Chooch Privacy Policy

Updated Jan 1, 2019

Your privacy is important to us at Chooch Intelligence Technologies Co. (“Chooch”). When you use the Chooch Services, we will receive some information about you. When we talk about the Chooch Services, we mean the websites, apps, APIs, tools and other products, services and features offered by Chooch and linked to this privacy policy.

Some of the information we receive is Personal Data, which means it could be used to directly or indirectly identify a natural person.

This policy is designed to explain to you what information about you, including Personal Data, Chooch collects in providing the Chooch Services, how that information is used and shared and the control you have over that information.

Data processed by Chooch

App users

We do not ask that you set up an account to use the Chooch app to explore the world around you. However, when you point your device and we will collect and store information about you. The legal ground for processing information for this purpose is based on Chooch’s legitimate interest in serving you the correct content as part of the user experience and continuously improving our Services.

This includes digital images of the people or items you scan, your GPS location, IP address and Advertising ID. We’ll never share that information with anyone outside of the Chooch Group.

It also includes information about how you have interacted with our Services and the scans, such as the time and frequency of the interactions, dwell time and the devices and operating systems used to access the scans, so we can understand more about the user journey.

If the scan is connected to a client of ours, all information about scan interactions is combined and shared with them in a way that doesn’t identify any individuals, so that they can better understand the performance of the scans.

Sometimes, the scan experience will be designed to request more Personal Data from you, such as a personal tag, usually in relation to create a better experience for you. In each case, the purpose of the data collection and processing will be explained to you beforehand and you will have the option of not providing the additional information.

The above information is also received by Chooch when you access a scan through third party apps, via an API. Those third parties may decide to collect and send to us additional Personal Data; you can read more about that in their privacy policies.

Account holders

Users of Chooch’s tools, including the Platform and Computer Vision APIs, will have a Dashboard account. We will obtain Personal Data from you to set up the account on your behalf, or you may provide the details via a form to set up the account directly.

We will use your name and email address to create your account profile and to communicate with you regarding the Services, if there are any technical or operational issues or updates which we think our account holders need to know about, or if we make any material changes to our Terms or this Privacy Policy.

The legal ground for processing information for this purpose is for the performance of the contract between us, under which we are delivering our Services to you.

When you interact with our customer support representatives or your account manager via email, telephone, or online, we collect personal data, such as your name, phone number, email address, IP address and contact preferences, information about the Chooch Services you are using, and any other information you volunteer. We also may create event logs to assist with diagnosing and resolving product or app performance-related issues, and capture information relating to the support or service issue. The legal ground for processing information for this purpose is legitimate interests in providing you with quality customer and product support.

Other clients

Other Chooch clients, or prospective clients, may provide us with Personal Data, including name, email address, phone number and other contact information, in connection with the Chooch Services you are, or will be, receiving. The legal ground for process information for this purpose is for the performance of the contract between us, for these Services, or in preparation for entering into that contract. In the delivery of the Services, you might also provide us with content that contains Personal Data, such as digital images of individuals.

Transfer of personal data

Chooch is a global company which transfers Personal Data to other Chooch companies in other countries in order to deliver and maintain our Services. The information we collect in relation to you is stored on data centers operated by our third party providers. Our AWS data centers are currently based in Europe and the United States. By using Chooch Services, you consent to the hosting of your personal information on servers in both locations and the transfer of your Personal Data outside of the country it was collected. It is important to note that countries have different regulations in relation to personal information, including in relation to rights of access by law enforcement authorities.

We will share your Personal Data in the following ways:

• Service Providers – we provide Personal Data to service providers who provide services on our behalf. This includes cloud storage providers, customer support providers, email marketing and SaaS providers.

• Affiliates – we will share Personal Data with the Chooch Group companies. All Chooch companies follow privacy practices set out in this Privacy Policy.

• Clients – we will share non-identifiable, aggregated data relating to your scan activity with our clients to whom the scan is connected. If you have provided additional Personal Data as part of the scan (eg. as part of a competition entry), we will transfer this information to our clients and notify you beforehand.

• Other Third Party Disclosures

• we may also disclose Personal Data about you to others if: we need to comply with a legal or court order, governmental request, investigation, subpoena or other legal obligation;​

• we need to detect and resolve any fraud or security concerns;

• we are involved in a partial or total merger, joint venture, acquisition, financing, asset sale, liquidation or bankruptcy, we may share Personal Data with the other party(s) ahead of that transaction;

• we are enforcing any of our terms or policies or pursuing legal remedies or defending legal claims;

• we have your valid consent.

Cookies and Other Technologies

What is a cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone web browser from a website’s computer (i.e., a Web server) and is stored on your computer, table or mobile phone web browser.

How does Chooch use cookies?

In general terms, Chooch only uses cookies to record information about your preferences, how you prefer to use our websites and our services. They allow us to tailor our app, websites and our other services to your interests.

Information supplied by cookies can help us to analyze the profile of visitors to our app and website and users of our other services and help us to provide you with a better user experience.

Third party cookies

We use analytics cookies and mobile device equivalents served by our third party providers to analyze how users use our app and websites and report back to us. This helps us work out what elements of the app and websites are working and helps us improve them. In the future, we may have digital advertising partners who may use cookies, mobile equivalents and other technologies to collect information to support the delivery of interest-based advertising to users. We will ensure you are properly notified including through updates to this policy before that happens.

Third party cookies in embedded content on Chooch pages

Please note that during your visits to our websites you may notice some cookies that are not related to Chooch or Chooch’s partners. When you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites (“Third Party Websites”). Chooch does not control the dissemination of these cookies. Any information that you provide on or to a Third Party Website or that is collected by a Third Party Website is provided directly to the owner or operator of the Third Party Website and is subject to the owner’s or operator’s privacy policy. Chooch is not responsible for the content, privacy or security practices and policies of any Third Party Website. To protect your information we recommend that you carefully review the privacy policies of all Third Party Websites that you access.

Chooch cookies and how to reject cookies

If you wish to control what cookies are set on your device through our app, websites or other services then you can by changing the settings on your personal computer or mobile device web browser. It is important to note that if you change your settings and block certain cookies, this means that certain personalized features and other functionality cannot then be provided to you and accordingly you may not be able to take full advantage of all of the app, websites or our other services features.

Other information collected from web browsers

Your web browser may also provide Chooch with information about your device, such as an IP address and details about the browser that you are using. It may also provide Chooch with access to details of your personal computer or mobile device’s location.

Children

Chooch does not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data from a child under 13, we will take steps to delete the information as soon as possible. If we need to rely on consent as legal grounds for processing Personal Data and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Retention of Personal Data

We will retain Personal Data for as long as your Chooch account is considered to be active, or otherwise for as long as is necessary for the purposes for which it is being processed, including for ongoing product and service improvement purposes. See below for your rights in relation to the erasure of Personal Data we keep about you.

Your Rights under GDPR

Under the General Data Protection Regulation, individuals have the right to request access to and rectification or erasure of your Personal Data, data portability, restriction of processing of your Personal Data. You also have the right to object to processing of your Personal Data.

By emailing delete@chooch.ai, you can have all account data deleted – if you do this a red flag goes on the database and, while Chooch cannot use the personal information, it stays on the system for a period for administration purposes before being deleted automatically.

You can contact us at privacy@chooch.ai to request information in connection with any of your rights under GDPR.

If you have access to the Dashboard, you can delete scans that you have created, which might contain Personal Data. This content will stay on our systems so that we can offer it to you for future scans, so make sure you email us at delete@chooch.ai if you want it permanently removed.

If you are based in the European Union, you can lodge a complaint with a supervisory authority in your Member State.

Privacy Policy Updates

We may update this Privacy Policy from time to time, as we add new products and services, make improvements to our existing products and services, and as technologies and laws change. You can see when this Privacy Policy was last revised by referring to the date at the top of the Privacy Policy that is available on our website and mobile app. At times, we may provide you with additional notice, such as by adding a statement to our website or in-app notification, or emailing you, where possible. We may be required by law to obtain your consent with respect to these changes.