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| 0 | A121 SOLUTIONS PRIVACY POLICY Last Updated: July 29, 2025 California Consumer Privacy Act (“CCPA”) Notice at Collection The following serves as our notice at collection (“ Notice ”) of Personal Information. | 0 | AI21 Labs – Privacy Policy Last Updated: August 2, 2026 Introduction and Scope AI21 Labs Ltd., together with its subsidiaries and affiliates (“AI21,” “we,” “us,” or “our”), respects your privacy and is committed to protecting Personal Data. |
| 1 | We collect personal information as detailed in this Notice and in our Privacy Policy below. | 1 | This Privacy Policy (this “Policy”) describes how we collect, use, disclose, and otherwise process Personal Data in connection with our website at https://www.ai21.com and other websites we operate (each, a “Site”), and our proprietary artificial-intelligence systems, platforms, applications, application programming interfaces (APIs), tools, models and related products and services (collectively, the “AI Systems,” and together with the Site, the “Services”). “Personal Data” or “Personal Information” means any information that, alone or combined with other information, can identify, relate to, describe, or be reasonably linked to an identified or identifiable natural person. |
| 2 | Categories of Personal Information collected : Automatically collected data: This includes IP address, device type, browser type, operating system, referring URLs, geographic location (country only), and data concerning pages viewed and the time you spend on each page, collected by cookies and other tracking tools, when you interact with our Websites and/or Services. | 2 | When you (a “User”) access or use the Services, your Personal Data will be processed as described in this Policy. |
| 3 | Identifiers (including account credentials information): This includes your name, country, email address, phone number, username and password if you register an account with us. | 3 | This Policy applies to Users of our Services, including business customers, the individual developers and other authorized users acting under a business customer’s account, and individual developers who register in their own right. |
| 4 | We may collect information from partners that verify your identity for account log-in purposes. | 4 | It also applies to visitors to our Site and to individuals who contact us, subscribe to our communications, or interact with us on social media. |
| 5 | Communication information : This includes your contact information and the context of the communication (to the extent considered Personal Information) when you send us an email or request, such as name of workplace and job title. | 5 | You are not legally required to provide Personal Data, but some information is necessary for us to provide the Services, for example to create and administer your account or to respond to a support request. |
| 6 | Geolocation data : This means the device details, geolocation from where your device accesses our Websites and Services based on information like its IP address. | 6 | By accessing or using the Services, you acknowledge that you have read and understood this Policy. |
| 7 | Network and services activity information : This includes content data and how you interact with our Websites and Services, including your answers to general questions (e.g., your preferred language, purpose of usage of the Services), and content supplied through your interaction with our models (e.g., prompts, text, documents, and any other content and information uploaded, entered, or otherwise transmitted by you in connection with your use of the Services), feedback, answers to surveys or other comments sent to us. | 7 | If you do not agree with this Policy, please do not access or use the Services. |
| 8 | Purposes for which the Personal Information is used : To provide you with the Services . | 8 | This Policy forms part of, and should be read together with, our Terms of Service and any other agreement that references it. |
| 9 | We will use your Personal Information for the following purposes: (i) to allow you to create an account; and (ii) to administer and improve, enhance and develop our products and Services. | 9 | Capitalized terms used but not defined in this Policy have the meaning given to them in our Terms of Service. |
| 10 | To allow you to make use of our Website . | 10 | It is important to understand the two distinct capacities in which AI21 may process Personal Data, because they are governed by different rules. |
| 11 | We will use your Personal Information to allow you to make use of our Websites, including: (i) if you complete a Website form, (ii) to answer your questions and to allow you to communicate with us; (iii) to analyze your use of our Websites and to improve our Websites; and (iv) to customize your experience. | 11 | AI21 as a Data Controller . |
| 12 | For Administrative Purposes . | 12 | For most Personal Data we collect directly in operating our business and Services, such as account-registration data, billing and contact details, communications with us, prompts and inputs, and technical and Usage Data , AI21 determines the purposes and means of processing and therefore acts as a “data controller” (and as a “business” under U.S. state privacy laws, and as the database owner or holder under Israeli law). |
| 13 | AI21 uses your Personal Information (i) to respond to your questions, comments, and other requests, or information, including information about potential or future products and Services; (ii) to provide you with the Websites and the Services; (iii) for internal quality control purposes; and (iv) to generally administer the Websites and the Services. | 13 | This Policy governs processing by a data controller. |
| 14 | To Market and develop AI21 products and Services . | 14 | AI21 as a Data Processor . |
| 15 | We use information to market AI21 products and Services. | 15 | When a business customer uses the AI Systems, it may submit, upload, transmit, route, or otherwise make available content and data through the Services, including prompts, inputs, files, datasets, configurations, and the resulting outputs (collectively, “Customer Data”). |
| 16 | Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) adding you to our mailing list, send newsletters or other marketing communications; (iii) advertising AI21 products and Services and other-related offers for you; (iv) conducting market research; (v) developing, enhancing, improving and marketing new products and Services; (vi) to measure interest in our Websites, products and services; (vii) other purposes disclosed at the time you provide information; and (viii) as you otherwise consent. | 16 | To the extent Customer Data contains Personal Data, AI21 processes that Personal Data on behalf of, and under the instructions of, the business customer, who is the data controller (and the “business” or, where applicable, the “service provider’s” customer) for that data. |
| 17 | Security purposes . | 17 | In that capacity AI21 acts as a “data processor” (or “service provider” or the equivalent term under applicable data protection laws). |
| 18 | Some of the abovementioned Personal Information will be used: (i) for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; (ii) To prevent fraud, prohibited or illegal activities and to enforce our contracts with you; (iii) to identify and repair errors; to conduct audits (including bias audit); (iv) for security purposes; and (v) to comply with legal obligations and to protect the rights, privacy, and safety of our users, ours and/or third parties. | 18 | This Privacy Policy does not govern Customer Data for which AI21 acts as a Data Processor. |
| 19 | Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. | 19 | Such data is described herein for informational purposes only. |
| 20 | De-identified and Aggregated Information Use . | 20 | Our processing of Customer Data is governed by the agreement between AI21 and the relevant business customer, including any applicable data processing agreement (“DPA”), and by that customer’s own privacy notices and instructions. |
| 21 | In certain cases, we may aggregate or de-identify your Personal Information and further use it, including, without limitation, to analyze and improve our Websites, as well as our products and Services (including through the use of artificial intelligence) and for research purposes. | 21 | The customer is responsible for the legality of the Customer Data, for providing all required notices, and for obtaining all consents and legal bases necessary for AI21 to process the Customer Data, and for honoring data-subject requests relating to it. |
| 22 | Cookies and Similar Technologies . | 22 | If you are an individual whose Personal Data appears in Customer Data and you have questions or wish to exercise your rights, please contact the relevant business customer directly; we will reasonably assist that customer as required under our agreement and applicable law. |
| 23 | We use cookies, analytic tools and other technologies to automatically collect information through, and to track users’ movement in our Websites and the Services. | 23 | Where you use the Services as an individual developer in your own right (and not on behalf of an organization), we generally act as a controller of your account and usage data, while your own inputs and outputs are handled as described in the “Inputs, Outputs, and AI Processing” section below and in our Terms of Service. |
| 24 | Sale or share of Personal Information : We do not “sell” or “share” Personal Data for cross-contextual behavioral advertising and we do not process Personal Information for “targeted advertising” purposes. | 24 | Data Controller and Contact Information AI21 Labs Ltd. is the data controller for the Personal Data processed under this Policy. |
| 25 | Retention periods : Your Personal Information will be stored until we proactively delete it, or you send a valid deletion request. | 25 | Our principal place of business is in Tel Aviv, Israel. |
| 26 | Please note that in some circumstances we may store your Personal Information for longer periods of time. | 26 | For users in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, AI21 is the controller responsible for your Personal Data under the EU and UK General Data Protection Regulation (collectively, the “GDPR”). |
| 27 | These circumstances include: (i) where we are required to do so, for example for compliance with legal and regulatory requirements in accordance with legal, regulatory, tax or accounting requirements, (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings, and/or (iv) in the form of Aggregated Information (as described below). | 27 | For users in Israel, AI21 is the database owner under the Israeli Privacy Protection Law, 5741-1981. |
| 28 | In order to ensure transparency and give you more control over your Personal Information, this privacy policy (“ Privacy Policy ”) governs how we, AI21 LABS LTD. | 28 | You may contact us, including our privacy team, at privacy@ai21.com . |
| 29 | (together, “ AI21 ”, “ we ”, “ our ” or “ us ”) use, collect and store Personal Data we collect or receive from or about you (“ you ”) such as in the following use cases: In order to ensure transparency and give you more control over your Personal Information, this privacy policy (“ Privacy Policy ”) governs how we, AI21 LABS LTD. | 29 | If you are in the EEA or UK and we are required to designate a representative, the contact details of our EU/UK representative are available on request at privacy@ai21.com . |
| 30 | (together, “ AI21 ”, “ we ”, “ our ” or “ us ”) use, collect and store Personal Data we collect or receive from or about you (“ you ”) such as in the following use cases: When you make use of, or interact with, our websites ( https://www.ai21.com/ ) (“ Websites ”) When you contact us (e.g. customer support, need help, submit a request) When you subscribe to our distribution list(s) / newsletter(s) When you make use of the trust centers, documentation and status page ( trust.ai21.com , status.ai21.com , and/or https://docs.ai21.com/ ) (“ Trust Center ”) When you download, access and/or make use of, or interact with our Studio application programming interfaces, or associated software, websites, tools, developer services, data, UI and design or documentation https://studio.ai21.com/home (“ Studio ”); interact with our Maestro application programming interfaces (“ Maestro ”); or our foundational models (for example, via API or other access methods) (collectively, the “ Services” ) When you download and make use of the Services When you contact us When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. | 30 | Categories of Personal Data We Collect We collect Personal Data in the following categories, depending on how you interact with the Services. |
| 31 | Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to personal data. “ Personal Data ” or “ Personal Information ” means any information that can be used, alone or together with other data, to uniquely identify any living human being. | 31 | Information you provide directly . |
| 32 | Please note that some provisions only apply to individuals in certain jurisdictions. | 32 | When you create an account or register, we collect account and registration data such as your name, email address, username, password, organization name, job title, country, and, for organizational accounts, administrator and authorized-user details (“Account Information”). |
| 33 | Important note : Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement. | 33 | We collect Personal Data that you provide in the input to our Services, including your prompts and other content you upload, and data from connected services , depending on the features you use (“User Content”). |
| 34 | Table of contents: What information we collect, why we collect it, and how it is used Customer Information How we protect and retain your Personal Data How we share your Personal Data Additional information regarding transfers of Personal Data Your privacy rights Use by children Interaction with third party products Analytic tools and other tracking technologies Specific provisions applicable under California Consumer Privacy Act (“CCPA”) Contact us This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. | 34 | Any text or data you input into the Services that contains Personal Data may be collected by us; where you act on behalf of a business customer, such inputs are Customer Data processed under that customer’s instructions and are addressed in the “When This Policy Does Not Apply” section above, not by this Policy. |
| 35 | If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Websites, Services or by other means. 1. | 35 | When you contact us or communicate with us, such as via email, our pages on social media sites, for support, sales, or other inquiries, or when you subscribe to our newsletters or distribution lists, we collect the contents and metadata of those communications, including your name, contact information, work email, telephone number, workplace, and the contents of the messages you send, as well as any other information you choose to provide (“Communication Data”). |
| 36 | WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED Personal Data Why is the Personal Data collected and for what purposes? | 36 | Information collected automatically . |
| 37 | Legal basis (GDPR only, if applicable) Consequences of not providing the Personal Data When you make use of, or interact with, our Websites Cookies and other tracking technologies To review or improve the usage and operations of our Websites To analyze trends To administer the Websites To track users’ movement around the Websites Consent Legitimate interest (e.g., necessary cookies) Certain non-essential Websites features may not be available When you contact us (e.g., customer support, need help, submit a request, schedule a custom demo) Full name Email address Phone number Name of workplace Job title Country of residence Message To process and answer questions To provide support (e.g., to solve problems, bugs or issues) Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract. | 37 | When you access the Site or the AI Systems, we automatically collect the following categories of information (collectively, “Usage Data”): Log Data: Information that your browser or device automatically transmits when you access the Services, including your Internet Protocol (IP) address, browser type and settings, referring URLs, the date and time of your requests, and how you interact with the Site and AI Systems. |
| 38 | Legitimate interest (e.g. respond to your request) Cannot process and answer questionsCannot provide you with support (e.g., to solve problems, bugs or issues) When you subscribe to our distribution list(s) / newsletter(s) Full name Email address To add you to our mailing list To send newsletters or other marketing communications Legitimate interest (e.g. to send you marketing communications). | 38 | Activity Data: Information about your activity across the Services, including pages and features viewed, time spent, click and interaction patterns, session data, and, for the AI Systems specifically, operational and usage metrics relating to your access, configuration, and consumption of the Services, for example, request volumes, routing and model-selection metrics, token and resource consumption, latency and performance data, and error logs which we use to operate, secure, meter, and improve the Services. |
| 39 | Consent (in some contexts) Cannot add you to our mailing list Cannot send you marketing communications When you make use of the Trust Center Cookies and other tracking technologies (e.g., region, usage pattern) To review or improve the usage and operations of the Trust Center To analyze trends To administer the Trust Center To track users’ movement around the Websites Legitimate interest Certain non-essential Trust Center features may not be available Email address When you request us to send you information Legitimate interest Certain non-essential Trust Center features may not be available When you make use of, or interact with the Services When you download, access and/or make use of the Services Username & password Full name Email address IP address Device information To allow you to sign-up To manage your account To know from which countries users access the Services and apply geo-localization rules (e.g. our Service is not allowed from certain countries) To perform the Services pursuant to the agreement executed with the customer Legitimate interest (e.g. to provide you with the Services) Cannot sign-upCannot manage your accountCannot apply geo-localization rules Cannot perform the Services User usage (including, without limitation, data collected using cookies and other technologies relating to, for example, the time you spend on each page of the Services, which links you click on in the Services, which features you like or dislike on the Services. | 39 | Device Information: Information about the device you use to access the Services, such as device name, type and unique identifiers, operating system, and browser version. |
| 40 | Other information collected may include your device’s IP address, device screen size, device type, browser information, geographic location (country only), and the preferred language used to display the Services and derived data from your use of the Services). | 40 | The specific information collected depends on the type of device and its settings. |
| 41 | To improve, enhance and develop the Services, AI21’s products and Services and to conduct research To create statistics and benchmarks To learn patterns For internal quality control checks To monitor and better understand your use of the Services (e.g., via tracking technologies and/or using your feedback) Legitimate interest (e.g., to improve Services and AI21’s products) Cannot improve the Services, AI21’s products and to conduct research Cannot implement quality control checksCannot monitor and better understand your use of the Services Your feedback, answers to surveys or other comments sent to us. | 41 | Location Information: We derive approximate location (such as country or region) from your IP address for security purposes (for example, detecting unusual login activity), analytics, and geo-compliance (for example, applying geographic access rules required by law). |
| 42 | To process your feedback and comments Legitimate interest (e.g. to process your feedback when providing proactively by you). | 42 | We do not collect precise GPS-based location data unless a specific Service feature requires it and you expressly enable it. |
| 43 | Cannot process your feedback When you contact us (e.g. customer support, need help, submit a request) Full name Email address Message Any other information that you decide to provide or supply us with To process and answer questions To provide support (e.g., to solve problems, bugs or issues) Processing is necessary for the performance of a contract to which the data subject is a party (i.e., EULA) or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to your request) Cannot process and answer questionsCannot provide support (e.g., to solve problems, bugs or issues) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) Full name Email address Company name Job position Any other information that you decide to provide or supply us with To answer your questions To establish a connection or discussion Depending on the context, legitimate interest (e.g., to answer your questions and/or establish a connection) or consent Cannot answer your questionsCannot establish a connection/discussion Finally, please note that some of the above-mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits (including, without limitation, bias audits), and for security purposes. | 43 | Cookies and Similar Technologies: We use cookies, pixels, SDKs, log files, and similar technologies to operate and administer the Services, maintain your preferences, assist with authentication and support, and improve your experience. |
| 44 | Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. 2. | 44 | For details about the cookies and tracking technologies we use and how to manage your preferences, please see the “Cookies and Tracking Technologies” section below. |
| 45 | CUSTOMER INFORMATION 2.1. For the avoidance of doubt, AI21 processes the Customer Information (defined below) on behalf of the applicable customer. | 45 | Information from third parties . |
| 46 | Therefore, the customer is the party responsible for the security, integrity and authorized usage of Customer Information in the context of the services and for obtaining all the necessary consents and permissions and providing all notices required for the collection and usage of such Customer Information and honoring all data subject requests. | 46 | We may receive Personal Data about you from affiliates, business partners, resellers, identity-verification and fraud-prevention providers, marketing and business-intelligence providers, social-media platforms where you interact with our presence, and publicly available sources. |
| 47 | AI21 has a contractual relationship with its customers. | 47 | Inputs, Outputs, and AI Processing The Services use artificial-intelligence technology. |
| 48 | In the context of AI21Services, customers can upload, add, input and/or receive to the Services (at the customer’s sole discretion) information, including Personal Data (“ Customer Information ”). 2.2. Customer Information is not regulated by this Privacy Policy, and this paragraph is provided only for transparency purposes. | 48 | As part of providing the Services, Personal Data may be processed, in whole or in part, by AI systems. |
| 49 | If you have any questions related to the Customer Information, please contact the customer directly. 2.3. Please note that, as part of providing our Services, the Personal Data will be processed, in whole or in part, by artificial intelligence (AI) systems. 3. | 49 | Where AI21 acts as a controller (for example, for individual-developer accounts or for our own operational data), we process inputs and outputs to deliver and operate the Services, to return the outputs you request, to maintain security and prevent abuse, to provide support, and to maintain, troubleshoot, and improve the Services. |
| 50 | HOW WE PROTECT AND RETAIN YOUR INFORMATION 3.1. Security . | 50 | Consistent with our Terms of Service, and unless otherwise agreed in writing or required to provide the Services, we do not use your inputs or outputs to train AI21’s foundational or generally available AI models. |
| 51 | We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. | 51 | Because AI output is probabilistic and may be inaccurate or not unique across users, you are responsible for reviewing outputs before relying on them, and AI21 is not responsible for decisions you make based on outputs. |
| 52 | As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information and items. 3.2. Retention of your Personal Data . | 52 | Where AI21 processes inputs and outputs as a processor on behalf of a business customer, that processing is governed by our agreement with the customer and not by this Policy. |
| 53 | Your Personal Data will be stored until we proactively delete it, or you send a valid deletion request. | 53 | How We Use Your Personal Data We use Personal Data for which we are the controller for the following purposes: to create, administer, and secure your account and to provide, maintain, and operate the Services; to authenticate users and administer access for organizational accounts; to process transactions, calculate and collect fees, and meter consumption; to respond to your inquiries and provide customer and technical support; to send service-related and administrative communications, such as security alerts, billing notices, and changes to our policies; to send marketing and promotional communications where permitted, subject to your choices; to operate, analyze, troubleshoot, secure, improve, and develop the Services and our other products, including by analyzing usage patterns and creating statistics, benchmarks, and aggregated insights; to personalize and improve your experience; to detect, prevent, investigate, and respond to fraud, abuse, security incidents, and violations of our terms and policies, including bias and quality audits; to comply with applicable laws, regulations, legal process, and governmental requests, and to establish, exercise, or defend legal claims; and to conduct internal administration, audits, business planning, and corporate transactions. |
| 54 | Please note that in some circumstances we may store your Personal Data for longer periods of time. | 54 | Aggregated and De-Identified Information We may aggregate or de-identify Personal Data so that it no longer identifies you, and may use and disclose such aggregated or de-identified information for any lawful purpose, including to analyze and improve the Services, study usage, develop new features, and produce industry benchmarks and reports. |
| 55 | These circumstances include: (i) where we are required to do so, for example for compliance with legal and regulatory requirements in accordance with legal, regulatory, tax or accounting requirements, (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings, and/or (iv) in the form of Aggregated Information. 4. | 55 | When we use de-identified information, we maintain it as de-identified and do not attempt to re-identify it except as permitted by law. |
| 56 | HOW WE SHARE YOUR PERSONAL DATA In addition to the recipients described above, we may share your Personal Data as follows: 4.1. With our corporate affiliates (e.g. parent and subsidiaries within our group) and/or partners; 4.2. With our vendors and service providers, including: 4.2.1. Email provider and email distribution 4.2.2. Website and product hosting 4.2.3. Payment processor 4.2.4. Customer engagement 4.2.5. Customer support 4.2.6. Product analytics 4.2.7. Website analytic tools 4.2.8. Serving and models Platforms 4.2.9. Business intelligence 4.2.10. | 56 | Legal Bases for Processing (EEA, UK, and Switzerland) If you are located in the EEA, the UK, or Switzerland, we rely on the following legal bases under the GDPR, depending on the processing purpose. |
| 57 | Advertisement/marketing activities Notices from Third Parties: Google – Our use of information received from Google Workspace APIs adheres to the Google AP I Services User Data Policy , including the Limited Use requirements. | 57 | The table below summarizes the principal processing activities, the categories of Personal Data involved, and our lawful basis. |
| 58 | We do not use data obtained from these APIs to develop, improve, or train any machine learning or AI models beyond the user’s own personalized experience. 4.3. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. | 58 | Where more than one basis may apply, we identify the primary basis. |
| 59 | We may use or disclose Personal Data we collect in order to ensure that our users are complying with all applicable aspects of our policies; 4.4. We may disclose Personal Data with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests; 4.5. We may use or disclose Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations; 4.6. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events; 4.7. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 4.8. Where you have provided your consent to our sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality). 4.9. For more information, please contact us at privacy@ai21.com . 5. | 59 | If you reside in, or use the Services within, a jurisdiction where privacy laws require “consent” as the sole or primary legal basis for processing personal data (whether generally, for specific categories of personal data you choose to process, or due to the nature of such processing), your acceptance of our Terms of Service and this Policy will constitute your consent to the processing of your personal data for all purposes outlined in this Policy, unless applicable law mandates a different form of consent. |
| 60 | ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA 5.1. Internal transfers : Transfers within the AI21 group will be covered by an internal processing agreement entered into by members of the AI21 group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to. 5.2. External transfers : We process Personal Data on servers located outside of the EEA, Switzerland and the UK for the purposes described in this Privacy Policy. | 60 | Where consent is the only relevant legal basis for particular processing activities, and you do not provide your consent, we may be unable to provide the Services, in whole or in part. |
| 61 | This includes processing and storing your Personal Data in our facilities and servers in the United States. | 61 | Processing purpose Principal data categories Legal basis Creating and administering your account; providing and operating the Services; authentication and access administration Account Information; User Content; Usage Data Performance of a contract with you, or steps taken at your request before entering into a contract Processing payments, billing, metering consumption, and record-keeping Account Information; Usage Data (Activity Data) Performance of a contract; legal obligation for record-keeping; legitimate interests in accurate billing records Responding to inquiries and providing support Communication Data; Account Information Performance of a contract; legitimate interests in responding to and assisting you Securing the Services; fraud and abuse prevention; debugging; enforcing our terms Usage Data (Log Data, Activity Data, Device Information); Account Information Legitimate interests in protecting our users, the Services, and our business; compliance with a legal obligation Operating, analyzing, improving, and developing the Services and our products Usage Data; User Content; Information from third parties; aggregated and de-identified data Legitimate interests in maintaining and improving our Services Sending marketing and promotional communications Communication Data; Account Information Your consent, where required, or legitimate interests in direct marketing subject to your right to object Non-essential cookies, analytics, and tracking Usage Data (Cookies and Similar Technologies, Log Data, Device Information) Your consent, where required under applicable law Complying with law; responding to legal process; establishing or defending legal claims Any relevant categories Compliance with a legal obligation; legitimate interests in protecting our legal rights Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal, except where, under applicable law in your jurisdiction, consent is the sole available legal basis for the relevant processing, in which case withdrawal of consent may result in our inability to continue providing the relevant services or carrying out the relevant processing. |
| 62 | While data protection law varies by country and some countries may not offer the same level of data protection as your country, we apply the below-mentioned protections to your Personal Data. 5.2.1. We will obtain contractual commitments from them to protect your Personal Data. 5.2.2. We will comply with the transfers rules under the GDPR, including, by implementing a transfer mechanism, for example, transferring Personal Data to a country declared adequate by the European Commission, executing Standard Contractual Clauses with the data recipient and/or relying on their Data Privacy Framework certification. 5.3. For more information, please contact us at privacy@ai21.com . 6. | 62 | Where we rely on legitimate interests, you may object as described in the “Your Privacy Rights” section, and we will stop processing unless we demonstrate compelling legitimate grounds that override your rights or the processing is necessary for legal claims. |
| 63 | YOUR PRIVACY RIGHTS 6.1. Rights : The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals depending on your location and applicable privacy law: You have the right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time, or before the relevant institutions in your place of residence. | 63 | How We Share Your Personal Data We may disclose Personal Data to the following categories of recipients: We share with our affiliates and corporate group for the purposes described in this Policy. |
| 64 | We kindly ask that you attempt to resolve any issues with us before contacting your local supervisory authority and/or relevant institution. | 64 | We engage service providers and subprocessors that perform functions on our behalf, such as cloud hosting and infrastructure, content delivery, analytics, payment processing, customer support and engagement, communications, security and fraud prevention, and marketing, which are contractually bound to use Personal Data only to provide services to us and consistent with this Policy. |
| 65 | You have a right to access Personal Data held about you; You have the right to request that we rectify or delete any Personal Data we hold that is inaccurate or misleading; You have the right to request the erasure/deletion of your Personal Data (e.g. from our records); You have the right to object to, or to request restriction of, the processing of your Personal Data; You have the right to data portability. | 65 | We may share Personal Data with professional advisors such as lawyers, accountants, auditors, and insurers where necessary for advice, risk management, or legal proceedings. |
| 66 | This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller; You have the right to object to profiling; You have the right to withdraw your consent at any time. | 66 | We may disclose Personal Data to regulators, courts, law-enforcement, and other authorities where required to comply with law or legal process, to enforce our terms and policies, to investigate or prevent fraud, security threats, or illegal activity, or to protect the rights, property, or safety of AI21, our users, or others. |
| 67 | Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. | 67 | In connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, Personal Data may be transferred to the counterparty or successor, subject to this Policy or a successor policy. |
| 68 | Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal; You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality; and You have the right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time, or before the relevant institutions in your place of residence. | 68 | We may also share Personal Data with your consent or at your direction. |
| 69 | We kindly ask that you attempt to resolve any issues with us before contacting your local supervisory authority and/or relevant institution. 6.2. Data subject request process : You can exercise your rights by contacting us at privacy@ai21.com . | 69 | We do not “sell” Personal Data for monetary consideration, and we do not “share” Personal Data for cross-context behavioral advertising or process it for targeted advertising in the manner most people would commonly understand those terms; however, certain uses of cookies and similar advertising technologies may constitute a “sale” or “share” under some U.S. state laws, in which case you may exercise the opt-out rights described below. |
| 70 | You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. | 70 | Cookies, Analytics, and Tracking Technologies Our Site and Services use cookies, pixels, SDKs, and similar technologies, as well as third-party analytics, business, marketing, and payment-related tools, to operate and improve the Services, distinguish you from other users, remember your preferences, analyze usage, support billing and fraud detection, enable customer engagement and marketing automation, and, where applicable, deliver relevant content and advertising. |
| 71 | To protect your privacy, we may take steps to verify your identity before fulfilling your request. | 71 | These technologies and providers may collect device, usage, and identifier information. |
| 72 | Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. | 72 | We use strictly necessary cookies, which are required for the Services to function and cannot be switched off; performance and analytics cookies, which help us measure and improve performance; functional cookies, which enable enhanced features and personalization; and marketing or targeting cookies, where applicable. |
| 73 | When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. | 73 | A full list of the cookies we use is available on the Cookie List page on our Site. |
| 74 | We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. | 74 | Third-party providers process information in accordance with their own privacy policies, which we encourage you to review. |
| 75 | In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 6.3. Marketing emails – opt-out : You can unsubscribe from our marketing emails using the link found at the bottom of the email, and we will process your request within a reasonable time after receipt. 7. | 75 | You can manage most cookies through your browser settings and, where we provide one, through our cookie-preference tool, including to withdraw consent to non-essential cookies. |
| 76 | USE BY CHILDREN We do not intentionally collect data from children under the age of eighteen (18). | 76 | Disabling certain cookies may affect the functionality of the Services. |
| 77 | If you believe that we might have any such information, please contact us at privacy@ai21.com . | 77 | We do not currently respond to “Do Not Track” browser signals, as there is no consistent industry standard. |
| 78 | Regardless, in the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. 8. | 78 | We may add or remove analytics and related tools from time to time and will update our disclosures and cookie tools accordingly. |
| 79 | INTERACTION WITH THIRD PARTY PRODUCTS We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “ Third Party Service ”). | 79 | International Data Transfers We operate globally, and your Personal Data may be transferred to, stored in, and processed in countries other than your own, including Israel, the United States, the EEA, the UK, and other locations where we or our service providers operate. |
| 80 | We are not responsible for the privacy practices or the content of such Third Party Services. | 80 | These countries may have data-protection laws that differ from those in your jurisdiction. |
| 81 | Please be aware that Third Party Services can collect Personal Data from you. | 81 | For transfers from the EEA, UK, or Switzerland to countries that are not the subject of an adequacy decision, we implement appropriate safeguards, principally the European Commission’s Standard Contractual Clauses, or we rely on an adequacy decision or another lawful transfer mechanism. |
| 82 | Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service. 9. | 82 | Transfers within the AI21 group are covered by an intra-group data processing agreement requiring an adequate and consistent level of protection. |
| 83 | ANALYTIC TOOLS AND OTHER TRACKING TECHNOLOGIES Google Analytics . | 83 | You may request further information about our transfer safeguards at privacy@ai21.com . |
| 84 | Our Websites use a tool called “ Google Analytics ” to collect information about the use of the Websites. | 84 | Data Retention We retain Personal Data for as long as necessary to fulfill the purposes described in this Policy, after which we securely delete or anonymize it. |
| 85 | Google Analytics collects information such as how often users visit these Websites, what pages they visit, and what other websites they used prior to coming to these Websites. | 85 | Retention periods depend on the nature and sensitivity of the data, the purposes for which we process it, applicable legal, regulatory, tax, and accounting requirements, and our legitimate business needs. |
| 86 | We use the information we obtain from Google Analytics to maintain and improve the Websites and our products. | 86 | We may retain Personal Data for longer where required to comply with law, to maintain accurate records of our dealings with you in the event of complaints or disputes, where we reasonably anticipate litigation, or in aggregated or de-identified form. |
| 87 | We do not combine the information collected through Google Analytics with Personal Data we collect. | 87 | The Services are not intended to serve as a data-storage or archiving product, and you remain responsible for maintaining your own records and backups of your inputs and outputs. |
| 88 | Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Service and the Google Privacy Policy . | 88 | Information Security We implement appropriate technical, organizational, and administrative measures designed to protect Personal Data against accidental loss and unauthorized access, alteration, disclosure, or destruction, consistent with applicable industry certifications we maintain. |
| 89 | You can learn more about how Google collects and processes data specifically in connection with Google Analytics h e re . | 89 | These measures include encryption of data in transit and at rest, access controls limiting access to authorized personnel, security assessments and testing, personnel training, and incident-response procedures. |
| 90 | You may prevent your data from being used by Google Analytics by using the Google Analytics opt-out . | 90 | No method of transmission or storage is completely secure, and we cannot guarantee absolute security; the security of your data also depends on the security of the devices, networks, and credentials you use, which you are responsible for protecting. |
| 91 | YouTube API. | 91 | If you believe your interaction with us is no longer secure, please contact us at privacy@ai21.com . |
| 92 | Our Websites and Services use the YouTube API to collect and process the captions of YouTube videos, as requested by you. | 92 | Your Privacy Rights Depending on your jurisdiction and the applicable law, you may have some or all of the following rights regarding Personal Data for which we are the controller: the right to access and obtain a copy of your Personal Data; the right to correct inaccurate or incomplete data; the right to delete your data, subject to exceptions; the right to data portability; the right to restrict or object to certain processing, including processing based on our legitimate interests; the right to withdraw consent where processing is based on consent; the right to opt out of marketing communications; and the right to opt out of any “sale” or “sharing” of Personal Data and of certain automated processing, where applicable. |
| 93 | We do not collect or share any Personal Data with YouTube via the API. | 93 | You also have the right to lodge a complaint with your local data-protection supervisory authority; we ask that you first contact us so we can try to resolve your concern. |
| 94 | For further details please see the YouTube’s Terms of Service and the Google privacy policy . | 94 | To exercise your rights, contact us at privacy@ai21.com . |
| 95 | Facebook Pixels and SDKs. We use Facebook pixels and SDKs, which help us, and our partners integrate, use, and exchange information with Facebook, including for ad targeting. | 95 | You may use an authorized agent to submit a request on your behalf where permitted, with proof of authorization. |
| 96 | Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our Websites and elsewhere on the internet and use that information to provide measurement services and target ads. | 96 | To protect your privacy, we may take steps to verify your identity before responding, and we may decline or limit a request where permitted by law or where it would adversely affect the rights of others. |
| 97 | Facebook’s ability to use and share information is governed by the Facebook Business Tools Terms. | 97 | We will respond within the timeframe required by applicable law. |
| 98 | You can prevent your data from being used by Facebook Pixels and SDKs by adjusting your ad preferences or using opt-out mechanisms provided by Facebook . | 98 | We will not discriminate against you for exercising your rights. |
| 99 | Facebook Custom Audience. | 99 | If you are an individual whose Personal Data appears in Customer Data processed by AI21 as a processor on behalf of a business customer, please direct your request to that customer, as explained in the “When This Policy Does Not Apply” section. |
| 100 | We may use Facebook’s Custom Audiences and Lookalike Audiences to deliver personalized advertisements to users and individuals who share similar characteristics with our existing audience. | 100 | Email and Marketing Communications We may send you service-related communications, such as account notifications, security alerts, and transaction confirmations, that are necessary to operate the Services and that you cannot opt out of while using the Services. |
| 101 | This may involve sharing hashed (anonymized) email addresses or other identifiers with Facebook solely for the purpose of matching and ad targeting. | 101 | With your consent, or otherwise as permitted by law, we may also send marketing communications, from which you can opt out at any time by using the “unsubscribe” link in our emails or by contacting us at privacy@ai21.com . |
| 102 | These practices are conducted in compliance with applicable data protection laws, and users may opt out of such advertising through their Facebook account settings. | 102 | Opt-out requests may take a reasonable time to process. |
| 103 | For more information, see Facebook’s Privacy Policy . | 103 | We comply with applicable anti-spam laws, including the U.S. CAN-SPAM Act. |
| 104 | Braze. | 104 | Third-Party Services and Links The Services may enable you to access, integrate with, or interact with third-party websites, products, models, or services that we do not own or control (“Third-Party Services”). |
| 105 | We use Braze to manage and deliver personalized communications such as in-app messages, push notifications, and emails. | 105 | This Policy does not apply to Third-Party Services, and we are not responsible for their privacy practices or content. |
| 106 | Braze helps us understand user behavior and tailor our communications accordingly. | 106 | Third-Party Services may collect Personal Data directly from you and process it under their own policies, which we encourage you to review. |
| 107 | Information shared with Braze may include device data, engagement metrics, and interaction history. | 107 | Children’s Privacy The Services are intended for business, professional, and developer use and are not directed to children. |
| 108 | We do not share personally identifiable information unless explicitly required and authorized. | 108 | We do not knowingly collect Personal Data from individuals under the age of eighteen (18). |
| 109 | Braze maintains strong security measures and complies with relevant data protection regulations. | 109 | If you believe a child has provided us Personal Data, please contact us at privacy@ai21.com , and we will take steps to delete it as required by applicable law. |
| 110 | For more details, visit Braze’s Privacy Policy . | 110 | Notice for California Residents This section supplements the rest of this Policy and applies to California residents, to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “ CCPA ”), applies. |
| 111 | Intercom. | 111 | It does not apply to Personal Data we process as a service provider on behalf of a business customer. |
| 112 | We use Intercom as a customer communication platform to provide real-time support, manage user inquiries, and improve engagement through in-app messaging, email, and live chat. | 112 | We collect the categories of personal information described in the “Categories of Personal Data We Collect” section, which may include identifiers; categories listed in California Civil Code section 1798.80(e); protected-classification characteristics; commercial information; internet and electronic network activity; geolocation data; professional or employment-related information; and inferences. |
| 113 | Intercom may collect information such as your name, email address, device information, interaction history, and usage data to help us offer timely and personalized support. | 113 | We collect this information from the sources described above, including directly from you, automatically from your devices, from affiliates and service providers, from business partners, and from publicly available sources. |
| 114 | This data is used solely for communication and service purposes and is not shared with third parties for marketing without explicit consent. | 114 | We use and disclose personal information for the business and commercial purposes described in this Policy. |
| 115 | All information processed through Intercom is handled securely. | 115 | We do not “sell” or “share” personal information in the manner most people would understand those terms, and we do not knowingly sell or share the personal information of consumers under sixteen (16) years of age; however, certain uses of advertising cookies may be treated as a “sale” or “share” under the CCPA, and you may opt out as described above. |
| 116 | Users may request access to or their Intercom data by contacting us directly. | 116 | California residents have the right to know and access the personal information we collect, use, and disclose; the right to delete personal information, subject to exceptions; the right to correct inaccurate personal information; the right to opt out of the sale or sharing of personal information; the right to limit the use and disclosure of sensitive personal information, where applicable; and the right to non-discrimination for exercising these rights. |
| 117 | For more information, please see Intercom’s Privacy Policy . | 117 | To submit a request, contact us at privacy@ai21.com . |
| 118 | Stripe. | 118 | We will verify your identity before responding and will respond within the time required by the CCPA. |
| 119 | We use Stripe for payment, analytics, and other business services. | 119 | We do not offer financial incentives for the collection of personal information. |
| 120 | Stripe collects identifying information about the devices that connect to its services. | 120 | Where we use automated decision-making technology to make a decision that produces legal or similarly significant effects, we will provide any notices and opt-out rights required by applicable California law. |
| 121 | Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. | 121 | Under California’s “Shine the Light” law, California residents may request information about disclosures of personal information to third parties for their direct-marketing purposes by contacting privacy@ai21.com . |
| 122 | You can learn more about Stripe and read its privacy policy . | 122 | Other U.S. State Privacy Rights If you are a resident of a U.S. state with a comprehensive privacy law – including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, or another such state you may have rights similar to those described above, including the rights to access, correct, delete, and port your personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling. |
| 123 | Hotjar . | 123 | To exercise these rights, or to appeal a decision on a request, contact us at privacy@ai21.com . |
| 124 | Our Services use Hotjar to better understand our users’ needs and to optimize our service and user experience. | 124 | Changes to This Policy We may update this Policy from time to time to reflect changes in our practices, technologies, or legal requirements. |
| 125 | Hotjar is a technology service that helps us understand user experience (e.g., how much time users spend on which pages, which links they click, what users do and don’t like, etc.), enabling us to build and maintain our service with user feedback. | 125 | We will post the updated Policy with a new “Last Updated” date and, for material changes, provide additional notice by reasonable means, such as email or an in-product or Site notice. |
| 126 | Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. | 126 | Where required by law, we will obtain your consent before implementing material changes. |
| 127 | This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our App. | 127 | Your continued use of the Services after the effective date constitutes acceptance of the updated Policy. |
| 128 | Hotjar stores this information in a pseudonymized user profile. | 128 | We may also provide “just-in-time” notices that supplement this Policy or offer additional choices at the point of collection. |
| 129 | For further details, please see Hotjar’s privacy policy . | 129 | Contact Us If you have questions, concerns, or complaints about this Policy or our privacy practices, or wish to exercise your rights, please contact us first at: AI21 Labs Ltd. – Attn: Privacy Team / Data Protection Officer – Tel Aviv, Israel – Email: privacy@ai21.com |
| 130 | You can opt out of the creation of a user profile, Hotjar’s storing of data about your usage of our Websites, and Hotjar’s use of tracking cookies on other websites by following this link . | — | Removed |
| 131 | Amplitude . | — | Removed |
| 132 | We use Amplitude, a product analytics platform, to better understand how users interact with our services and to improve user experience. | — | Removed |
| 133 | Amplitude collects information such as in-app actions, usage frequency, common errors, device type, and browser information. | — | Removed |
| 134 | This data is collected in an anonymized manner and does not include personally identifiable information unless the user has explicitly consented. | — | Removed |
| 135 | The insights provided by Amplitude help us identify usage patterns, troubleshoot issues, and optimize the performance of our product. | — | Removed |
| 136 | For more information about how Amplitude handles data, please refer to their privacy policy . | — | Removed |
| 137 | Paragon. | — | Removed |
| 138 | We use Paragon, an integration platform, to facilitate secure and efficient connections between our application and third-party services. | — | Removed |
| 139 | Paragon helps us streamline workflows, automate processes, and manage integrations without compromising user data security. | — | Removed |
| 140 | In the course of providing these integrations, Paragon may process metadata related to connected services, but it does not access or store any personally identifiable information unless explicitly required and authorized by the user. | — | Removed |
| 141 | All data transfers through Paragon are encrypted and comply with industry-standard security protocols. | — | Removed |
| 142 | For more details on how Paragon handles data, please refer to their privacy policy . | — | Removed |
| 143 | Visual Website Optimizer (VWO). | — | Removed |
| 144 | We use Visual Website Optimizer (VWO) to run A/B tests and multivariate experiments on our website. | — | Removed |
| 145 | This allows us to understand which design or content variations perform best, and to optimize the overall user experience accordingly. | — | Removed |
| 146 | VWO may collect data on user interactions, such as clicks, scroll behavior, and session duration, but does not collect personally identifiable information. | — | Removed |
| 147 | All data is anonymized and processed in compliance with applicable privacy laws. | — | Removed |
| 148 | Learn more at VWO’s Privacy Policy . | — | Removed |
| 149 | ZoomInfo . | — | Removed |
| 150 | We may use ZoomInfo to enrich our business contact database and improve outreach efforts in B2B communications. | — | Removed |
| 151 | ZoomInfo provides professional and company-level data, such as job titles, company names, and publicly available contact information. | — | Removed |
| 152 | This data is used for legitimate business interest purposes and complies with relevant data protection regulations. | — | Removed |
| 153 | For more details, see ZoomInfo’s Privacy Policy . | — | Removed |
| 154 | Hockeystack. | — | Removed |
| 155 | We use Hockeystack, a privacy-friendly analytics tool, to understand user behavior across our website and product. | — | Removed |
| 156 | Unlike traditional analytics platforms, Hockeystack focuses on event-based tracking and does not use cookies or collect personally identifiable information by default. | — | Removed |
| 157 | This helps us maintain a high level of user privacy while still gaining valuable insights into product performance. | — | Removed |
| 158 | For more, see Hockeystack’s Privacy Policy . | — | Removed |
| 159 | HubSpot Analytics & Marketing . | — | Removed |
| 160 | We use HubSpot to manage our marketing automation, customer communication, and website analytics. | — | Removed |
| 161 | HubSpot helps us track visitor behavior, manage email campaigns, and analyze lead interactions across channels. | — | Removed |
| 162 | Information such as page views, form submissions, email engagement, and IP addresses may be collected and associated with known user profiles when applicable. | — | Removed |
| 163 | This data is used only for marketing and customer relationship purposes and is handled securely in line with GDPR and CCPA requirements. | — | Removed |
| 164 | See HubSpot’s Privacy Policy for more information. | — | Removed |
| 165 | Log Files . | — | Removed |
| 166 | We use log files to analyze trends, administer the Websites and Services, track users’ movement around the Websites and Services, and gather demographic information. | — | Removed |
| 167 | We reserve the right to remove or add new analytics tools. 10. | — | Removed |
| 168 | SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA CONSUMER PRIVACY ACT 10.1. General . | — | Removed |
| 169 | This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). | — | Removed |
| 170 | We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 and its amendments and regulations (“CCPA”). | — | Removed |
| 171 | Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Policy. 10.2. Categories of Personal Information . | — | Removed |
| 172 | Personal Information collected in the last 12 months is described in Section 1 above. | — | Removed |
| 173 | If you have further questions with respect the collection, use, disclosure or sale of your Personal Information, please make your request by contacting us at privacy@ai21.com . 10.3. Disclosure of Personal Information . | — | Removed |
| 174 | We disclose Personal Information to third parties as described in Section 4 above. 10.4. Categories of sources . | — | Removed |
| 175 | We obtain these categories of personal information listed above from the following categories of sources: Directly from you. | — | Removed |
| 176 | For example, when you make use of the Services. | — | Removed |
| 177 | Indirectly from you. | — | Removed |
| 178 | For example, via any of our vendors and service providers, for example from observing your actions on our Services. 10.5. Your privacy rights . 10.5.1. Rights : The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA: You have the right to know what Personal Information is being collected about you, this includes the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell; You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). | — | Removed |
| 179 | Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims; You have the right to know whether your Personal Information is sold or disclosed and to whom; You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law; You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA; You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in California). | — | Removed |
| 180 | We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution; and If we decline to take action on one of your rights, applicable law may allow us to submit an appeal, this may be done by emailing us at privacy@ai21.com . 10.5.2. Exercise your rights . | — | Removed |
| 181 | You can exercise your rights by following the steps and options described in Section 6 above. 10.5.3. Non-Discrimination . | — | Removed |
| 182 | If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. | — | Removed |
| 183 | However, note that some features of our Websites and the Services will not function without your Personal Information. | — | Removed |
| 184 | Unless permitted by the CCPA, we will not: (i) deny goods or services, (ii) charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you with a different level or quality of goods or services, and (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 10.6. Sale or Share of Personal Information . | — | Removed |
| 185 | We do not “sell” or “share” Personal Data for cross-contextual behavioral advertising and we do not process Personal Information for “targeted advertising” purposes. 10.7. Notice of financial incentives . | — | Removed |
| 186 | We do not offer financial incentives for the collection of Personal Information. | — | Removed |
| 187 | However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. | — | Removed |
| 188 | Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program. 10.8. Our California Do Not Track Notice (Shine the Light) . | — | Removed |
| 189 | Do Not Track (“ DNT ”) is a privacy preference that users can set in certain web browsers. | — | Removed |
| 190 | Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. 11. | — | Removed |
| 191 | CONTACT US If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us – AI21 Labs Ltd., as the data controller, at privacy@ai21.com . | — | Removed |
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