Speak - Global Privacy Notice - 12/7/23

Last Modified: 12/7/23

This Privacy Notice explains how Speakeasy Labs, Inc. (“Speak”, “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal data in connection with our websites, including http://www.speak.com, http://www.usespeak.com, and other websites we own and operate that link to this Privacy Notice (the “Sites”), the Speak mobile application (the “App”) and the related content, platforms, services, products, and other functionality offered on or through our services (collectively, the “Services”). This Privacy Notice does not address our privacy practices relating to Speak job applicants, employees, and other personnel. Please note this Privacy Notice is not a contract and does not create any legal rights or obligations.

Data We Process Through Our Customers to Provide Our Services. Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (or the why and the how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to contractual restrictions. In providing our Services, we may collect personal data about our Customers’ end users or other individuals, or we may collect personal data on our Customers’ behalf (all of which we call “Customer Data”). When we process Customer Data, we have contractually committed ourselves to only process such information on behalf and under the instruction of the respective Customer, who is the data controller. This Privacy Notice does not apply to such processing and we recommend you read the Privacy Notice of the respective Customer if their processing concerns your personal data. This Privacy Notice describes how we process personal data in our capacity as a controller.

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REGION-SPECIFIC DISCLOSURES

This Privacy Notice is designed to apply to our Site visitors and users of our Services. We may choose or be required by law to provide additional disclosures relating to the processing of personal information in certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California, Colorado, Connecticut, Nevada, Utah or Virginia in the United States, please click here for additional U.S. state-specific privacy disclosures.
• If you are located in China, please click here for additional China-specific privacy disclosures.
• If you are located in European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), United Kingdom, or Switzerland, please click here for the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures section for additional European-specific privacy disclosures.
• If you are located in Japan, please click here for additional Japan-specific privacy disclosures.
• If you are located in Korea, please click here for additional Korea-specific privacy disclosures.
• If you are located in Mexico, please click here for additional Mexico-specific privacy disclosures.

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1. WHAT IS PERSONAL DATA?

When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or household. It does not include aggregated, de-identified, or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.

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2. HOW WE COLLECT AND USE PERSONAL DATA

Personal Data Collected from Individuals

The categories of personal data we collect submitted to us by individuals through the Services may include:

• Account Information, including full name, email address, mailing address, country or region, social media handle(s), phone number, profile picture, username and password, language selection(s), and payment information. We use this information to administer your account, provide you with the relevant Services-related information, communicate with you regarding your account and your use of the Services, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
• Payment Information, including information collected in connection with signing up for one of our Services that requires payment (i.e., an Speak subscription). Please note that we use third party payment processors, including through the Apple App Store, Google Play Store, Paddle, and Stripe, to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal data is governed by their privacy notice. Please see Stripe’s Privacy Notice here.
• Audio information. Upon installation of the app, we may request access to your microphone or audio recordings in order to provide you with the Services, including for voice recognition purposes. We also use this information to improve Speak’s voice input function, and to develop, create, improve, optimize, maintain, and otherwise enhance its automatic speech recognition and voice transcription technology, and natural language understanding software products, services or platforms.
• Inquiry and Communications Information, including information provided in custom messages sent through the forms on our Services, in chat messages, to one of our email addresses, or via phone, Whatsapp, or other messaging platforms. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
• Newsletter, Marketing Emails, and Blog Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
• Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
• Other Information that you provide to us online, by phone or in person, and use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.

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Personal Data from Third Parties

We also obtain personal data from third parties, which we often combine with personal data we collect either automatically or directly from an individual.

• Our Affiliates. We may receive personal data from other companies and brands owned or controlled by Speak, and other companies owned by or under common ownership as Speak.
• Your Employer / Company. If you engage in our Services through your employer or company, we may receive information from the company such as name and contact information.
• Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you post a question or answer on our Services and linking to information on third-party platforms, we will be able to see any public communications made within that platform.
• Social Media: When an individual interacts with our Services through social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Referrals: we may also receive your name, phone number, and email address from a friend as part of our Referral Program. We may use this information to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Services Providers: Our service providers that perform services solely on our behalf, such as audience measurement, marketing providers and payment processors, collect personal data and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your subscription(s). We may use this information to administer and facilitate our services, your subscriptions, and our marketing activities.
• Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Information we receive from authentication services you connect to our Services: Some parts of our Services may allow you to login through a third-party social network or authentication service such as Facebook, Google, Apple, or Kakao. These services will authenticate your identity and provide you the option to share certain personal data with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).
• Other sources. In addition to third-party data providers, we may also collect personal data about individuals that we do not otherwise have from, for example, publicly available sources, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

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Other Uses of Personal Data

In addition to the above, we may use personal data to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested, including through the use of artificial intelligence (“AI”) / generative AI and machine learning tools that may be integrated into our Services;
• Manage our organization and its day-to-day operations;
• Communicate with individuals, including via email, text message, social media and/or telephone calls;
• Request individuals to complete surveys about our organization, organizations we partner with, and Services;
• For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message information and updates on products or services we think that you may be interested in;
• Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
• Process payment for our Services;
• Facilitate customer benefits and services, including customer support;
• Identify and analyze how individuals use our Services;
• Conduct research and analytics on our customer and user base and our Services;
• Administer, identify and facilitate potential product improvements or future product developments (including training and refining automated tools leveraging AI);
• Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
• To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations and requirements;
• To fulfill any other purpose for which you provide personal data; and
• For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

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3. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

EU, UK, and Swiss Residents: Please see the Cookies and Similar Technologies section of the Additional EU, UK, and Switzerland Privacy Disclosures for additional information about cookies and online tracking technologies’ practices and your choices regarding cookies.

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our Services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and other similar information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

We may engage in the following:

• Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our Services, for example, the site from which you came and the site to which you are going when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Sites.
• Information about how you use the Services, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat features through our Services.
• Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
• Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users (including through the use of automated tools leveraging artificial intelligence (“AI”)). You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; (g) train and refine automated tools leveraging AI; and (h) otherwise to plan for and enhance our services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Data Collection and Online Advertising below.

For more information about your choices regarding cookies, please see the Control Over Your Information section below.

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4. OUR DISCLOSURE OF PERSONAL DATA

We may disclose your personal data with:

• With Affiliates: We may disclose personal data between and among Speak and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
• Online Advertising Partners: We may also share personal data with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see the Control Over Your Information section below.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, marketing providers, customer service and communications providers, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
• Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect the rights and property of Speak, our agents, customers, and others, including to enforce our agreements, policies, and our Terms of Service;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us; to protect the health and safety of us, our customers, or any person; or as otherwise required by applicable law.
• With Your Consent or At Your Direction: We may disclose personal data about you to certain other third parties with your consent or at your direction.

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5. Third Party Data Collection and Online Advertising

EU, UK, and Swiss Residents: Please see the Cookies and Similar Technologies section of the Additional EU, UK, and Switzerland Privacy Disclosures for additional information about third party data collection and your choices regarding cookies.

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and other similar information. If permitted by your device settings, they may also collect location data through GPS, Wi-Fi or other methods. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see Online Ads of the Control Over Your Information section below, to learn how you can opt out of interest-based advertising.

We may engage in the following:

• Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, LinkedIn, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

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Third Party Partners.

We work with a variety of third-party partners to provide advertising services. For example, we may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our Services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below.

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6. DATA RETENTION

The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

• Contract. Where we are processing personal data based on a contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
• Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time in order to fulfill the legitimate interests, taking into account your fundamental interests and your rights and freedoms.
• Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
• Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
• Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

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7. CONTROL OVER YOUR INFORMATON

Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your microphone, network devices and geolocation and to integrate with your other applications.

Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.

SMS Text Messaging. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from Speak directly relating to your use of the Services, such as for account login (e.g., we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Use.

Modifying and Deleting your Information: If you have an account with us, you may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect. If you have any questions about modifying or updating any information in your account, please contact us at [email protected].

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8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

For your convenience, our Services may provide links to third-party websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal data.

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9. CHILDREN’S PRIVACY

Our services are not intended for children under the age of 15. We do not knowingly solicit or collect personal data from children under the age of 15. If we learn that any personal data has been collected inadvertently from a child under 15 we will delete the information as soon as possible. If you believe that we might have collected information from a child under 15, please contact us at [email protected].

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10. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to change this Privacy Notice from time to time at our sole discretion. We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Speak account, by updating the “Last Updated” date at the top of this Privacy Notice, and/or by placing a prominent notice on our Sites. It is your responsibility to review this Privacy Notice periodically.

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11. CONTACT US

If you have any questions regarding this Privacy Notice, or any other privacy-related questions, please send an email to [email protected].

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12. Additional U.S. State Privacy Disclosures

Last Updated: 12/7/23

For Nevada Residents: If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at [email protected].

For residents of the States of California, Colorado, Connecticut, Utah and Virginia: These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our Services, please visit our Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these U.S. Privacy Disclosures.

For the purposes of these U.S. Disclosures, personal data does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

The U.S. Disclosures set out in this section do not describe our practices when we process Customer Data as a service provider on behalf of our Customers in accordance with our contractual agreements with our customers.

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Collection and Use of Personal data

We collect various categories and types of personal data from a variety of sources and for a variety of purposes.
In the last 12 months, we may have collected the following categories of personal data:

• Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
• Personal data, as defined in the California customer records law.
• Protected Classification Characteristics, such as demographic data.
• Commercial Information, such information about products or services purchased or considered, and information about your use of the Services.
• Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our website.
• Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
• Professional/Employment Information, such as job title, department, employer or business.
• Sensory Information, such as voice recordings between you and Speak from your lessons.
• Inferences, including information generated from your use of the Services reflecting predictions about your interests and preferences.

For more information about our collection of personal data, the sources of personal data, and how we use this information, please see the How We Collect and Use Personal Data section of our Privacy Notice.

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DISCLOSURE OF PERSONAL DATA

As described in the Our Disclosure of Personal Data section of our Privacy Notice, we disclose personal data with a variety of third parties for business purposes or we may sell or share your personal data to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see the Your Privacy Rights section below).

In the previous 12 months, we have disclosed all of the categories of personal data we collect, explained above, to third parties for a business purpose. The categories of third parties to whom we sell or disclose your personal data for a business purpose may include: (i) other affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing providers; (iv) your employer / company; (v) analytics providers; and (vi) social networks.

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SALE OF PERSONAL DATA AND SHARING FOR TARGETED ADVERTISING

In the previous 12 months, we have sold or shared for targeted advertising purposes the following categories of personal data to third parties, subject to your settings and preferences and your Right to Opt Out:

• Identifiers
• Commercial Information
• Internet / Network Information
• Inferences

In addition, please see the Third-Party Data Collection and Online Advertising section of our Privacy Notice to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your personal data directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us.

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Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

• Account name and password;
• Financial account, debit card, or credit card number in combination with any required security or access code;

As described in our Privacy Notice, we use account name and password and financial information to provide certain of our products and services.

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

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Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

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Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:

• Right of access. You may have the right to obtain:
  • confirmation of whether, and where, we are processing your personal information;
  • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • information about the categories of recipients with whom we may share your personal information; and
  • a copy of the personal information we hold about you.
• Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
• Right to rectification or correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
• Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete erase your personal information.
• Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
• Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

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How to Exercise Your Privacy Rights

To Exercise Your Privacy Rights
Please submit a request by:

• Reaching out to customer support: [email protected]
• Calling us at: +1 707-397-9360.

We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and state of residency. Although we try to limit the personal data collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal data from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

To Exercise the Right to Opt Out of the Selling of Personal Data, or Sharing or Processing Personal Data for Targeted Advertising Purposes
Unless you have exercised your Right to Opt Out, we may sell personal data or share or otherwise process personal data (including Identifiers, Commercial Information, Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.

You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal data so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal data provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, via the cookie manager on the usespeak.com site.

For Non-Cookie-Based Opt-Outs: You may submit a request by calling +17073979360 or by emailing [email protected]

Authorized Agents
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at [email protected] with the subject line, “Privacy Request Appeal.”

Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.

Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.

Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.

Minors Under Age 16
We do not sell personal data of consumers we know to be less than 16 years of age unless they have opted in (“Right to Opt In”). Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal data and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

“Shine the Light” Disclosures
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal data (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal data with third parties for their own direct marketing purposes.

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NOTICE OF FINANCIAL INCENTIVES

‍We provide financial incentives to prospective customers who allow us to collect and retain personal information, such as your name, email address and phone number. These incentives may result in differences in our prices or services offered to consumers, and may include a lower price for goods and services (e.g., free trials, discounts and other promotions). For example, the financial incentives we may provide include free and open access to Speak, including a free trial of Speak’s Services, credits and promotions as part of our referral program, or prospective customers providing an email address can take advantage of certain free offerings by being automatically signed up to receive email updates from Speak. We have determined in good faith that the value of the personal information we receive from you and the relationship we establish is reasonably related to the value of the free offerings we provide.

Additional financial incentive terms may be made available to you when you sign up for the applicable offering. You may withdraw from our financial incentive programs at any time by contacting us at [email protected]. You may also opt out of receiving marketing updates from Speak by following any available opt-out instructions in the communications you receive, or by contacting us at [email protected].

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13. ADDITIONAL EU, UK AND SWITZERLAND PRIVACY DISCLOSURES‍

‍OUR APPROACH TO PRIVACY

‍Speakeasy Labs, Inc. ("Speak", "we", "our", or "us") is committed to protecting and respecting your privacy. These Additional EU, UK, and Switzerland Privacy Disclosures (“European Privacy Disclosures”) supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to users accessing the Speak Website and Application from the EU, UK or Switzerland, and sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal data") when you access and browse our website ("Website") and our mobile application (“Application”) from the EU, UK or Switzerland as well as provides additional information regarding our use of cookies and similar technologies. Please ensure that you have read and understood these additional privacy disclosures alongside our Privacy Notice before you use the Speak Website and Application.

If you have any questions about these European Privacy Disclosures or how we use your personal data, please contact us using the details at the end of these Disclosures.

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WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Speakeasy Labs, Inc., a company duly incorporated and organised under the laws of the United States of America, having its registered address at 99 Osgood Pl Floor 4, 94133 San Francisco, California is the data controller of the personal data we hold about you. This means that we determine and are responsible for how your personal data is used.

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PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE USE IT

‍We collect the categories of personal data set forth in the How We Collect and Use Personal Data section of our Privacy Notice directly when you use the Services. The table in this section 3 sets out in further detail the categories of personal data we collect about you and how we use that information when you use the Speak Site and/or Application, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

We will indicate to you if the provision of certain personal data is mandatory, for instance in connection with the provision of the Services, or optional. If you choose not to provide any personal data marked as mandatory, we may not be able to respond to your queries or provide other services to you or respond to your other requests.

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PERSONAL DATA WE COLLECT ABOUT YOU AUTOMATICALLY

‍We also automatically collect personal data indirectly about how you access and use the Speak Website and/or Application, information about the device you use to access the Speak Website and/or Application and usage information about the length of time you are using the Speak Website and/or Application. We use this information for our own analytical purposes to improve the Speak Website and/or Application and our other services. We typically collect this information through a variety of tracking technologies, including cookies and similar tracking technologies.

We collect the categories of personal data set forth in the How We Collect and Use Personal Data section of our Privacy Notice directly when you use the Speak Site and Application. The table in this section 4 sets out in further detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see Section 8 below.

We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Speak Website and/or Application and our services or developing new services and features. We may also share such anonymised and aggregated information with others.

We may link or combine the personal data we collect about you and the information we collect automatically.

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RECIPIENTS

We may share your personal data with the categories of third parties described in the Our Disclosure of Personal Data section above (as required in accordance with the uses set out in the tables above).

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MARKETING

‍From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

Our marketing messages will be sent by email, text, post, push notification, and instant messages apps such as “WhatsApp”. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails, by opting out via the link in the text message, by contacting us on the contact details provided at the end of this Privacy Notice. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

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COOKIES AND SIMILAR TECHNOLOGIES

‍The Speak Website and Application uses cookies and similar tracking technologies to distinguish you from other users of the Speak Website and Application. Cookies are pieces of code that we transfer to your device for record-keeping purposes. This helps us to provide certain functionalities of the Speak Website and Application, to monitor and improve the Speak Website and Application. We also use cookies and similar tracking technologies on the Speak Website and Application to allow our partners determine products and services that may be of interest to you and to display relevant advertising to you as you browse the Internet.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Website and Application. They include, for example, cookies that enable you to log into secure areas of our Website and Application, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors, to see how visitors move around the Speak Website and Application when they are using it and to monitor the performance of certain features on the Speak Website and Application. This helps us to improve the way the Speak Website and Application works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features.
• Functionality cookies. These are used to recognise you as you move around the Speak Website and Application and to remember information that you enter when you use the Speak Website and Application, such as when you fill in a form.
• Advertising / Performance Cookies. These cookies are used to make advertising messages about Speak that are displayed on third party websites more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and choosing which ads to display to you based on your interests.
• Third party cookies. These cookies are used by third parties on our Website for the purposes of serving relevant advertisements to you based on your interests on our Services.

The table at this paragraph 8 sets out more information about the cookies we use and how long they remain on your device.

Other than cookies that are required to operate the Website, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive by using our cookie management tool.

You also have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS.

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TRACKING TECHNOLOGIES USED IN OUR EMAILS

‍Our emails may contain tracking pixels that identify email performance information, including delivery status, if and when you have opened an email that we have sent to you, how many times you have read it, and whether you have clicked on any links in that email. We use this information on an aggregate basis to help us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

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STORING AND TRANSFERRING YOUR PERSONAL DATA

Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information.

International Transfers of your personal data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal data may be processed outside of the UK or EEA. These international transfers of your personal data will be made pursuant to appropriate safeguards, including:

• ensuring that the personal data is transferred to countries recognised by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or
• ensuring that such transfer is to a third party who uses appropriate safeguards in respect of the processing in question, including but not limited to the UK or EU standard contractual clauses, which are recognised as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable).

We may transfer your personal data to, or store your personal data in, the following countries:

We will take appropriate steps to ensure that your personal data is treated securely and in accordance with applicable law and these Privacy Disclosures regardless of where it is processed.

If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of these Privacy Disclosures.

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PROFILING

‍We may analyse personal data we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.

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YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

‍In accordance with applicable privacy laws, you have the following rights in respect of your personal data that we hold:

• Right of access. You have the right to obtain:
  • confirmation of whether, and where, we are processing your personal data;
  • information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
  • information about the categories of recipients with whom we may share your personal data; and
  • a copy of the personal data we hold about you.
• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
• Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
• Right to withdraw consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
• You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

In some jurisdictions, you have the right to stipulate instructions concerning the conservation, deletion and communication of your personal data after your death. In the absence of instructions to the contrary from the deceased, it is possible for heirs to request that data processors take into account the death of the deceased with a view to deleting or updating the deceased's account.

If you wish to exercise one of these rights, please contact us using the contact details at the end of these Privacy Disclosures.

We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.

Due to the confidential nature of data processing we may ask you to confirm your identity when exercising the above rights.

You also have the right to lodge a complaint to a data protection authority. If you are based in the European Union, information about how to contact a data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.

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NOTICE TO YOU

‍If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Speak Website and Application.

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CONTACTING US

‍Please contact [email protected] if you have any questions, comments and requests regarding these Privacy Disclosures.

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14. Additional Korea Disclosures

1. Collection and Use of Personal data

‍We collect various categories and types of personal data from a variety of sources and for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal data, and the purposes for which we use personal data, please review the How We Collect and Use Personal Data and Our Disclosure of Personal Data sections of our Privacy Notice to learn more.

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2. Data Retention

‍To learn more about our data retention practices, please review the Data Retention section of our Privacy Notice to learn more.

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3. Transfer of Personal Data Abroad and Outsourcing of Personal Data Processed

‍For information on how we may transfer your personal data and outsource our personal data processing activities, please see Annex 1 of our Privacy Notice.

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4. Rights of Users and Legal Representatives and Their Exercise Methods

‍Users can exercise the following rights related to personal data protection at any time against Speakeasy Labs, Inc.

• Request for personal data perusal
• Request for correction in case of error
• Request for deletion
• Request for processing stop

Users can request for these rights through Speakeasy Labs, Inc. by letter, phone, email, fax, etc., and Speakeasy Labs, Inc. will take immediate action.

When users request corrections or deletions of personal data errors and omissions, Speakeasy Labs, Inc. does not use or provide the personal data until the correction or deletion is completed.

Such rights can also be exercised through a legal representative or assigned agent of the user. In such cases, a power of attorney in the form of Form 11 of the Enforcement Regulations of the Personal Information Protection Act must be submitted. Users should not violate other users' personal data or their privacy by violating relevant laws and regulations concerning the protection of personal data processed by Speakeasy Labs, Inc.

Speakeasy Labs, Inc. requires users to be over 14 years old for registration and usage. Therefore, we do not collect and use the personal data of children under 14.

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5. Procedure and Method of Personal data Destruction

‍The procedure and method of destroying personal data in Speakeasy Labs, Inc. are as follows.

Destruction Procedure
When the purpose of processing personal data is achieved, we immediately destroy the personal data that has become unnecessary. When personal data should be preserved according to the provisions of relevant laws and regulations, we will separately store and manage the personal data or personal data file. At the time of destruction, we: select relevant personal data for which the cause of destruction has occurred, receive the approval of the personal data officer for it, and then destroy it.

Destruction Method
Personal data printed on paper is shredded using a shredder, and personal data stored in the form of electronic files is deleted using a technical method that makes records irreversible.

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6. Matters on the Guarantee of Personal data Safety

‍Speak implements the following measures to ensure the safety of users' personal data in order to prevent it from being lost, stolen, leaked, altered, or damaged while processing users' personal data.

• Users' personal data is encrypted, stored, and managed, is transmitted via encrypted communication (SSL), and passwords are stored and managed after one-way encryption to make decoding impossible.
• We have installed the system in an area where access from the outside is controlled to prevent leakage or damage of users' personal data or data by hacking or computer viruses.
• In preparation for damage to personal data, data is backed up regularly, and efforts are made to prevent users' personal data and data from being leaked or damaged by using the latest antivirus software. We also ensure that personal data can be securely transmitted over the network through encrypted communication (SSL).
• We are using an intrusion prevention system to control unauthorized access from the outside, and we are making efforts to equip all possible technical devices to secure the system in order to ensure system security.
• By minimizing the number of employees who handle personal data, we are reducing the risk of personal data leakage.
• Systems have been established for generating and changing passwords that can access databases and systems that process personal data, and the right of access, and continuous audits are carried out.
• Regular education on personal data protection obligations and security is conducted for employees who handle personal data.
• An internal management plan has been established and implemented to ensure the safe processing of personal data.

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7. Changes to the Personal data Processing Policy

‍In case of addition, deletion, or modification of the contents of this privacy policy, Speak will send a notification via email at least 7 days before the change.
Enforced on 12/7/23

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8. Personal Data Protection Officer and Department Contact Information

Personal Data Protection Officer
Name: Connor Nicolai Zwick
Position: CEO
Email: [email protected]

Department in Charge of Personal Data Protection
Department Name: Development Team
Person in Charge: Andrew David Hsu
Position: CTO
Email: [email protected]

Users can contact the Personal Data Protection Officer and the designated department for any inquiries, complaints handling, and damage relief related to protection of personal data arising while using Speak's services. Speak ensures prompt responses and processing for user inquiries.

If you need further consultation or reports related to personal data leakage, please contact the following organizations.

• Personal data Protection Commission (http://www.ppc.go.jp / 03-6457-9680)
• Cyber Security Bureau of the National Police Agency (http://www.npa.go.jp/cybersecurity / 03-3581-0141)
• Fair Trade Commission Consumer Consultation Room (http://www.caa.go.jp / 0570-064-370)

Appointment of Domestic Representative
Domestic Representative
Name: Speakeasy Labs Korea Co., Ltd. (Representative Lee Seung-Yeop)
Address: 9th floor, BMY Yeoksam Tower, 16, Teheran-ro 27-gil, Gangnam-gu, Seoul
Phone Number: 1668-1051
Email: [email protected]

The domestic corporate body is a marketing service company for the US corporate body, Speakeasy Labs, Inc. Necessity permitting, the appointed representative performs the duties of the information management officer, handles notification of loss, theft, leakage of personal data, and submits data to the Personal Data Protection Commission.

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15. Additional Japan Disclosures

1. Collection and Use of Personal data

‍We collect various categories and types of personal data from a variety of sources and for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal data, and the purposes for which we use personal data, please review the How We Collect and Use Personal Data and Our Disclosure of Personal Data sections of our Privacy Notice to learn more.

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2. Data Retention

‍To learn more about our data retention practices, please review the Data Retention section of our Privacy Notice to learn more.

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3. Transfer of Personal Data Abroad and Outsourcing of Personal Data Processed

‍For information on how we may transfer your personal data and outsource our personal data processing activities, please see Annex 1 of our Privacy Notice.

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4. Procedure and Method of Personal data Destruction

‍The procedure and method of destroying personal data in Speakeasy Labs, Inc. are as follows.

Destruction Procedure
When the purpose of processing personal data is achieved, we immediately destroy the personal data that has become unnecessary. When personal data should be preserved according to the provisions of relevant laws and regulations, we will separately store and manage the personal data or personal data file. At the time of destruction, we: select relevant personal data for which the cause of destruction has occurred, receive the approval of the personal data officer for it, and then destroy it.

Destruction Method
Personal data printed on paper is shredded using a shredder, and personal data stored in the form of electronic files is deleted using a technical method that makes records irreversible.

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5. Rights of the user and legal representative and how to exercise these rights

Options or methods provided by the controller to limit the use or disclosure of personal data.
To limit the use or disclosure of their personal data, the holder should send an email to the following email address: [email protected], requesting limitation of the use or disclosure involved, and requesting to be included in the internal do-not-contact list for non-promotion and marketing logic purposes.

The method of exercising access, correction, deletion, or opposition rights (“ARCO rights”).
In accordance with the law, the holder of personal data has the right to access the data and details of its procession held by the controller, and to correct it ("Correct") if it is incorrect or incomplete; To cancel ("Cancel") or oppose its use for specific purposes ("Oppose") under the terms provided by law.

The holder of personal data or his legal representative can exercise the above rights by sending an email to the following address: [email protected], indicating in it the request to exercise his ARCO rights. This request may be made in free writing, considering the elements of Article 29 of the law, or the Privacy Office will send you a format for exercising ARCO rights as a response.

The following requirements must be considered for the request to exercise ARCO rights:

• Legal identification of the holder.
• The inclusion of a specified email address to notify its response to your request.
• A clear and precise description of the personal data for which any of the aforementioned rights are requested to be exercised.
• If the right is exercised by a representative, the official identification and document proving their representative status should be provided.

If the information requested in the request is insufficient or wrong for processing, or if the necessary documents are not attached, the controller may request that it provide the necessary information and/or documents for processing in accordance with Article 96. The holder has 10 working days to respond to this request. The controller will respond to it within 20 (twenty) working days after receiving the request. The aforementioned term can be extended one same term once according to Article 32 of the law. If the request is approved, it will take effect within 15 working days.

If exercising the right of access, the necessary information or personal data can be obtained in the form of simple photocopies or electronic files (which will be sent to the email you specified in your request). The controller may refuse to access personal data, or perform a correction or cancellation, or grant the right to oppose the processing of personal data in the situations listed in Article 34 of the law.

According to the provisions of Article 26 of the Law, the controller does not need to cancel the personal data of the holder.

To clarify doubts about the procedure and requirements for exercising ARCO rights, the person responsible for providing attention is the Information Privacy Office, whose contact information is as follows: [email protected]

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6. MATTERS related to the security measures of personal data

‍Speak implements the following security measures to ensure that users' personal data is not lost, stolen, leaked, altered or damaged when processed.

• Users' personal data is encrypted, stored, and managed, and transmitted through encrypted communication (SSL), and passwords are stored and managed in a one-way encryption method that cannot be decrypted.
• A system is installed in one area, and external access is controlled to prevent the disclosure or damage of users' personal data or data due to computer viruses or network attacks.
• Data are backed up regularly to prepare for the damage to users' personal data, the latest antivirus programs are used to prevent the disclosure or damage of users' personal data or data, and encrypted communication (SSL) is used to securely transmit personal data over the network.
• Intrusion prevention systems are used to control unauthorized external access, and all possible technical equipment is prepared to ensure the security of the system.
• The number of employees processing personal data is reduced to reduce the risk of personal data leakage.
• An internal management plan is established and implemented to process personal data securely.

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7. personal data Department in charge of personal data protection

Designation and contact information of the person and department in charge of personal data protection

Person in charge of personal data protection
Name: Connor Nicolai Zwick
Position: CEO
Email: [email protected]

Department in charge of personal data protection
Department name: Development Team
Person in charge: Andrew David Hsu
Position: Technical Director
Email: [email protected]

Users can consult the person in charge of personal data protection and the department in charge about matters related to personal data protection, complaint handling, and damages resulting from the use of the Speak service. Speak will respond quickly and handle users' consultations.

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8. Designation of National Representative

‍National Representative
Name: Speakeasy Labs Korea Co., Ltd. (Representative Lee Seung Yeop)
Address: 27 Teheran-ro 16th Street BMY Yeoksam Building 9th Floor, Gangnam District, Seoul
Phone Number: 1668-1051
Email: [email protected]
The national company is a company providing market promotion services for U.S. Speakeasy Labs Inc. If necessary, the national representative will assume the obligations of notifying and reporting the personal data protection responsible, personal data loss, theft, leakage, and submitting data to the personal data protection committee, etc.

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9. Notice of changes/updates to the privacy statement

‍The controller can modify and/or update this privacy statement at any time to address legislative or judicial reforms, internal policies, or new needs; updated versions will be posted on the website Privacy Notice, and this version will always apply.

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16. Additional Mexico Disclosures

1. Collection and Use of Personal data

‍We collect various categories and types of personal data from a variety of sources and for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal data, and the purposes for which we use personal data, please review the How We Collect and Use Personal Data and Our Disclosure of Personal Data sections of our Privacy Notice to learn more.

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2. Data Retention

‍To learn more about our data retention practices, please review the Data Retention section of our Privacy Notice to learn more.

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3. Transfer of Personal Data Abroad and Outsourcing of Personal Data Processed

‍For information on how we may transfer your personal data and outsource our personal data processing activities, please see Annex 1 of our Privacy Notice.

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4. Procedure and Method of Personal data Destruction

‍The procedure and method of destroying personal data in Speakeasy Labs, Inc. are as follows.

Destruction Procedure
When the purpose of processing personal data is achieved, we immediately destroy the personal data that has become unnecessary. When personal data should be preserved according to the provisions of relevant laws and regulations, we will separately store and manage the personal data or personal data file. At the time of destruction, we: select relevant personal data for which the cause of destruction has occurred, receive the approval of the personal data officer for it, and then destroy it.

Destruction Method
Personal data printed on paper is shredded using a shredder, and personal data stored in the form of electronic files is deleted using a technical method that makes records irreversible.

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5. Identity and address of the responsible party

‍Speakeasy Labs, Inc. with address at 100 Pine St, Suite 2000, San Francisco, CA 94111.

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6. Users and legal representatives' rights and how to exercise them:

Options or means offered by the responsible party to limit the use or disclosure of personal data
To limit the use or disclosure of your personal data, the owner must send an email to the following email address: [email protected], requesting the limitation of the use or disclosure in question, where you can ask to be included in the internal exclusion lists not to be contacted for promotional and market logic purposes.

Means to exercise your rights of access, rectification, cancellation, or opposition (“ARCO Rights”)
In accordance with the Law, the owner of personal data has the right to Access ("Access") the data that the Responsible party has and to the details of its processing, as well as to Rectify them if they are inaccurate or incomplete ("Rectification"); Cancel them within the terms of the Law (“Cancellation”) or Oppose the processing for specific purposes ("Opposition").

The owner of personal data or his legal representative may exercise the rights described above through an email to the following email address: [email protected], indicating that he is requesting to exercise his ARCO rights. This request may be through free writing considering the elements of Article 29 of the Law, or the Privacy Office will send you back the form to exercise ARCO rights as a response.

For the request to exercise your ARCO rights, you should consider the following requirements:

• Official identification of the owner.
• Indicate the email to communicate the response to your request.
• Clear and precise description of the personal data concerning which it is sought to exercise any of the aforementioned rights.
• If the right is exercised by a representative, the official identification and the document proving their representation must be provided.

If the information provided in the request is insufficient or wrong to attend to it, or the necessary and indispensable documents for its attention are not accompanied, the Responsible party may request the necessary information and/or documentation according to Article 96 of the regulation. The owner will have 10 business days, to attend to this requirement. The responsible will answer your request within 20 (twenty) business days from the date of receipt of your request, this period may be extended only once for an equal period according to Article 32 of the Law. If the request is appropriate, it will be made effective within 15 business days.

In case of exercising the right of access, the medium through which you can obtain the information or personal data requested will be in simple copies or electronic documents (which will be sent to the email indicated in your request). The Responsible party may deny access to personal data, or the rectification or cancellation, or concede the opposition to the processing, in the cases established in Article 34 of the Law.

The Responsible party will not be obliged to cancel the personal data of the owner, under the cases established in Article 26 of the Law.

For clarification regarding the procedure and requirements for exercising ARCO rights, the empowered figure to provide attention is the Information Privacy Office. The contact details are as follows: [email protected]

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7. Matters related to security measures for personal data

‍Speak implements the following security measures to ensure that personal data is not lost, stolen, leaked, altered, or damaged while it is processing user's personal data.

• Users' personal data is encrypted, stored, and managed, it is transmitted through encrypted communications (SSL), and passwords are stored and managed one-way encrypted to make them indistinguishable
• A system is installed in an area where access from the outside is controlled to prevent leakage or damage of users' personal data or data by hacking or computer viruses.
• In preparation for damage to personal data, data is backed up regularly, and efforts are made to prevent users' personal data and data from being leaked or damaged by using the latest antivirus software. We also ensure that personal data can be securely transmitted over the network through encrypted communication (SSL).
• Unauthorized access from the outside is controlled using an intrusion prevention system, and we are making efforts to equip all possible technical devices to secure the system in order to ensure system security.
• By minimizing the number of employees who handle personal data, we are reducing the risk of personal data leakage.
• Systematic standards are established for password creation, changes, and access authority for the database system that stores personal data and the system that processes personal data, and continuous audits are conducted.
• Regular training and campaigns are conducted on the obligations of personal data protection and security for employees who handle personal data.
• An internal management plan has been established and implemented to ensure the safe processing of personal data.

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8. Designation and contact information of the personal data protection office and responsible department

Personal data protection officer
Name: Connor Nicolai Zwick
Position: CEO
Email: [email protected]

Department in charge of personal data protection
Department name: Development Team
Person in charge: Andrew David Hsu
Position: CTO
Email: [email protected]

Users can consult the person in charge of personal data protection and the department in charge about matters related to personal data protection, complaint handling, and damages resulting from the use of the Speak service. Speak will respond quickly and handle users' consultations.

If you need to report or consult about personal data breaches, contact the National Transparency Institute, information access, and personal data protection (INAI):

• Website: www.inai.org.mx
• Phone: 5550042400

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9. Designation of national representative

National representative
Name: Speakeasy Labs Korea Co., Ltd. (Representative Lee Seung Yeop)
Address: 9th floor, BMY Yeoksam Tower, 16 Teheran-ro 27-gil, Gangnam-gu, Seoul
Phone Number: 1668-1051
Email: [email protected]
The national corporation is a marketing service company for the American corporation Speakeasy Labs Inc. If necessary, the national representative performs functions such as notifying and reporting personal data protection officer duties, personal data loss, theft, personal data leakage and submitting materials to the Personal data Protection Commission.

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10. Notification of changes/updates to the privacy notice

‍This Privacy Notice may be modified and/or updated at any time by the Responsible party, to address legislative or jurisprudential reforms, internal policies, or new requirements, being the updated version which is published on the website and applicable at all times.

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17. Additional China Disclosures

1. Collection and Use of Personal data

‍We collect various categories and types of personal data from a variety of sources and for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal data, and the purposes for which we use personal data, please review the How We Collect and Use Personal Data and Our Disclosure of Personal Data sections of our Privacy Notice to learn more.

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2. Data Retention

‍To learn more about our data retention practices, please review the Data Retention section of our Privacy Notice to learn more.

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3. Transfer of Personal Data Abroad and Outsourcing of Personal Data Processed

‍For information on how we may transfer your personal data and outsource our personal data processing activities, please see Annex 1 of our Privacy Notice.

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4. Procedure and Method of Personal data Destruction

‍The procedure and method of destroying personal data in Speakeasy Labs, Inc. are as follows.

Destruction Procedure
When the purpose of processing personal data is achieved, we immediately destroy the personal data that has become unnecessary. When personal data should be preserved according to the provisions of relevant laws and regulations, we will separately store and manage the personal data or personal data file. At the time of destruction, we: select relevant personal data for which the cause of destruction has occurred, receive the approval of the personal data officer for it, and then destroy it.

Destruction Method
Personal data printed on paper is shredded using a shredder, and personal data stored in the form of electronic files is deleted using a technical method that makes records irreversible.

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5. Rights of the user and legal representative and how to exercise these rights

Options or methods provided by the controller to limit the use or disclosure of personal data.
To limit the use or disclosure of their personal data, the holder should send an email to the following email address: [email protected], requesting limitation of the use or disclosure involved, and requesting to be included in the internal do-not-contact list for non-promotion and marketing logic purposes.

The method of exercising access, correction, deletion, or opposition rights (“ARCO rights”).
In accordance with the law, the holder of personal data has the right to access the data and details of its procession held by the controller, and to correct it ("Correct") if it is incorrect or incomplete; To cancel ("Cancel") or oppose its use for specific purposes ("Oppose") under the terms provided by law.

The holder of personal data or his legal representative can exercise the above rights by sending an email to the following address: [email protected], indicating in it the request to exercise his ARCO rights. This request may be made in free writing, considering the elements of Article 29 of the law, or the Privacy Office will send you a format for exercising ARCO rights as a response.

The following requirements must be considered for the request to exercise ARCO rights:

• Legal identification of the holder.
• The inclusion of a specified email address to notify its response to your request.
• A clear and precise description of the personal data for which any of the aforementioned rights are requested to be exercised.
• If the right is exercised by a representative, the official identification and document proving their representative status should be provided.

If the information requested in the request is insufficient or wrong for processing, or if the necessary documents are not attached, the controller may request that it provide the necessary information and/or documents for processing in accordance with Article 96. The holder has 10 working days to respond to this request. The controller will respond to it within 20 (twenty) working days after receiving the request. The aforementioned term can be extended one same term once according to Article 32 of the law. If the request is approved, it will take effect within 15 working days.

If exercising the right of access, the necessary information or personal data can be obtained in the form of simple photocopies or electronic files (which will be sent to the email you specified in your request). The controller may refuse to access personal data, or perform a correction or cancellation, or grant the right to oppose the processing of personal data in the situations listed in Article 34 of the law.

According to the provisions of Article 26 of the Law, the controller does not need to cancel the personal data of the holder.

To clarify doubts about the procedure and requirements for exercising ARCO rights, the person responsible for providing attention is the Information Privacy Office, whose contact information is as follows: [email protected]

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6. MATTERS related to the security measures of personal data

‍Speak implements the following security measures to ensure that users' personal data is not lost, stolen, leaked, altered or damaged when processed.

• Users' personal data is encrypted, stored, and managed, and transmitted through encrypted communication (SSL), and passwords are stored and managed in a one-way encryption method that cannot be decrypted.
• A system is installed in one area, and external access is controlled to prevent the disclosure or damage of users' personal data or data due to computer viruses or network attacks.
• Data are backed up regularly to prepare for the damage to users' personal data, the latest antivirus programs are used to prevent the disclosure or damage of users' personal data or data, and encrypted communication (SSL) is used to securely transmit personal data over the network.
• Intrusion prevention systems are used to control unauthorized external access, and all possible technical equipment is prepared to ensure the security of the system.
• The number of employees processing personal data is reduced to reduce the risk of personal data leakage.
• An internal management plan is established and implemented to process personal data securely.

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7. personal data Department in charge of personal data protection

‍Designation and contact information of the person and department in charge of personal data protection

Person in charge of personal data protection
Name: Connor Nicolai Zwick
Position: CEO
Email: [email protected]

Department in charge of personal data protection
Department name: Development Team
Person in charge: Andrew David Hsu
Position: Technical Director
Email: [email protected]

Users can consult the person in charge of personal data protection and the department in charge about matters related to personal data protection, complaint handling, and damages resulting from the use of the Speak service. Speak will respond quickly and handle users' consultations.

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8. Designation of National Representative

‍National Representative
Name: Speakeasy Labs Korea Co., Ltd. (Representative Lee Seung Yeop)
Address: 27 Teheran-ro 16th Street BMY Yeoksam Building 9th Floor, Gangnam District, Seoul
Phone Number: 1668-1051
Email: [email protected]
The national company is a company providing market promotion services for U.S. Speakeasy Labs Inc. If necessary, the national representative will assume the obligations of notifying and reporting the personal data protection responsible, personal data loss, theft, leakage, and submitting data to the personal data protection committee, etc.

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9. Notice of changes/updates to the privacy statement

‍The controller can modify and/or update this privacy statement at any time to address legislative or judicial reforms, internal policies, or new needs; updated versions will be posted on the website Privacy Notice, and this version will always apply.

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18. Annex I

The following disclosures apply to residents of China, Korea, Japan, and Mexico.

1. Outsourcing of Personal Information Processing

‍Speakeasy Labs, Inc. outsources personal information processing tasks as follows in order to smooth out personal information-related tasks. We will disclose this information through the privacy policy, without hesitation, if the content of the delegated tasks or the trustee changes.

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2. Personal Information Processing Outsourcing and Overseas Transfer

‍Speakeasy Labs Inc. (hereinafter referred to as “Speakeasy”) does not provide the user’s personal information to overseas businesses. However, Speakeasy outsources data storage and service operation tasks to overseas companies as follows.

For users in Korea, such overseas transfers are made pursuant to Article 28-8(1)(3) of the Personal Information Protection Act, which permits overseas outsourcing for the purpose of contract performance. If you are a user in Korea and do not wish for your personal data to be transferred overseas, please note that you may not be able to use the service. You may withdraw your membership through our website or mobile app, or by contacting our customer support center.