Ensemble Privacy Policy

Voiceitt – Privacy Notice and Cookies Policy

Last modified date: December 18^th, 2020

We at Technologies of Voice Interface Ltd., together with our affiliate, Voiceitt, Inc., (“Voiceitt,” “we,” “us” or “our“) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice explains how your Personal Data (as defined below) is collected, used and disclosed by Voiceitt when you visit our Site, use our App, and/or use our Services. If not otherwise defined herein, capitalized terms have the meaning given to them in our Terms of Service, available at https://voiceitt.com/ensemble-terms-of-service (“Terms“).

If you are located in the European Economic Area (“EEA“), UK or Switzerland, for the purposes of applicable data protection laws, some additional terms and rights may apply to you, as detailed herein. Voiceitt and Voiceitt Inc. serve as joint controllers in respect of the processing activities outlined in this Privacy Notice. Technologies of Voice Interface Ltd.’s registered office is Dov Friedman 2, Ramat-Gan, Israel and our registration number is 514794486. For further details regarding our arrangement with Voiceitt, Inc., please contact us at support@voiceitt.com. Voiceitt Inc.’s details and contact information are as follows: 700 Canal Street Stamford, CT 06902.

“Personal Data” or “Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

Privacy Notice Key Points. The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the items in this section in order to find out more information about any topic.

‎What Personal Data We Collect and Why We Collect It
Additional Uses
Sharing the Personal Data We Collect
International Transfer
Security
For Residents in the EEA, UK and Switzerland: Your Rights – How to Access and Limit Our Use of Certain Personal Data
Data Retention
Cookies and Other Tracking Technologies
Third-Party Applications and Services
Communications
Children’s Privacy Notice
Changes to the Privacy Notice
Comments and Questions

What Personal Data We Collect and Why We Collect It. Depending on your usage of the Site, App and Services, we collect different types of data and use it for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Data, but if you choose not to, we may not be able to register you and/or provide you with the Services or part thereof. For instance, if you do not provide permission for the App to access your microphone or provide Recordings, we will not be able to provide you with the Services. We may receive and/or collect Personal Data from you in one or more of the ways listed below.

Users. When you use the Services, we collect the following types of Personal Data from you:

Registration Data. In order to use our Services, you will be required to register and provide us with the following mandatory Personal Data: your name and email address as well as a password that you will choose and use for your User Account. You may choose to provide optional information such as your age, native language, country, information about your health and diagnosis (see ‘Special Categories’ below), and information about your speech characteristics.

How we Use this Data: We use this Personal Data in order to provide you with the Services and to respond to your inquiries and requests and to contact and communicate with you; and (2) to prevent fraud, improve the Services and App, protect the security of and address any problems with the App.

Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered performance of a contract with you, including responding to your inquiries and requests and providing customer support; (2) when we process the Personal Data to prevent fraud, improve the Services and/or our app, protect the security of and address any problems with the App, we process the Personal Data based on our legitimate interest.

Purchase and Transaction Data. When you make a purchase through Apple’s App Store to access and use the Services, we may collect information from the App Store, such as items purchased, date and time of your transaction, amount of transaction, and other order details.

Automatically Collected Data. When you use the Services, we will collect information about your mobile device, including non-Personal Data such as your device type, and Personal Data such as your device ID and your actual usage and related account activity, including, but not limited to, your last login time, duration of login and list of activities performed by you. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our App and Services, and address any problems with the App and/or Services.

Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights.

Voice Recordings. Upon installation of the App, we may request access to your microphone or voice recordings. This allows you to have the capability to record and upload chosen voice recordings for the purpose of creating a translation of non-standard speech into recognizable speech to enable you to communicate better (“Recordings”). With your permission, Recordings can be activated by pressing the “record” button on the App, or through the use of a wake word such as [“Computer”]. The App is designed to detect wake words by identifying acoustic patterns that match the wake word. The App will only send to the cloud or store the voice recordings that are initiated through either the wake word or by pressing a button. For more information about your rights in connection with voice recording, please see the “Your Rights – How to Access and Limit Our Use of Certain Personal Data” section.

How we use this data: (1) to provide you with the Services, including to learn to recognize your individual speech patterns, (2) to train our machine learning algorithms, troubleshoot, and to analyse and improve our products and Services; and (3) and tailor our Services to your needs and the needs of other users.

Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered performance of a contract with you and (2) based our legitimate interests to develop our products and Services, review usage, perform analytics, for our recordkeeping, and protection of our legal rights.

Text of Recordings – Through the use of the Services, we may also collect the text version of the Recordings, as well as related text matching the recognizable speech of such Recordings.

Special Categories of Data – In the course of providing our Services to you, we also may collect data concerning your health, which is subject to special protections under the law. We will only collect such data if you provide your consent.

How we use this data: We use this data in order to improve our Services and tailor our Services to your needs and the needs of other users.

Legal Basis: We process this Personal Data based on your explicit consent. You may withdraw your consent by contacting us at support@voiceitt.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.

Visitors to the Site

Contact Information. If you send us a “Contact Us” request, whether by submitting an online form or by sending an email to an email address that we display with questions, comments or for purposes of customer/technical support, or in order to subscribe to our mailing list, we collect the information contained in your message and any other information, including Personal Data, you provide.

How we use this data: To respond to your request or inquiry, to provide you with newsletters, and for retargeting purposes.

Legal Basis: We process this Personal Data (1) as it is necessary for our legitimate interests, namely communicating with you to respond to your queries or concerns; (2) based on performance of a contract with you when we provide you with service-related communications; and (3) only where you have given us consent to do so where we send you our newsletter, other marketing communications and for re-targeting purposes.

Automatically Collected Data. When you visit the Site, we will collect information about your computer, including non-Personal Data such as your operating system and browser type, and Personal Data such as your IP address date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services.

Legal Basis: We process this Personal Data for our legitimate interests to develop our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights.

Additional Uses

Statistical Information. By analysing the information we receive, including all information concerning users we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics. We and/or our service providers or subcontractors, use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the Site, App, and/or Services. Such Tools collect information such as how often users visit the Site or App what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site or App. The Tools may collect certain Personal Data and may link such Personal Data to specific information stored in our customer database. We use the information we get from the Tools to improve our Site, App, and/or Services. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service located at http://www.google.com/analytics/terms/us.htmland the Google Privacy Policy located at http://www.google.com/policies/privacy/.

Direct Marketing. As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. We may contact you by email or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:

We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at any time by emailing support@voiceitt.com.

You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below.

Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:

We share information, including your Personal Data, with our affiliated company and joint controller, Voiceitt, Inc. where this is necessary to provide you with our products and Services, and for the purpose of management of our business.

Service Providers, and Subcontractors. We also disclose information, including Personal Data we collect from and/or about you, to our trusted third-party service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site, App, and/or Services; (2) aid in their understanding of how users are using our Site, App, and/or Services; (3) for the purpose of direct marketing (see above for more details).

Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, web hosting, data analysis, help us serve advertisements and provide other marketing or mailing services, and provide us with tax and accounting services.

Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation) in such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

International Transfer. We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as the US and Israel, and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country. Whenever we transfer your Personal Data to third parties based outside of the EEA, Switzerland and the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA, Switzerland and the UK.

Please contact us at support@voiceitt.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA, Switzerland and the UK.

Security. We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:

Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.

Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.

Internal Policies – We maintain and regularly review and update our privacy related and information security policies.

Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.

Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

For Residents in the EEA, UK and Switzerland: Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, if you are located in the EEA, UK or Switzerland, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavour to explain to you why.

Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.

Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.

Deletion of Personal Data (“Right to Be Forgotten”). You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our App from your mobile devices, terminate your account with us, and clear our cookies from any device where you have used our App. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.

Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.

Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at support@voiceitt.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.

Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.

Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

Right to Object. You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Data Retention. Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

Please contact us at support@voiceitt.com if you would like details regarding the retention periods for different types of your Personal Data.

Cookies and Other Tracking Technologies. We use cookies and similar technologies for a number of reasons, including to help personalize your experience. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting this Site, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein.

What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

A “session cookie” is temporary and will remain on your device until you leave the Site or stop using the App.
A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified below. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

Type of Cookie	Why We Use These Cookies
Necessary	These cookies are necessary in order to allow the Site and/or App to work correctly. They enable you to access the Site and/or App, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
Functionality	These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
Performance	These cookies can help us collect information to help us understand how you use our Site and/or App, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site and/or App.
Analytics	These cookies collect information regarding your activity on our Site and/or App to help us learn more about which features are popular with our users and how our Site and/or App can be improved.
Advertising	These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our Site and/or App and those of third-parties.

How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

Email Cookies. Additionally, cookies may be placed in messages we send in order to track your interaction with such emails.

Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies.

Communications. With your consent, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at support@voiceitt.com. We reserve the right to send you service-related communications, including service announcements and administrative messages, without your consent and without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.

Children’s Privacy Notice. Voiceitt takes special precaution to protect the privacy of our younger users. Voiceitt does not knowingly collect personal information from children under the age of 13 (a “child” or “children”) without the consent of a parent or guardian, and the Service is intended to be used by children under 13 only with parental involvement and approval. If Voiceitt learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing support@voiceitt.com so that we may delete that child’s personal information as soon as possible. In the EU, Voiceitt requires the permission of a parent or guardian where it is processing the personal information of a child aged between 13 and 16 years old. Please contact us at support@voiceitt.com for a copy of a consent form that can be used to provide this permission. By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children’s Privacy Notice and you consent to the collection, use, and disclosure of your child’s personal information as described herein.

Setting up a child account. During the registration process, we collect the user’s first and last name, email address and date of birth. If we determine the individual is a child, we use the contact information for the parent or guardian provided by the child to provide notice and request consent for the child to participate in the full features and functionality of the Service. If a parent wishes to allow their child who is under 13 to register as a user to the Service, we request the Parent provide verifiable consent by submitting a signed parental consent form via email. The child will then be able to participate in most aspects of the Service, subject to the parental controls set forth in “Your Choices” below.

Personal information we collect. We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (name, email address and date of birth) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as native language, country, information about health and diagnosis, and information about speech characteristics. We also collect information generated through your child’s activities on and use of the Service, such as the products, services and functionalities used, content (including text and images) provided or uploaded to the Service, performance data and similar information.

If your child uses the Voiceitt App, we collect voice recordings and text of recordings. We may request access to your child’s device microphone or voice recordings stored on the device through the Voiceitt App. This allows your child to record and upload chosen voice recordings for the purpose of creating a translation of non-standard speech into recognizable speech to enable him/her to communicate better (“Recordings”). The Voiceitt App is designed to detect wake words by identifying acoustic patterns that match the wake word. Through the use of the Voiceitt App, we may also collect the text version of the Recordings, as well as related text matching the recognizable speech of such Recordings.

We automatically collect usage information and information related to the child’s device used to access the Service, such as a device or app ID number or other persistent identifier, IP address, information about the operating system and device settings, as well as certain usage information about the use of the Service. We also collect analytics data. This information is typically collected through a variety of analytical tracking technologies, including cookies, web beacons, log files, and similar technology (collectively, “tracking technologies”), and we may use third party providers to collect this information on our behalf. Please review the section of our Privacy Policy called “What Personal Data We Collect and Why We Collect It” to learn more.

Information sharing. We use the personal information collected to provide the features and functions of the Service, to enhance and improve the Service, and as otherwise disclosed in this Privacy Policy, such as permitting the child to use the App’s translation functions. Voiceitt may share or disclose a child’s personal information with our third party vendors, service providers and business partners or as otherwise required by applicable law, as described in our Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of The Personal Data We Collect” to learn more about how we share information with our vendors, partners and others.

Your Choices. The Parent has a right to request to review or have deleted the child’s personal information and may withdraw consent for the Service to collect any further personal information from the child. Please contact us at support@voiceitt.com to request to review and/or delete any personal information we have collected from the child, or to withdraw permission for Voiceitt to collect any additional information from the child. Please also review the section of the Privacy Policy called “Communications” to learn more about unsubscribing from certain communications from Voiceitt.

Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on our Site. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or by email.

Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at support@voiceitt.com.

Privacy Notice Key Points. The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the items in this section in order to find out more information about any topic.

Danny Weissberg