Privacy Policy

01What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Site. “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” 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.

02Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

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 use our interactive tools and Site.
• When you use the Site and such information is collected automatically.
  • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
  • If you use a location-enabled browser, we may receive information about your location.

Third Parties

• Vendors
  • We may use analytics providers to analyze how you interact and engage with the Site, or third parties may help us provide you with customer support.

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

Providing, Customizing and Improving the Site

• Providing you with the products, Site or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Site.
• Improving the Site, including testing, research, internal analytics and product development.
• Personalizing the Site, 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.

Meeting Legal Requirements and Enforcing Legal Terms

• 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, Thread AI, or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• 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.

03How 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 Site or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Support and customer service vendors.

Analytics Partners.

These parties provide analytics on web traffic or usage of the Site. They include:

• Companies that track how users found or were referred to the Site.
• Companies that track how users interact with the Site.

Parties You Authorize, Access or Authenticate

• Third parties you access through the Site.
• Social media Site.
• Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting 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). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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 share it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business, provided that we will not share such data in a manner that could identify you.

Google Workspace Integrations

If you elect to use any Google Workspace Integrations, the use and transfer of raw or derived user data received from Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Transfers Outside of Australia

Thread AI’s operations are primarily located in the United States. Consequently, this means that your Personal Data will be transferred to the United States.

04Tracking Tools and Opt-Out

The Site 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 Site, analyze trends, learn about our user base and operate and improve our Site. 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 Site. 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).

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or Site that you have requested. For example, certain Cookies enable you to log into secure areas of our Site. Disabling these Cookies may make certain features and Site unavailable.
• Functional Cookies are used to record your choices and settings regarding our Site, maintain your preferences over time and recognize you when you return to our Site. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site. They do this by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Site’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics Site. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

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 Site and functionalities may not work.

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.

05SMS/Text Messaging

Thread AI offers SMS text notifications as an optional feature of its Lemma platform as part of the Handoff (human-in-the-loop) product offering. These are operational messages configured by the builder of the workflow sent only to business users who have individually opted in to receive them. SMS notifications are used only where a customer has configured workflows with human-in-the-loop notifications; many users of the platform will never receive SMS messages.

Users opt in by enabling SMS Alerts in their account notification settings within the platform. Consent is optional and is not a condition of using the platform or any of its features. Message frequency varies based on workflow activity. Message and data rates may apply. Users may opt out at any time by disabling SMS Alerts in their account settings or by replying STOP to any message. Reply HELP to any message, or contact [email protected], for assistance.

Mobile phone numbers and SMS opt-in consent are not shared with, sold to, or disclosed to third parties or affiliates for marketing or promotional purposes. Mobile information is shared only with SMS delivery service providers acting on our behalf, solely for the purpose of delivering the messages described above.

06Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Site 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 device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

We do not use data that you provide us to train our own models or third party models without your permission. Any collaborations on model development will require explicit consent on the handling of your data.

07Personal 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 Site 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 [email protected].

08Your Rights

You may request to access or correct your Personal Data by reaching out to [email protected]. Such rights may be subject to certain conditions and restrictions provided by applicable law. We reserve the right to request information to verify your identity as a condition to your request.

09General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Thread AI, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

10Contact Information

If you would like to file a complaint or 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:

[email protected]