Privacy

Introduction

When we refer to “ALO”, we mean the entity, ALO.ai, Inc., that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Applicability Of This Privacy Policy

This Privacy Policy applies to ALO’s online workplace productivity tools and platform, including the associated ALO mobile and desktop applications (collectively, the “Services”), alo.ai. app.alo.ai and other ALO websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with ALO. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of ALO’s business.

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

Information We Collect And Receive

ALO may collect and receive Customer Data and other information and data(“Other Information”) in a variety of ways:

Customer Data. Customers or individuals granted access to a Team by aCustomer (“Authorized Users”) routinely submit Customer Data to ALO when using the Services.

Other Information. ALO also collects, generates and/or receives.

Team and Account Information. To create or update a Team account, you or your Customer (e.g., your employer) supply ALO with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide ALO (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.

Usage Information. Services Metadata. When an Authorized User interacts with theServices, metadata is generated that provides additional context about the wayAuthorized Users work. For example, ALO logs the Teams, channels, people, features, content and links you view or interact with, the types of files shared, and what Third Party Services are used (if any).

Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences, and cookie data.

Device information. ALO collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. ALO may also collect location information from devices in accordance with the consent process provided by your device.

Cookie Information. ALO uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

Image information. When you take a photo or upload an image, we collect the image data itself, as well as the metadata associated with the image, such as the date and time the image was created, the camera settings used to create the image, and the people in the image.

Third Party Services. A Customer can choose to permit or restrict Third Party Services for its Team. Typically, Third Party Services are software that integrate with ourServices, and a Customer can permit its Authorized Users to enable and disable these integrations for its Team. ALO may also develop and offer ALO applications that connect the Services with a Third Party Service. Once enabled, the provider of a Third Party Service may share certain information with ALO. For example, if a cloud storage application is enabled to permit files to be imported to a Team we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to ALO to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to ALO. When a Third PartyService is enabled, ALO is authorized to connect and access Other Information made available to ALO in accordance with our agreement with the Third Party Provider and any permission(s) granted by Customer (including, by itsAuthorized User(s)). We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.

‍Contact Information.

ALO collects contact data to enable you to find people you know who are already on ALO and invite people to ALO, even when the app is not in use. ALO will store a copy of the first names, last names, phone numbers, and email addresses in your account on ALO's servers (api-server.alo.ai).

Your contact information is your data and will never be shared, and ALO can be used with or without sharing contact information. If you share your contacts with ALO and then choose to delete your ALO account, your contacts will be permanently removed from ALO. More info on how we handle your contacts is here.

Third Party Data. ALO may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific:for example, how well an online marketing or email campaign performed. Additional Information Provided to ALO. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by ALO or a vendor, request support, interact with our social media accounts or otherwise communicate with ALO.

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

How We Use Information

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

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

To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request, or as required by applicable law, legal process or regulation.

To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.

To develop and provide search, learning and productivity tools and additional features. ALO tries to make the Services as useful as possible for specific Teams and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services or Third Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.

To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about ALO. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from ALO please reach out through the contact mechanisms described below.

For billing, account management and other administrative matters. ALO may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.

To investigate and help prevent security issues and abuse. IfInformation is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, ALO may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

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

How We Share And Disclose Information

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

Customer’s Instructions. ALO will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.

Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Teams. For example, an Authorized User’s email address may be displayed with their Team profile. Please consult with us for more information on Services functionality.

Collaborating with Others. The Services provide different ways forAuthorized Users working in independent Teams to collaborate, such as shared channels or email interoperability. Other Information, such as an AuthorizedUser’s profile Information, may be shared, subject to the policies and practices of the other Team(s).

Customer Access. Owners, administrators, Authorized Users, and otherCustomer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Team activity, or accessing or modifying your profile details.

Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers. Additional information about the subprocessors we use to support delivery of our Services is set forth at ALO Subprocessors.

Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. We require each Third Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, ALO may share Other Information with Third PartyServices. Third Party Services are not owned or controlled by ALO and third parties that have been granted access to Other Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third Party Services or contact the provider for any questions.

Corporate Affiliates. ALO may share Other Information with its corporate affiliates, parents and/or subsidiaries.

During a Change to ALO’s Business. If ALO engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of ALO’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 Other Information may be shared or transferred, subject to standard confidentiality arrangements.

Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective ALO customer the average amount of time spent within a typical Team.

To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. Please see the Data RequestPolicy to understand how ALO responds to requests to disclose data from government agencies and other sources.

To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of ALO or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.With Consent. ALO may share Other Information with third parties when we have consent to do so.

Security

ALO takes data security very seriously. ALO works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. ALO has received internationally recognized security certifications. Given the nature of communications and information processing technology, ALO cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limits

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

Changes To This Privacy Policy

ALO 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 service or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, ALO will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International Data Transfers

ALO may transfer yourPersonal Data to countries other than the one in which you live. We deploy the following safeguards if ALO transfers Personal Data from jurisdictions with differing data protection laws:

E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. To comply with European Union and Swiss data protection laws, ALO.ai, Inc. (“ALO US”) self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. For more information, including the types of Information covered, see ALO US’s Privacy Shield Notice. To learn more about the Privacy Shield Program, please see http://www.privacyshield.gov/welcome. Once the United Kingdom is no longer a Member State of the EuropeanUnion, ALO US will comply with the E.U.- U.S. Privacy Shield in respect of the collection, use and retention of personal data transferred from the UnitedKingdom to the United States in reliance on the E.U. – U.S. Privacy Shield, or any successor framework between the U.S. and the U.K. European Union Model Clauses. ALO offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for ourCustomers that operate in the European Union and the United Kingdom, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available here.Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors. ALO’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross BorderPrivacy Rules (“CBPR”) system and the Privacy Recognition for Processors(“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor”of information. In general, Customer is the controller of Customer Data. In general, ALO is the processor of Customer Data and the controller of OtherInformation.  ALO.ai, Inc., a Delaware Company, is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Teams established for all Customers.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account.If you cannot use the settings and tools, contact the Customer who controls your team for additional access and assistance.

To the extent that ALO’s processing of your Personal Data is subject to the General Data ProtectionRegulation (or applicable laws covering the processing of Personal Data in the United Kingdom), ALO relies on its legitimate interests, described above, to process your data. ALO may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to ALO’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer PrivacyAct or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect And Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. ALO does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@ALO.ai. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict ALO’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is ALO’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

Irish Data ProtectionCommissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, IrelandPhone +353 57 868 4757
Fax: +353 57 868 4757
Email: info@dataprotection.ie

Once the United Kingdom is no longer a Member State of the European Union, if you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the InformationCommissioner’s Office.

Contacting ALO

Please also feel free to contact us if you have any questions about this Privacy Policy or ALO’s practices, or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at privacy@ALO.ai or at our mailing address below:

ALO.ai, Inc.

211 Hope Street #893

Mountain View, CA 94042

United States