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Privacy Policy

1. General Provisions

The OOTO AI Service (“OOTO AI”) collects personal information about you from various sources to provide the OOTO AI Services. “You“ is a user of one or more of our OOTO AI Services (”User“ or ‘Licensee’), or a customer of a User (”Customer"). If you are a Customer, please review our Privacy Policy and Terms of Use to understand how Licensee, who sells our OOTO AI Services, uses your personal information. OOTO AI collects data through the API solely for research or analytical purposes. Data collected through the OOTO AI API includes biometric information (an extractable vector from an image), for example, which in some cases may be considered personal and sensitive information. the image is removed from the service immediately after the User's request is processed. All biometric templates are anonymized, meaning we cannot identify end users from the data we have. OOTO AI will only use the collected data for research and analytical purposes. Research may include analyzing trends, identifying patterns, or developing new products and services. OOTO AI may share collected data with third parties, including research institutes and organizations, for research purposes only. This data will not be used for commercial or marketing purposes. The OOTO AI service will take reasonable steps to protect collected data from unauthorized access, use or disclosure. This includes implementing appropriate physical, technical and administrative safeguards.
We guarantee and assure you that OOTO AI does not store images of Users, obtained through the use of the service by Users. The image is deleted from the service immediately after the User's request is processed.

2. Personal Information We Collect

When you visit our websites, we collect two types of information about you: personal information that you actively provide to us and information that we automatically collect from your devices.

(a) Personal Information We Collect About You. Personal Information is any information relating to an identified or identifiable natural person. Personal Information that you provide to us directly through our websites will be evident from the context in which you provide it. In particular
– When you register an OOTO AI account, we receive your full name, email address and account login information.
– When you fill out our online form or contact our sales team, we receive your full name, work email address, country, and anything else you provide on the forms.
– When you respond to OOTO AI emails, we collect your email address, name and any other information you choose to include in the body of the email or response, as well as any metadata that may be included automatically. If you contact us by phone, we collect the phone number you call OOTO AI.

If you contact us by phone as a licensee, we may collect additional information to verify your identity, such as your name, mailing address, phone number, and email address.

If you are a customer, when you appear in a licensee's authorized camera or conduct transactions through a licensee's application, we collect any transactional information associated with you. Depending on how Licensee uses our OOTO AI Services, we may collect this information directly from you, from Licensee, or from third parties. The information we collect may include biometric data, email address, and other information that is detected or can be obtained from an image or other transaction conducted through the OOTO AI Services. 

Different uses and applications of our OOTO AI Services require the collection of different categories of information. It is up to Licensee to determine what information it collects.

(b) Information we automatically collect on our sites. Our sites use cookies and other technologies to operate efficiently. These technologies record information about your use of our sites, including
– Browser and device information such as IP address, device type, operating system and internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language version of the sites you visit;
– Usage information, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages from which you accessed our Sites or clicked on a link.
– We may also collect information about your online activities on the Sites and connected devices over time, as well as on third party websites, devices, applications, and other online features and services.

3. How we use personal information

(a) Our Products and Services. We use personal information to facilitate business relationships with our users, to comply with our financial regulatory and other legal obligations, and to fulfill our legitimate business interests. However, we do not guarantee compliance with all applicable laws and cannot guarantee that our users use the OOTO AI Software in compliance with applicable laws. We also use personal information to process payment transactions and provide payment-related services to our users.

(b) Marketing and Event-Related Communications. We may send you marketing emails about OOTO AI products and services, invite you to participate in our events or surveys, and otherwise communicate with you for marketing purposes, provided that we do so in accordance with the requirements of applicable consent laws. If we collect your business contact information as part of participating in trade shows or other events, we may use that information to follow up with you about the event, to send you information you have requested about our products and services and, with your permission, to include you in our marketing communications campaigns.

(c) We want to simplify digital identification. To do this, where we have our customers' permission and where not prohibited by applicable law, we use the information we collect to improve and develop our services. This includes creating and improving algorithms, developing and testing new checks, products and services.

4. How and to whom we disclose Personal Information

OOTO AI does not sell or rent personal information to marketers or unaffiliated third parties. We share your personal information with trusted.
(a) Service Providers. We share personal information with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting services, data analytics, information technology and related infrastructure, customer service, email delivery and auditing services. These service providers may need access to personal information to perform their services. We authorize these service providers to use or disclose personal information only as necessary to perform services on our behalf or to comply with legal requirements. We require such service providers to contractually obligate themselves to maintain the security and confidentiality of the personal information they process on our behalf.

(b) Our licensees and third parties authorized by our users. We share Personal Information with Users as necessary to maintain User accounts and provide the OOTO AI Services. We share information with parties directly authorized by the User to receive Personal Information. Use of Personal Information by an authorized third party is governed by that third party's privacy policy.

(c) Business Transactions. In the event we enter into or intend to enter into a transaction that changes the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control or other disposition of all or part of our business, assets or stock, we may share Personal Information with third parties to facilitate and complete the transaction.

(d) Compliance and Prevention of Harm. We may disclose Personal Information if we believe it is necessary to (i) comply with applicable international and Washington State law and other local laws or regulations regarding payment methods; (ii) enforce our contractual rights; (iii) protect the rights, privacy, safety or property of OOTO AI, you or others; and (iv) respond to requests from courts, law enforcement agencies, regulators and other public and governmental authorities, which may include

(e) Data collected will not be disclosed for commercial or marketing purposes.

5. User's legal position

You have a choice regarding our use and disclosure of your personal information:

(a) Opt-out of receiving electronic communications from us. If you no longer wish to receive marketing-related electronic communications from us, you may opt-out by submitting a written request to us. We will endeavor to accommodate your request(s) as soon as possible. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative communications necessary to provide the OOTO AI Services to you.

(b) How you can view or change your personal account information. If you wish to review, correct or update any personal information you have previously provided to us, you may do so by logging into your OOTO AI account or by contacting us.

(c) Your Privacy Rights. Depending on where you live and in accordance with applicable law, you may have the following rights with respect to the personal information we hold about you:
– The right to request confirmation of whether the OOTO AI service processes personal data relating to you and, if it does, to request a copy of such personal data;
– The right to request that OOTO AI correct or update inaccurate, incomplete or outdated personal information about you;
– The right to request that the OOTO AI service delete your personal information in certain circumstances where required by law;
– The right to request that the OOTO AI service restrict the use of your personal information in certain circumstances, such as while the OOTO AI service is considering another request you have submitted.

If the processing of your personal information is based on your prior consent, you have the right to withdraw your consent at any time.

For your protection, we may need to verify your identity before responding to your request, for example, by verifying that the email address from which you submit your request matches the email address we have on file for you. If we no longer need to process personal information about you to provide the OOTO AI Services, we will not retain, collect or process additional information to identify you.

As previously stated OOTO AI does not store User images, the image is removed from the service immediately after the User's request is processed. All biometric templates are anonymized, i.e. we cannot identify end users from the data we have. 

6. Storage of Information

We make reasonable efforts to provide a level of security commensurate with the risk associated with the processing of Personal Information. We take organizational, technical and administrative measures to protect Personal Information within our organization from unauthorized access, destruction, loss, alteration or misuse. Your Personal Information is available only to a limited number of employees who need access to that information to do their jobs. 

We may retain Personal Information after we cease providing the OOTO AI Services to you, even if you close your OOTO AI account, to the extent necessary to fulfill our legal and regulatory obligations and for monitoring, fraud detection and prevention purposes.

7. International Data Transfer

We operate around the world. Personal information may be stored and processed in any country in which we operate or in which we employ service providers. We may transfer the personal information we hold about you to recipients in countries other than the country in which the information was originally collected. These countries may have different data protection laws than your country. However, we will take steps to ensure that any such transfer complies with applicable data protection laws and that your personal information is protected in accordance with the standards described in this Privacy Policy.

8. Legal Basis for Processing

We process biometric and technical data solely based on the following legal grounds
User consent — when applicable, such as when a customer integrates our technology into their app or product and obtains end-user permission;
Performance of a contract — when data processing is necessary to deliver our services;
Legitimate interest — to ensure system security, prevent fraud, and improve the accuracy and reliability of our algorithms, without compromising user rights.We never collect personal data directly from end users, nor do we store images or facial templates after processing is complete.

9. Data Processor Role

OOTO acts solely as a data processor, processing anonymized biometric templates on behalf of its clients. We do not determine the purpose of biometric data processing nor retain any identifiable user information. The responsibility for obtaining appropriate consent and complying with end-user privacy obligations lies with the data controller (our client).

10. Use by Minors

The OOTO AI Services are not intended for anyone under the age of eighteen (18), and we ask that you do not submit any personal information through the OOTO AI Services if you are under that age. 

11. Updates to this Privacy Policy and Notices

We may modify this Privacy Policy from time to time to reflect new services, changes in our personal information practices, or relevant legislation. Any changes will be effective when we post the revised Privacy Policy on the OOTO AI Services. We may provide you with information and notices regarding the Privacy Policy or personal information collected by posting them on our website.

12. Provisions relating to jurisdiction

If you wish to delete your personal or private data, email us at request@ooto-ai.com and we will delete all non-anonymized data.

If you have any questions or complaints about this Privacy Policy, send an email to request@ooto-ai.com.

Address: Doylestown, Pennsylvania 18902 United States

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