The following Privacy Policy describes how Equally AI (collectively, "Equally", "Company", "our", "we", or "us") and its affiliates collect, use, and disclose information, and the choices you have regarding your information. This Privacy Policy applies to Equally’s automated web accessibility solution,"Flowy," (“Equally AI Solution”), the Equally website available at www.equally.ai ( “Website”), and any other communication between an individual (“you” or “User(s)”) and the Company with regard to the access or use of the Equally Solution and/or the Website (collectively, the Equally AI Solution and the Website, “Services”).

This Privacy Policy is incorporated by reference to the Equally AI Terms of Service or any other separate agreement between you and Equally AI, that governs your access to and use of the Services ("Terms"). All capitalized terms not defined here shall have the meaning ascribed to them in the Terms.

This Privacy Policy refers to "Personal Information" as information that relates to an identified or identifiable individual.

Make sure you understand and agree to this Privacy Policy by carefully reading it. If you do not agree to the terms of this privacy policy, do not access or use the Services, the Website, or any other content, service, or software that we provide or make available.

We do not require you to provide any Personal Information, but please keep in mind that without it we may not be able to offer you the full range of Services or the best experience when using the Services.

Information we Collect and Receive

Licensees, Partners, and Resellers (collectively, "Customers"), including individuals acting on their behalf, or individuals visiting the Website or accessing and using certain Services as specifically outlined in this Privacy Statement, provide us with various types of information, including Personal Information.

Information You Provide

1. Information about your account.

Equally AI collects certain Personal Information about you when you register for and create (or update) an Equally AI user account that grants you access to use Equally AI solutions, whether for your benefit or for another user's benefit. Additionally, you may provide us with additional information, such as domains (for example, where the Equally AI Solution will be implemented). Furthermore, when you purchase a license to use the Equally AI Solution, you provide us (or our third-party payment processor) with billing information, such as credit card information, banking information, and billing address. The Personal Information that is part of your account is directly provided by you and, as mentioned above, may include either your Personal Information or the relevant Customer Personal Information. It is possible for you to make changes to certain elements of your Personal Information at any time via your account or by sending an email to support@equally.ai.

2. Device and Technical Information.

About the devices that access the Website, the following information is collected: IP Address, referring URL and domain, device type, operating system and version, browser type and version, and screen resolution.

3. Support Information.

If you contact us via support or provide us with feedback, we will collect certain Personal Information based on how you use the Website or Personal Information you choose to share with us. Depending on the applicable law, we may document your communication with our support team or with other similar channels.

Information Collected from Other Sources

1. Communication in Marketing.

   As part of the sign-up process for any marketing communication from us, including news regarding the Services, we will collect and process your name, email address, and phone number. We may also collect additional information such as your job title and role at the company you work for.

2. Usage Information.

   The Equally Solution collects the following data when a website implements it: Image URLs, link URLs, HTML structure, CSS attributes, clicks, interactions, and pages viewed. The information does not include content or text from the webpage or information from a form or field. Moreover, the foregoing information does not contain any Personal Information of any user and cannot be linked to any user.

3. Log Information.

   When you access or use the Website, our servers record information in log files. The log information we collect may include your IP address, the address of the web page you visited before using the Website, your browser type and settings, and cookie data.

4. Cookies.

   Cookies are used to enhance your experience on our Website. These small packets of information are sent to your browser and may be stored on your device. Session Cookies are temporary and removed after closing your browser, while Persistent Cookies remain on your device for a longer period. We use Persistent Cookies for login convenience and Session Cookies to aid website tool usage. We also use cookies for analytics and advertising campaign effectiveness. You can manage your cookie preferences in your browser settings.

5. Google Chrome.

   Cookies are used to enhance your experience on our Website. These small packets of information are sent to your browser and may be stored on your device. Session Cookies are temporary and removed after closing your browser, while Persistent Cookies remain on your device for a longer period. We use Persistent Cookies for login convenience and Session Cookies to aid website tool usage. We also use cookies for analytics and advertising campaign effectiveness. You can manage your cookie preferences in your browser settings.

6. Segment.

   We use a third-party service provider called Segment to collect certain data about your interactions with our website and services. Segment helps us analyze user behavior, understand usage patterns, and improve our offerings. The data collected through Segment includes, but is not limited to, IP addresses, device type, operating system, browser type, and usage information such as clicks and interactions. Segment collects this data on our behalf and provides us with insights that help us enhance your experience and tailor our services to better suit your needs. Please note that the data collected by Segment is used in accordance with our privacy policy and is subject to the same safeguards and protections.

   If you would like to learn more about Segment's privacy practices, you can review their privacy policy on their website. By using our website and services, you acknowledge and consent to the use of Segment for data collection and analysis as described in this section.

7. Information from Social Media.

   Similarly, we collect social media handles, content, and other information posted on our official social media pages (such as feedback, reviews, email address, and other information). Please note that we may (at our discretion) store and present any information you submit (including Personal Information). If you wish to remove such information, please contact us at support@equally.ai

8. Data obtained through analytics tools.

   Analytics tools (e.g., Google Analytics) and others are used to collect data about the use of the Website. Data is collected by analytical tools such as IP addresses, how frequently users visit the Website, what pages they visit and when, and which website, ad, or e-mail message brought them there.

9. Information We Collect from Third Parties.

   Information about you may be collected from other sources, which may include your Personal Information. You may receive information from the following sources: (i) third parties providing you with information as part of a referral program; (ii) third parties requesting services on your behalf; (iii) third parties providing information in relation to claims or disputes; (iv) service providers (defined below), such as payment processors and social media providers; (v) publicly available information; and (vi) marketing service providers. The information collected from third parties may be combined with other information in our possession.

10. Information Collected in Accordance with Applicable Law.

    We may also collect the information we are required or otherwise authorized to collect under applicable laws in order to authenticate or identify you or to verify the information you have provided, or that we have collected from you through the Services.

Communications.

Emails and phone calls about changes to the Services, updates to your account, billing issues, and important notices may be sent to you, such as security notices or notices regarding your account with us. These communications cannot be opted out of. We may also send you newsletters, updates on new features, offerings, events, special opportunities, and other marketing and promotional emails from time to time. You can opt out of receiving these emails by clicking the unsubscribe link in the email you receive, or by sending a message to support@equally.ai requesting to not receive such communications.

How We Use Your Information

The information we collect is used according to the Terms; your instructions; or in accordance with applicable law; and as part of our legitimate interests in managing and improving our Services and offerings, understanding how users interact with the Services, enhancing marketing, customer service, and support operations, and protecting and securing Users and ourselves.

We do not sell your Personal Information for the intents and purposes of the California Consumer Privacy Act (CCPA).

If you reside or are using the Services in a jurisdiction that requires consent as the sole basis for processing Personal Information (in general, or specifically with respect to the types of Personal Information you choose to share via the Services) Acceptance of the Terms and this Privacy Policy signifies your consent to the processing of your Personal Information for all the purposes detailed in this Privacy Policy. If you wish to withdraw such consent, please contact us at support@equally.ai

Specifically, we use Personal Information to:

• Provide, maintain, and update our services (including your account) and any other products or services we might offer. The Services may include, for example: making sure the Terms are followed, addressing/preventing any errors with the Services, etc Services, or to provide you with assistance and support in relation to the Services;
• Authenticate the identity of our Users and enable them to access and use the Services.
• Contact you. Whenever you send us an email, make a request or inquiry, or share a concern or comment;

• Send you service and technical support, updates, administrative messages, as well as marketing or advertising communications related to our products or services;
• Optimize and improve the Services. Improving the services based upon historical usage, for example;
• detect, investigate and prevent fraud, security risks, misuse of the Services, violations of this Privacy Policy or the Terms, and other illegal activities; to create aggregated statistics, inferred non-personal data, or anonymous or pseudonymized data (made non-personal) that we or our business partners may use to provide and improve our services; billing, account management, and other related matters. As an example, to inform you about a rejected payment method or invoice;
• comply with applicable law and our legal obligations, we respond to court orders, lawsuits, subpoenas, and government requests; and
• perform any other purpose that is readily apparent to you or disclosed to you at the time the information is collected.

How your Personal Information is Shared

Legal Compliance.

In response to a subpoena, search warrant, or court order (or similar requirement), we may disclose or provide access to your Personal Information to government and law enforcement officials.

Service Providers.

In some cases, selected third-party services are provided by third-party companies and individuals (collectively, "Service Providers"). If our Service Providers have access to Personal Information, it is based on each of their specific roles and purposes in facilitating and enhancing the Services, and may only be used for such limited purposes as defined in our agreements with them.

Customer.

When you use the Website on behalf of a Customer, we may share Personal Information with them.

Safety and rights protection.

If we believe in good faith that sharing Personal Information with other parties will help protect the rights, property, or personal safety of Equally, our Users or customers, or the general public, we may do so.

Equally AI Subsidiaries and Affiliated Companies.

We may share Personal Information within our group for the purposes described in this Privacy Statement. Should we or any of our subsidiaries or affiliates undergo a change in control or ownership, such as a merger, acquisition, or sale of substantially all or part of our assets, then Personal Information may be disclosed to the parties involved in such an event.

We may also share Personal Information in other ways, if we have your explicit consent, or if we are legally obligated to do so, or if we have successfully rendered the Information non-personal, non-identifiable, and anonymous.

How Long we Retain your Information

We retain your Personal Information as long as your account is active and as required by the law. After account closure, we may retain certain data for a reasonable period to facilitate proper account closure, including data related to your use of ‘Flowy’.

Data Transfers

It is possible that your Personal Information will be transferred to countries with different data protection laws from the country where you access and use the Services. If a User is in the European Economic Area (EEA), the United Kingdom, or Switzerland, their Personal Information may be transferred to countries outside the EEA, the UK, or Switzerland, for example, to the United States. We ensure that there is a lawful basis for transferring your Personal Information (such as adequacy decisions or Standard Contractual Clauses as adopted by the European Commission) and that your Personal Information is adequately protected as required by applicable law. Contact us at support@equally.ai if you have any questions about the transfer of your Personal Information to other countries.

How We Protect Your Information

We take the security of your Personal Information very seriously. To prevent misuse, damage, or unauthorized access to the Personal Information we collect, we have implemented appropriate security measures. Our security measures take into account industry standards, available technology, and the Personal Information we collect. We do take steps to protect your Personal Information, but we cannot guarantee complete protection or security for information transmitted over the internet, information stored on our servers, or information in our possession or that of any third party.

Your Rights

Individuals have rights regarding their Personal Information. If you wish to exercise your privacy rights under the laws that apply to you (for example, the EU General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), or the California Consumer Privacy Act (CCPA)) such as the right to request access to, and erasure or rectification of your Personal Information held with Equally, or to restrict or object to such Personal Information’s processing, to port such Personal Information, the right to equal treatment under the law, or the right to object to the sale of your Personal Information (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at support@equally.ai

It is also important to note that some of your Personal Information may be processed by third parties acting as 'data controllers,' as described in the "Controller/Processor roles" below. Please contact the relevant party directly if you wish to exercise such rights with respect to their processing activities.

If you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide certain credentials to verify your identity, to avoid disclosure of Personal Information relating to other individuals, and to ask you to provide further information to better understand the nature and scope of information that you wish to access or have deleted, etc. We will retain such additional information in accordance with the "How Long we Retain Your Information" section above (e.g., as proof of the identity of the person submitting the request). We may redact any personal information about others from the information we provide to you.

Our goal is to respond to your request pursuant to "Your Rights" within a reasonable amount of time following receipt of the request, but no later than necessary under applicable law.

Children’s Privacy

We do not knowingly collect, use, or disclose personal information from anyone under the age of 18. If you are under 18, please do not register for an account, use our services, or otherwise send any personal information about yourself to us. In the event we discover that we have inadvertently collected personal information from a child under the age of 18, we will take immediate measures to delete that information from our databases. If you believe that a child under 18 may have provided us with personal information or registered on our platform, please contact us at support@equally.ai.

Third Party Websites and Services

Our Website and Services may provide, for your convenience and information, links or integrations to other websites, applications, or services. These external platforms operate independently and may have their own privacy policies, terms of use, and data collection practices. While we aim to partner with reputable third parties, we cannot audit or control the privacy practices and content of these third-party entities. As such, any personal information you provide or actions you undertake on third-party platforms fall outside our jurisdiction and responsibility. We encourage you to seek out and read each third-party website’s privacy notice to understand how the Personal Information about you is used and protected.

Changes to this Privacy Policy and to the Services

This Privacy Policy is subject to modifications based on legal compliance and business changes. We may revise this policy at our discretion to ensure compliance with laws and regulations, as well as to reflect updates to the Services. Any substantial changes will be communicated to you at least 10 days before the new policy takes effect. By continuing to use the Services, Website, or related content after this notice period, you agree to the revised Privacy Policy. We recommend reviewing this policy periodically to stay informed about its current terms.

Controller/Processor roles

In accordance with the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR), Equally AI acts as both a data controller and processor based on the context of data processing. This means that Equally AI is a controller for certain aspects of data and a processor for others, including data related to Equally AI Solution (Flowy).
If you have any questions, concerns, or inquiries about this Privacy Policy, please reach out to us via email at support@equally.ai. We are committed to addressing your privacy matters and maintaining transparency in our data practices.
Thank you for taking the time to review our Privacy Policy. Your trust and satisfaction are important to us as we continue to provide you with accessible solutions and services.