we process your Personal Data on behalf of another organization (the "data controller"). In such cases, the data controller determines the purposes and means of the processing and is primarily responsible for addressing your privacy rights.
Steps to Exercise Your Rights
If you wish to access, correct, delete, or otherwise exercise your privacy rights concerning data we process on behalf of a data controller, please follow these steps:
Contact the Data Controller Directly
The data controller is the organization that collected your data or provides the services you use.
Please refer to their privacy policy or contact them directly to submit your request.
Inform Us
If you are unsure how to reach the data controller, you may contact us at support@askethos.com.
While we cannot fulfill such requests directly, we will notify the data controller of your inquiry, if appropriate.
Our Role
As a data processor, we:
Process your Personal Data only under the instructions of the data controller.
Assist the data controller, when required, in responding to your request (e.g., retrieving or deleting your data).
Implement appropriate safeguards to protect your Personal Data.
Important Notes
We may be unable to process your request without authorization from the data controller.
For faster resolution, we recommend contacting the data controller directly.
10. Cookies and Tracking Technologies
Subject to compliance with the laws in the jurisdictions in which the Services are provided, Ethos’s use of cookies and similar technologies is described herein.
What are cookies?
“Cookies” are small files created by websites, including our Site, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Site, we use Cookies and other tracking technologies to:
Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customise our Site according to your individual needs;
Contact you to provide you with information or services that you request from us;
Advertise new content, events, and services that relate to your interests;
Provide you with more personalized content that is most relevant to your interest areas; and
Recognize when you return to our Site
How does Ethos use cookies and other tracking technologies?
Ethos uses Cookies, web beacons tracking pixels, tags, or similar tools. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Site. This information allows us to understand how you use the Websites and Services. We use or intend to use both session-based and persistent cookies on our Websites and Services. In addition, we also may use third party cookies (e.g., Google Analytics).
Categories of Use.
Essential Cookies. These Cookies are required for the operation of the Websites and Services and enable you to move around the Site and use its features. Disabling these Cookies can negatively impact the Site’s performance.
Analytics, Performance and Research Cookies. These Cookies allow us to analyze activities on the Websites and Services. They can be used to improve the functioning of the Websites and Services. For example, these Cookies recognize and count the number of visitors and see how they move around the Site. Analytics Cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the Site’s content for those who engage with our advertising.
Functionality and Performance Cookies. These Cookies are used to recognize you when you return to the Websites and Services. This enables us to personalize content for you and remember your preferences. These include cookies that can tell us which language you prefer and what your communications preferences are. They can also help you fill out forms on our Sites more easily and provide you with features, insights, and customised content.
Social Networking Cookies. These Cookies are used to enable you to share pages and content that you find interesting on our Websites and Services through third-party social networking and other websites. These Cookies may also be used for advertising purposes.
Targeting cookies. We may use cookies to help us deliver marketing campaigns and track their performance (e.g., a user visited our Help Center and then made a purchase). Similarly, our partners may use cookies to provide us with information about your interactions with their services.
Please be aware that the cookies we use may depend on the features you are using and the device, browser or operating system you are using. The number and names of cookies, pixels and other technologies may also change from time to time.
Use of cookies for marketing
Ethos may use cookies to market more effectively to you. In doing so, we may work with third parties that use cookies to learn more about your activity on the Websites and Services and other websites. These cookies can help provide Ethos with aggregated auditing, research, and reporting, and knowing when content has been shown to you.
What can you do if you don't want Ethos to use cookies?
It may be possible to block Cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Site.
Browser manufacturers usually provide help pages relating to cookie management. Click on the links below for more information on cookie management for the common browser manufacturers:
For other browsers, please consult the documentation that your browser manufacturer provides.
In addition to managing cookies in your browser settings, you can also opt out of certain third party cookies. For example, we use Google Analytics to help us understand how users engage with our Services, compile reports and improve our Services. The reports disclose usage trends without identifying individual users. You can opt out of these cookies without affecting how you use our Services.
For more information on Google Analytics, see here. You can opt out of Google Analytics and customise the Google Display Network ads by visiting the Google Ads Settings page and installing the Google Analytics Opt-out Browser Add-on from each browser on each device.
You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com). In addition, on your iPhone, iPad or Android, or other mobile device, you can change your device settings to control whether you have opted-in for interest-based ads.
If you want to change your settings at a later time (for example, if you accept all cookies but later decide you do not want a certain type of cookie), then you will need to use your browser settings to remove any third party cookies dropped on your previous visit.
You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.
Do the Websites and Services Respond to “Do Not Track” Signals?
There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Websites and Services do not respond differently based on a user’s Do Not Track signal.
11. Third-Party Links
Our Services may contain links to websites and services operated by third parties, which we do not own or control. This Privacy Policy does not apply to your use of such third-party websites, and you should read the relevant privacy notices and terms and conditions before using such websites or services. Ethos has no responsibility, makes no representations, and disclaims all warranties and liability for websites and services accessed via third-party links.
12. Security
We take commercially reasonable measures to protect Personal Data from unauthorised access or disclosure. Notwithstanding these measures and efforts, no security protections are perfect and we cannot guarantee any data, including Personal Data and Customer Content will be safe. To the maximum extent allowed by law, you agree and acknowledge that Ethos will not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient unless due to Ethos’s negligence.
13. Children’s Privacy
Our services are not intended for or directed to individuals under the age of 18. We do not knowingly collect Personal Data from individuals under the age of 18.
14. Updates to This Privacy Policy
Ethos 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 Services or business. We will post the changes to this page, and we encourage you to review our Privacy Policy to stay informed. If we make material changes to the Privacy Policy, Ethos will take commercially reasonable efforts to notify you and take additional steps as required by law. If you disagree with changes to this Privacy Policy, you should deactivate your account and discontinue your use of the Services. Contact the relevant Entity if you wish to request the removal of your Personal Data under their control.
15. Contact Us
If you have questions about this Privacy Policy, or regarding your Personal Data, you can contact us via email at support@askethos.com.