Privacy Policy

We at boodle, Inc (together with our affiliates, “boodleAI”, “we”, “our” or “us”) respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to Personal Information we collect from or about you when you use our website and services (collectively, “Services”). This Privacy Policy does not apply to content that we process on behalf of customers of our business offerings, such as our API. Our use of that data is governed by our customer agreements covering access to and use of those offerings.

 

1. Personal information we collect

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

Personal Information You Provide: We may collect Personal Information if you create an account to use our Services or communicate with us as follows:

• Account Information: When you create an account with us, we will collect information associated with your account, including your name, contact information, account credentials, payment card information, and transaction history, (collectively, “Account Information”).
• User Content: When you use our Services, we may collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).
• Communication Information: If you communicate with us, we may collect your name, contact information, and the contents of any messages you send (“Communication Information”).
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, and interact with the Services, we may receive the following information about your visit, use, or interactions (“Technical Information”):

• Log Data: Information that your browser automatically sends whenever you use our website (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with our website.
• Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and the like.
• Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Cookies: We use cookies to operate and administer our Services, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website. For more details on cookies please visit All About Cookies.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

 

2. How we use personal information

We may use Personal Information for the following purposes:

• To provide, administer, maintain and/or analyze the Services;
• To improve our Services and conduct research;
• To communicate with you;
• To develop new programs and services;
• To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture, and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated or De-Identified Information. We may aggregate or de-identify Personal Information and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information.

As noted above, we may use Content you provide us to improve our Services, for example to train models. See here for instructions on how you can opt out of our use of your Content to train our models.

 

3. Disclosure of personal information

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
• Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with boodleAI. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

 

4. Your rights

Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

• Access your Personal Information.
• Delete your Personal Information.
• Correct or update your Personal Information.
• Transfer your Personal Information elsewhere.
• Withdraw your consent to the processing of your Personal Information where we rely on consent as the legal basis for processing.
• Object to or restrict the processing of your Personal Information where we rely on legitimate interests as the legal basis for processing.
• You can exercise some of these rights through your boodleAI account. If you are unable to exercise your rights through your account, please send your request to [email protected].

A note about accuracy: Services like boodleBox generate responses by reading a user’s request and then predicting the next most likely words that might appear in response. In some cases, the most likely next words may not be the most factually accurate ones. For this reason, you should not rely on the factual accuracy of output from our models. If you notice that the output from an AI Assistant on boodleBox contains factually inaccurate personal information about you and you would like us to correct the inaccuracy, you may submit a correction request to [email protected]. Given the technical complexity of how our models work, we may not be able to correct the inaccuracy. In that case, you may request that we remove your personal information from that AI Assistant’s output by filling out this form.

 

5. California privacy rights

The following table provides additional information about how we disclose Personal Information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal information in “How we use personal information” above, and how we retain personal information in “Security and Retention” below.

Category of Personal Information	Disclosure of Personal Information
Identifiers, such as your contact details	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.
Commercial Information, such as your transaction history	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.
Network Activity Information, such as Content and how you interact with our Services	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.
Geolocation Data	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.
Your account login credentials (Sensitive Personal Information)	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.

To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to their Personal Information:

• The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;
• The right to request deletion of your Personal Information;
• The right to correct your Personal Information; and
• The right to be free from discrimination relating to the exercise of any of your privacy rights.
• We don’t sell or share Personal Information as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act. We also don’t process sensitive personal information for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. California residents can exercise their CCPA privacy rights by sending their request to [email protected].

Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not provide, correct, or delete your Personal Information.

Authorized Agents. You may submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to [email protected].

 

6. Children

Our Service is not directed to children who are under the age of 13. boodleAI does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to boodleAI through the Service please email us at [email protected]. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have consent from your parent or guardian to use our Services.

 

7. Links to other websites

The Service may contain links to other websites not operated or controlled by boodleAI, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

 

8. Security and Retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

We may also anonymize or de-identify your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, as described above, in which case we may use this information indefinitely without further notice to you.

 

9. International users

By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.

Our Service is not authorized for use by EEA, UK, or Swiss users.

 

10. Changes to the privacy policy

We may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means, you consent to the revised Privacy Policy.

 

11. How to contact us

Please contact support at [email protected] if you have any questions or concerns not already addressed in this Privacy Policy.