TranscribeGlass Privacy Policy

1. Personal information we collect

We collect personal information relating to you ("Personal Information") as follows:

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

• Account Information: When you create an account with us, we will collect information associated with your account, including your name, contact information, account credentials, payment card information, and transaction history, (collectively, "Account Information").
• Monitoring Information: We collect information about device health with respect to the TransribeGlass Glasses that you have purchased or that you are using.
• User Content: When you use our TranscribeGlass Services, we collect Personal Information, including any file uploads, or any feedback that you provide to our TranscribeGlass Services ("User Content").
• Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send ("Communication Information").
• Social Media Information: We have or may create pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube, and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, "Social Information"). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
• Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your identity (collectively, "Other Information You Provide").

Personal Information We Receive Automatically from Your Use of the TranscribeGlass Services: When you visit, use, or interact with the TranscribeGlass Services, we receive the following information about your visit, use, or interactions ("Technical Information"):

• TranscribeGlass Device information: We may automatically collect information that your TranscribeGlass Devices have collected, including data regarding a TranscribeGlass Device's health and status, location data for a TranscribeGlass Device, and performance data for a TranscribeGlass Device.
• Log Data:Information that your browser or device automatically sends when you use our TranscribeGlass Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our TranscribeGlass Services.
• Usage Data: We may automatically collect information about your use of the TranscribeGlass Services, such as the types of content that you view or engage with, the features you use, and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
• Service-related Content: We automatically collect and process audio data and content when you use the TranscribeGlass Service to receive transcription services ("Service-related Content") in order to generate the Output. Subject to your consent and your right to opt out, we may also collect and use such Service-related Content to improve and train our artificial intelligence models and to otherwise improve our TranscribeGlass Services.
• Device Information: Includes name of the device, operating system, device identifiers, and browser you are using.
• Cookies: We use cookies to operate and administer our TranscribeGlass Services and to improve your experience.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our TranscribeGlass Services and enhance your experience.

2. How we use Personal Information

We may use Personal Information for the following purposes:

• To provide the TranscribeGlass Services and generating Output;
• To administer, maintain, and/or analyze the TranscribeGlass Services;
• To improve the TranscribeGlass Services and conduct research;
• To communicate with you, including to send you information about our TranscribeGlass Services;
• To develop new programs, products, and/or services;
• To prevent fraud, criminal activity, or misuses of our TranscribeGlass Services, and to protect the security of our IT systems;
• To manage payments for the TranscribeGlass Services;
• To prepare for or carry out Transactions; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our TranscribeGlass Services, to improve and add features or new services to our TranscribeGlass Services, to conduct research, and for other similar purposes. Subject to your consent and your right to opt out, we may use Service-related Content and Output to train and improve our artificial intelligence models and for similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our TranscribeGlass Services or uses of our TranscribeGlass Services or the TranscribeGlass Devices and share aggregated information like general user or use or TranscribeGlass performance statistics with third parties, publish such aggregated information, or make such aggregated information generally available. We may collect aggregated information through the TranscribeGlass Services, through cookies, and through other means described in this Privacy Policy. As noted above, we may use User Content you provide to us and any Technical Information to improve our TranscribeGlass Services. For purposes of this Privacy Policy, “Output” means all textual or data output provided to you by our Services and includes transcriptions and any other output based on any information you provide.

3. Disclosure of Personal Information

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

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, payment processing service providers, providers of artificial intelligence technology or applications thereof, transcription service providers, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfers: Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: We may share your Personal Information, including information about your interaction with our TranscribeGlass Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
• Affiliates: We may disclose Personal Information to our affiliates, meaning a person or entity that controls, is controlled by, or is under common control with TranscribeGlass. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
• Account Administrators: When you create a TranscribeGlass account and while you maintain such an account, the administrators of that account may access and control your TranscribeGlass account.

4. Your rights

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

• Access your Personal Information and information relating to how it is processed;
• Have your Personal Information deleted from our records;
• Rectify or update your Personal Information;
• Transfer your Personal Information to a third party (right to data portability);
• Restrict how we process your Personal Information;
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time;
• Object to how we process your Personal Information; and/or
• Lodge a complaint with your local data protection authority.

You can exercise some of these rights through your TranscribeGlass account. If you are unable to exercise your rights through your account, please submit your request to our customer service at admin@transcribeglass.com.

5. Additional U.S. state disclosures

The following table provides additional information about the categories of Personal Information we collect and how we disclose that information.

You can read more about the Personal Information we collect in "Personal information we collect" above, how we use Personal Information in "How we use personal information" above, and how we retain Personal Information in "Security and retention" below.

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

• The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;
• The right to request deletion of your Personal Information;
• The right to correct your Personal Information; and
• The right to be free from discrimination relating to the exercise of any of your privacy rights.

We do not "sell" Personal Information or "share" Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also do not process sensitive Personal Information for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request through our customer service at admin@transcribeglass.com.

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

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to our customer service at admin@transcribeglass.com.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to our customer service at admin@transcribeglass.com.

California Privacy Rights. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375.

California's "Shine the Light" law (Civil Code § 1798.83) permits users of our Website or App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to admin@transcribeglass.com.

6. Children

If you are under 18 years old, you may not use our TranscribeGlass Services. Our TranscribeGlass Services are not directed to children under the age of 18. TranscribeGlass does not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to TranscribeGlass through the TranscribeGlass Services, please email us at our customer service at admin@transcribeglass.com. We will investigate any notification and, if appropriate, delete the Personal Information from our systems.

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see California Privacy Rights above for more information.

7. Links to other websites

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

8. Security and retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via the TranscribeGlass Services or where and how you use the TranscribeGlass Services, including without limitation transcription services. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the TranscribeGlass Services, or third-party websites.

We will retain your Personal Information for only as long as we need in order to provide our TranscribeGlass Services to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements. It is our current practice not to retain any Service-related Content or corresponding Output after we have transcribed and generated the corresponding Output and displayed it on your TranscribeGlass Device.

9. Compliance with applicable laws

You agree that you will comply with all applicable laws of any applicable jurisdiction when using an TranscribeGlass Device or any TranscribeGlass Service. Without limiting the generality of the foregoing, you agree to comply with all applicable laws that restrict or prohibit recording of conversations or communications. You acknowledge and agree that we will have no responsibility or liability for your use of an TranscribeGlass Device or any TranscribeGlass Service in non-compliance with applicable law. You hereby agree to indemnify and hold harmless TranscribeGlass and its officers and directors for any losses, damages, or expenses incurred by TranscribeGlass and its officers and directors as a result of any failure by you to use an TranscribeGlass Device or any TranscribeGlass Service in non-compliance with any applicable law.

10. International users

By using our TranscribeGlass Services, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in the United States and may be disclosed to our service providers and affiliates in other jurisdictions.

11. Legal Basis for Processing

Our legal bases for processing your Personal Information include:

• Performance of a contract with you when we provide and maintain our TranscribeGlass Services. When we process Account Information, User Content, and Technical Information solely to provide our TranscribeGlass Services to you, this information is necessary to be able to provide our TranscribeGlass Services. If you do not provide this information, we may not be able to provide our TranscribeGlass Services to you.
• Our legitimate interests in protecting our TranscribeGlass Services from abuse, fraud, or security risks, or in developing, improving, or promoting our TranscribeGlass Services. This may include the processing of Account Information, User Content, Social Information, and Technical Information.
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.
• Compliance with our legal obligations when we use your Personal Information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

12. Data transfers

Where required, we will use appropriate safeguards for transferring Personal Information outside of certain countries. We will only transfer Personal Information pursuant to a legally valid transfer mechanism.

13. Data protection officer

You can contact our data protection officer at admin@transcribeglass.com in matters related to Personal Information processing.

14. Changes to the privacy policy

TranscribeGlass may amend this Privacy Policy from time to time upon notice to you by email sent to the email address on file with TranscribeGlass, and by your continued use of the Services following such notice you agree to be bound by such amendments. All such amendments are effective immediately upon notice thereof. You may not amend or revise this Privacy Policy but no modification of this Privacy Policy by you is binding on TranscribeGlass.

15. How to contact us

Please contact us at admin@transcribeglass.com if you have any questions or concerns not already addressed in this Privacy Policy.