Privacy

Last Updated: March 1st, 2021

At AllVoices Holding Co, (“AllVoices,” “we,” or “us”) your privacy is important to us. This Privacy Policy is designed to explain how we collect, use, and disclose information in connection with our website (“the Site”). The terms “AllVoices,” “we,” and “us” include AllVoices and our affiliates and subsidiaries.AllVoices (located at 1507 7th Street #9, Santa Monica, CA) is the data controller for your information. By using the Services, you agree to the terms and conditions of this Privacy Policy. Beyond the Privacy Policy, your use of the Services is also subject to our Terms of Service.

Information We Collect

Information You Provide Us

When you sign up for an account or provide us with a report, we collect information from you such as:

• Telephone number.
• Incident Information: We collect information regarding the incident you witnessed or experienced, including the type of incident (e.g., sexual advances, subtle bias, culture issues, illegal acts); whether you experienced the incident firsthand or witnessed it happening to someone else; and when the incident occurred.
• Company Information: We collect information about the company at which the incident occurred, including the name of the company; the office and department in which the incident occurred; how often you have experienced or witnessed an incident at the company, and your status at the company at the time of the incident.
• Demographic Information: We may collect information about the person subject to the incident.
• Communications: If you contact us directly, we may receive additional information about you. For example, when you chat or email our Customer Support Team, we will receive your email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

If you choose to provide any additional information to us in connection with your report, we collect that information as well.

When you request a demonstration or seek information about our products and services, we collect your email address, company name, and position title.

Information We Collect Automatically From Your Use of the Site

When you use our Site, we and our third party service providers may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Site, you consent to the placement of cookies, beacons, and similar technologies in your browser in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Site.

We may use this information, for example, to ensure that the Site functions properly, to determine how many users have visited certain pages, or to prevent fraud. We use IP address to derive your approximate location.

We use analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. The services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.

How We Use Your Information

• We use your telephone number to verify that you are a real person when you create a report on the Site. We also use your telephone number to follow up with you about your report.
• We use Incident Information and Company Information to report information about incidents to affected companies.
• We also use your information:
• To operate, maintain, enhance and provide features of the Site, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to users.
• To understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, features, and functionality.
• To research and analyze patterns of sexual harassment and discrimination in the workplace, and develop reports and research materials.
• For marketing purposes (in an aggregated or de-identified way), such as for developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest.
• To contact or market to prospective business customers who have requested product demonstrations or information about products and services.
• For our business purposes, such as audits, security, fraud monitoring and prevention.
• To identify potential subject matter and informational resources to you that may pertain to the Company Information or Incident information you have provided.
• To enforce our Terms of Service or other legal rights.

We may use de-identified or aggregate data that does not identify individuals for any purpose and the use and disclosure of such information is not subject to any restrictions contained in this privacy policy.

How We Share Your Information

We may share Company Information and Incident Information with affected companies, including with individual Company employees who have been designated as administrators.

We also share information that we collect through the Site with third parties in the following circumstances:

• With our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, auditing, and other services.
• With a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
• If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose information that does not identify an individual for any purpose, except where we are required to do otherwise under applicable law.

Legal Bases For Use of Your Information

To the extent applicable, the legal bases for using your information as set out in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you)
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our websites, products, software, applications; operate our business and our Services; ensure safe environments for our staff and visitors; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services)
• Where use of your information is required to comply with an EU law (for example, to maintain your payment transaction history for tax reporting purposes)
• When we have your consent as defined by applicable law

Retention of your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

California Privacy Rights

California law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes. However, AllVoices does not share your personal information with third parties for their own direct marketing purposes.

Notice concerning Do Not Track. AllVoices does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals

International Users and Data Transfer

The information discussed in this Privacy Policy that is collected outside of the United States is processed in the United States by AllVoices for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within AllVoices, trusted service providers, and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If you are an EU data subject, if we provide any information about you to any such non-EEA members of our group or third-party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as detailed in the “Contact Information” section below.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

EU Data Subject Rights

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the AllVoices “Contact Us” section below at any time. Your local laws may allow you to request that we:

• Provide access to and/or a copy of certain information we hold about you
• Prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
• Update information which is out of date or incorrect
• Delete certain information which we are holding about you
• Restrict the way that we process and disclose certain of your information
• Transfer your information to a third-party provider of services

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information to provide services to you or to comply with a legal obligation. Moreover, you will not be permitted to examine the information of any other person or entity. We may request you provide us with information necessary to confirm your identity before responding to your request.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

Security

We use certain physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. To report any security concerns, or for any data subject requests, please email privacy@allvoices.co.

We have implemented and shall maintain commercially reasonable and appropriate technical and organizational measures to protect Personal Information against accidental loss, destruction or alteration, unauthorized disclosure or access, or unlawful destruction, including the procedures and internal controls set forth below.

Access Control of Processing Areas

We implement commercially reasonable and appropriate measures in order to prevent unauthorized persons from gaining access to the data processing equipment (namely telephones, database and application servers and related hardware) where Information is processed or used.

Access Control to Data Processing Systems

We implement commercially reasonable and appropriate measures to prevent data processing systems where Information is processed and used from being used by unauthorized persons.

Access Control to Use Specific Areas of Data Processing Systems

We commit that the people entitled to use our data processing system are only able to access the data within the scope and to the extent covered by their respective access permission (authorization) and that Information cannot be read, copied or modified or removed without authorization.

Availability Control

We implement commercially reasonable and appropriate measures to ensure that Information is protected from accidental destruction or loss.

Transmission Control

We implement commercially reasonable and appropriate measures to prevent Information from being read, copied, altered or deleted by unauthorized parties during the transmission thereof or during the transport of the data media.

Input Control

We implement commercially reasonable and appropriate input control measures.

Monitoring

We implement commercially reasonable and appropriate measures to monitor access restrictions to our system administrators and to ensure that they act in accordance with instructions received.

Limits on Retention/Destruction

We take commercially reasonable and appropriate measures designed to destroy or dispose of records containing Information when there no longer exists any lawful basis for processing. We implement commercially reasonable and appropriate measures designed to securely destroy all data consistent with Applicable Data Protection Law. Methods of performing these actions may include the use of a third party disk scrubbing utility or destruction of the drive, such as by degaussing, shredding, or other means of physically destroying data through specialized equipment and services.

Use of Site by Minors

The Services are intended for general audiences and not for anyone under the working age in their jurisdiction and not for children under the age of thirteen (13). We request that children under 13 not provide personal information through the Services. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 in the U.S. or from an EU resident under the age of 16 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Updates to This Privacy Policy

We may make changes to this Privacy Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes, we may notify you through the Services or by sending you an email or other communication. We encourage you to read this Privacy Policy periodically to stay up to date about our privacy practices. Your use of the Site following these changes means that you accept the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@allvoices.co.