At Ventrilo, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of Ventrilo Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy by clicking here:
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Ventrilo website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Privacy Policy Table of Contents
- What this Privacy Policy Covers
- Personal Data
- How We Disclose Your Personal Data
- Tracking Tools and Opt-Out
- Data Security
- Data Retention
- Personal Data of Children
- U.S. State Privacy Rights
- Exercising Your Rights under U.S. State Privacy Laws
- European Union, United Kingdom, and Swiss Data Subject Rights
- Contact Information
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We May Collect
This chart details the categories of Personal Data that we may collect or may have collected, depending on your relationship with us:
| Category of Personal Data (and Examples) | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Data |
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| Profile or Contact Data such as first and last name, email, phone number. |
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| Unique Identifiers such as your login information if you create an account with us. |
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| Payment Data such as financial account information, payment card type, last 4 digits of payment card, and billing address, phone number, and email. |
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| Device/IP Data such as IP address, IP-address-based location information, device ID, domain server, and type of device/ operating system/ browser used to access the Services. |
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| Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Services. |
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| Open Tabs such as the names and URLs of tabs you have open on the browser when using our Services. |
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| Browser Content* such as information about or available from web pages and related attachments in connection with our Services (further described below). |
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| Document Content* in documents or images of documents that you upload to the Services. |
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| Conversations* related to your conversations with the AI-Powered Agent. |
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| Memory* including long term facts and context from your Input to our Services. |
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| Other Identifying Information You Voluntarily Choose to Provide or Make Available to us, such User Submissions, User Allowed Content, in emails, chats, or other communications you send us. |
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*Browser, Document, Conversations, and Memory
When you are using our AI-Powered Agent, the default setting will be to collect the names and URLs of open browser tabs. We do not access the content of webpages (“Browser Content”), even related to your open tabs, without your permission. You can restrict access to Browser Content from open tabs at any time within the privacy settings of your Ventrilo account. You can also choose to exclude entire web domains, or specific web pages. If you’d like us to collect Browser Content from excluded web domains, you can also remove it from the excluded list.
If you upload documents or images to the Services, we will need to process the content and text of such documents or images (“Document Content”) in order for our AI-Powered Agent to respond to any related questions or otherwise assist you with that Document.
Your Browser Content, Document Content, conversations and other Inputs, and related Memory will be retained as described in our Terms of Use.
As described in the Targeted Advertising, “Selling,” “Sharing” section below, we will not sell, or share your Browser Content, Document Content, conversations, or Memory and for targeted advertising purposes.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
- Providing and Customizing the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- To maintain, optimize, and provide our products, and Services. Please note that we will not use your Personal Data to train our AI/ML models.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
- Marketing the Services
- Marketing and selling the Services.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Ventrilo or the Services.
- Sending emails and other communications according to your preferences.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Ventrilo or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
- You
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information to us or through the Services.
- When you send us an email or otherwise contact us.
- When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
- When you provide such information directly to us.
- Publicly-Available Information
- Such as from federal, state, or local government records or widely distributed media or similar sources.
- Third Parties
- Vendors
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
- We may use data enrichment services that provide data related to information that the user mentions in input text or chat messages, or that is mentioned in responses to user queries.
- Third-Party Credentials
- Vendors
If you provide your third-party account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
- Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Analytics providers for web traffic or usage of our Services.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- AI model providers.
- Data enrichment and search providers.
- Payment processors.
- Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
- Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
- Advertising Partners. These parties may help us market our services and provide you with offers that may be of interest to you. They may include:
- Ad networks.
- Marketing providers.
- Business Partners. These parties partner with us in offering various services. They include:
- Businesses that you have a relationship with.
- Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
- Social media services.
- Other users.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
Tracking Tools and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking below:
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
- We retain your Unique Identifiers for as long as you have an account with us.
- We retain your payment data for as long as we need to process your purchase or subscription.
- We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
- When you engage with Ventrilo’s chat function, we retain chat data, such as your chat messages, attached files, images, and web page snapshots. If you delete the chat, then we keep this information for at most 30 days after chat deletion.
- We may retain Memory of your interactions with our Services, including chat history with our AI-Powered Agent, to help personalize the Services to you. If you delete all Memory, we irretrievably delete this data within 30 days.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy-request@ventrilo.ai.
U.S. State Privacy Rights
Depending on your state of residence, you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the ‘Exercising Your Rights under U.S. State Privacy Laws’ section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance applicable U.S. State Privacy Laws.
If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy-request@ventrilo.ai.
- Access: You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we have disclosed your Personal Data.
- Deletion: You may have the right to request that we delete the Personal Data that we have collected about you.
- Correction: You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
- Portability: You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
Targeted Advertising, “Selling,” “Sharing”
As described in the “Tracking Tools, Opt-Out” section above, we may incorporate advertising-related Cookies on our marketing website, which would allow our Advertising Partners (who provide those Cookies) to receive information about your activity on our marketing website, including your Device/IP Data and Web Analytics Data. Those Advertising Partners may use that information to serve you relevant ads on other websites that you visit. Under certain U.S. State Privacy Laws, this may constitute “targeted advertising,” “selling,” or “sharing.” We do not sell personal data for monetary compensation.
Please note that this does not include Personal Data collected related to your use of our products – specifically, we do not sell, or share for targeted advertising purposes any of your Inputs (including Browser Content, Document Content, Memory, or conversations). We use targeted advertising solely to drive traffic to our marketing website.
You can opt out from targeted advertising activities related to our marketing website using the following methods:
- By accessing your cookie consent mechanisms here:
- By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the applicable law. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
Anti-Discrimination
We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws.
Other State-Specific Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy-request@ventrilo.ai.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Exercising Your Rights under U.S. State Privacy Laws
To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
Request to Access, Delete, or Correct
As applicable, you may submit a Valid Request for any other rights afforded to you in this Privacy Policy by emailing us at: privacy-request@ventrilo.ai.
Depending on your U.S. state of residence, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Appealing a Denial
Depending on your U.S. state of residence, if we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by emailing us at: privacy-request@ventrilo.ai.
European Union, United Kingdom, and Swiss Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Switzerland, Liechtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Ventrilo will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy-request@ventrilo.ai. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Profile or Contact Data
- Unique Identifiers
- Payment Data
- Device/IP Data
- Open Tabs
- Browser Content
- Document Content
- Conversations
- Memory
- Other Identifying Information or Content that You Voluntarily Choose to Provide
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
- Profile or Contact Data
- Unique Identifiers
- Payment Data
- Device/IP Data
- Web Analytics
- Open Tabs
- Other Identifying Information or Content that You Voluntarily Choose to Provide
We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
- Providing, customizing and improving the Services.
- Marketing the Services.
- Corresponding with you.
- Meeting legal requirements and enforcing legal terms.
- Completing corporate transactions.
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Disclosing Personal Data
The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.
EU, UK and Swiss Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy-request@ventrilo.ai. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Ventrilo practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Ventrilo and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Ventrilo in the U.S. and will be hosted on U.S. servers, and you authorize Ventrilo to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- Ventrilo.ai
- privacy-request@ventrilo.ai
- 2261 Market Street #5126, San Francisco, California 94114
If you are located in the EU or UK, you may use the following information to contact our Data Protection Officer and our EU or UK Based Member Representative:
- EU and UK Representative:
- www.dp-dock.com
- ventrilo@gdpr-rep.com
- EU: DP-Dock GmbH, Attn: Ventrilo.ai, Inc., Ballindamm 39, 20095 Hamburg, Germany
- UK: DP Data Protection Services UK Ltd., Attn: Ventrilo.ai, Inc., 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
- Data Protection Officer:
- DP Dock DPO Services GmbH
- Grüffkamp 10, 24159 Kiel, Germany
- ventrilo@dp-officer.com