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Privacy Policy

Updated as of January 17, 2024

I.  Introduction

Akin Labs, Inc. and its subsidiary Akin Community Pvt. Ltd. (collectively “D3x”, “Company,” or “we,” “us” and “our”) values your privacy and is committed to maintaining your trust.  We provide this Privacy Policy and the Additional Disclosures at Exhibit A attached hereto (collectively, the “Privacy Policy”) to inform you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from visitors to and/or users of the Company’s website located at https://d3x.ai and https://akin.community (collectively, the "Website"), and in the provision of its online services. Specifically, the Company maintains a Platform (“Platform”) that allows users to interact with each other and provides artificial intelligence (“AI”) services to offer automated guest communications and bookings for hospitality operators, through its Website.

II.  Collection, Use, Processing, and Sharing of Personal Information

Legitimate Business Interest in Personal Information.  Our use of your Personal Information is based on the legitimate business grounds that:

 

  • The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account – for example, in order to enable access to our Website on your device or charge you for our Services; 

  • The use is necessary for compliance with a legal obligation; 

  • The use is necessary in order to protect your vital interests or those of another person or entity; 

  • We have a legitimate interest in using your information – for example, to provide and update our Website or Services, to improve our Website or Services so that we can offer you an even better user experience, to safeguard our Website or Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; and/or

  • You have given us your consent.

 

Collection of Personal Information.  The Company may collect the following information that could be used to identify you (“Personal Information”): 

 

  • User Account Information: Information provided by you to create an account with us, including your name, email address, postal address, phone number, account credentials, payment card information, and transaction history. 

  • User Content: Information collected by the Company in your use of our Website or Services, including but not limited to user input, feedback, and document uploads.

  • Company Communications: Information provided by you as part of your communications with the Company, including your name and contact information. 

  • User Interaction Data: Information automatically received by us when you use our Website or Services, including device information, browser log data, user engagement and analytics data which may contain Personal Information such as your internet protocol address. 

  • Third Party Information: We also may obtain your Personal Information from third parties, such as third parties with whom we affiliate in providing the Company’s services.  If you provide the Company with Personal Information about third parties, you warrant to the Company that any Personal Information that you provide to the Company about any third party individuals was obtained by you with full consent, that you have the legal authority to provide us with such information, and that the individual has not communicated to you that they wish to opt out of receiving communications from the Company or having the Company collect information about them.

Use of Personal Information.  The following information applies to anyone who shares with us their or a third-party’s Personal Information. We may use, process and/or share Personal Information:

  • To respond to your inquiries and your requests regarding our Website or Services.

  • To send you information regarding our services and changes to our terms, conditions, and policies. 

  • To complete your account registration, process your payments, and communicate with you regarding your purchase of our Services.

  • To send you marketing communication and newsletters about our Services.

  • To personalize your experience on our Website.

  • To inform you and allow you to participate in our Company’s promotions.  

  • To facilitate social sharing functionality.

  • To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.

  • In connection with our business purposes, as described above, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc. 

  • To comply with our legal obligations (e.g,. in response to a subpoena), investigate claims, or comply with a government request.

  • To protect the privacy, safety, or property of you, the Company, and/or third parties, investigate fraud.  

  • To allow us to pursue available remedies or limit the damages that we may sustain.

  • To enforce our user agreements, including this Privacy Policy and our Terms of Service.

 

Use of Aggregated or De-Identified Personal Data.  The Company may also collect and aggregate or de-identify Personal Information to improve and analyze our Services, and may share such aggregated de-identified information statistics with third parties, publish such aggregated information, or make such aggregated information generally available to improve our Services via machine learning models.  Company maintains such aggregate information in a de-identified form and will not attempt to re-identify your Personal Information unless required to do so by law.

 

We Will Not Use And/Or Share Your Personal Information:

 

  • With anyone except for our Company’s authorized service providers, business affiliates, and business partners, including but not limited to Fly.io, AWS, Google, Microsoft, OpenAI, Crunchy Data, Temporal, Twilio, Meta, Freshdesk, Stripe, Apple Pay, Google Pay, Coinbase Commerce, Paypal, FullStory, Matomo, Sentry and/or Hubspot, and strictly for business purposes; or unless we specifically inform you, and give you an opportunity to opt out of sharing your Personal Information.  

  • To run interest-based advertising campaigns that collect Personal Information such as email addresses, telephone numbers, and credit card numbers.

  • To use or associate Personal Information with remarketing lists, cookies, data feeds, or other anonymous identifiers.

  • To use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page.

  • To share any Personal Information with third party companies through our remarketing tag or any product data feeds which might be associated with our ads.

III.  Collection and Use of Other Information

Aggregated Personally Non-Identifiable Information:  We may collect personally non-identifiable information, including but not limited to demographic data, age, education level, profession, geographic location or gender, from you at the time of registration on our Website or when you choose to use our Website or Services. This information is not, by itself, sufficient to identify or contact you.  The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company.  The Company may use such information and pool it with other information to track data related to growing the business, such as the total number of visitors to our Website and the domain names of our visitors' internet service providers.  

 

The Company may analyze your Personal Information provided through the Website or in connection with rendering the Services, in aggregate form.  This aggregate information does not identify you personally.  We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes.  We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes. 

 

Passively Collected Information.  Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies.  This information includes but is not limited to, for example browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services.  This information cannot presently be used to specifically identify you. 

 

Customer Credit Card Information.   The Company may use a Third-Party Payment Processor, as that term is defined in the incorporated Terms of Service, to process payments on its Website for Services rendered.  These Third-Party Payment Processors use and process your payment information in accordance with their respective privacy policies, the links to which can be found below: 

The Company does not store or save your payment information, other than your zip code and country, which we require for billing and to comply with tax and other government regulations. By purchasing the Services of Company, you agree to the above-linked privacy policies of our Third-Party Payment Processors. 

Website Tracking. We may, either directly or through third party companies and individuals we engage to provide services to us, also:

  • Track your use of our Website and the Services for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.

  • Track your use of the Website and the Services to enable you to use and access the Services and pay for your activities on the Website and through the Services.  

  • Track your behavior on our own Website and use of the Services to market and advertise our services to you on our Website platform and third party websites.  You may opt out of receiving advertisements by visiting the Network Advertising Initiative (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (http://www.aboutads.info/choices/).  Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Services, generally.  The advertising will simply not be targeted or specific to your interests.

Tracking Technologies on our Website. The Company may use the foregoing technologies to track your activity on our Website:

Cookies.  When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices.  Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience.  Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites.  Some features on this site will not function if you do not allow cookies.  We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.  

 

We may use both session ID cookies and persistent cookies.  A session ID cookie expires when you close your browser.  A persistent cookie remains on your hard drive for an extended period of time.  Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. 

 

Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.

 

Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

 

Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable the companies to serve up advertisements on other sites that are relevant to your interests. 

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  

If you reject cookies, you may still use our site, but some features on the site will not function properly.

Log Files.  A Log File is a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software.  Log file information is automatically reported by your browser each time you access the Website or use our Services.  Along with cookies and web beacons, log files help provide additional functionality to the Website and Services and help us analyze Website and Services usage more accurately.  We and our third party tracking-utility partners may use log files on our Service to gather automatically gather and store information including, but not limited to, internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for business purposes.  You can find further information regarding our use of third party tracking, including use of cookies and load files, in Section XI below. 
 

Embedded Scripts.   An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
 

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

IV.  Retention, Modification, and Erasure of Personal Information

Data Retention and Erasure.  We will retain your Personal Information for as long as needed to provide the applicable Services, specifically (1) Personal Information collected for purposes related to the performance of a contract between Company and the user shall be retained until such contract has been fully performed; and (2) Personal Information collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this Privacy Policy or by contacting the Company.

 

If, at any time after agreeing to this Privacy Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain Personal Information; (3) wish to object to the processing of your Personal Information; or (4) wish for us to erase a copy of your Personal Information, please make a request to the Company at privacy@d3x.ai.

 

If you request erasure of your data, we may retain some of your Personal Information only for legitimate business interests, such as fraud detection, prevention, and enhancing the safety of our Website or Services in an aggregated and non-personally identifiable form as set forth herein, and/or to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.

 

Data Accuracy and Corrections to Personal Information. To request an update or correction regarding your Personal Information, please make a request to the Company at privacy@d3x.ai. Company will issue a response to you within 30 days regarding compliance as it relates to your Personal Information. 

 

Please note that Company’s Services include machine learning, so some predictive or algorithmic-based outputs may not be factually accurate. In some instances, it may not be technologically practicable to correct the inaccuracies involving a user’s Personal Information. In such instances, you may request that we remove your Personal Information from as set forth in this Privacy Policy. 

 

Please see our FAQ page for information regarding how we collect data to inform and train our algorithmic models.

 

Our Response to Your Requests.  If you make any requests regarding your Personal Information, we will not charge you for compliance with the request.  The Company will respond and comply within 30 days.  The Company reserves the right to refuse or charge for requests that are manifestly unfounded or excessive.  If we refuse your request, we will tell you why we are refusing your request.  You have the right to complain to the relevant supervisory authority and to a legal remedy, but you must do so within one month of our refusal. 

 

Data Controller.  With the exception of processing payments for which the applicable Third-Party Payment Processor, as that term is defined in the Company’s Terms of Service, is the Payments Data Controller; the Company is the “data controller,” as defined under the GDPR, or the legal entity which determines the purposes and means of the processing of Personal Information of the customers of the Company and visitors to its Website.  The Company is responsible for collecting your consent, managing consent-revoking, enabling right to access, etc.  If you wish to revoke consent for us to store, use, or share your Personal Information, you may contact us at privacy@d3x.ai

 

Data Processor.  The Company is the “data processor," as defined under the GDPR, or the legal entity which processes, as this term is defined here in footnote 1, your Personal Information.  The Company has not retained any third-party service provider to process your Personal Information.  Any processing of Personal Information shall be done solely by the Company.  The Company maintains records of any processing activities it performs, and is able to show how the Company complies with the data protection principles under the GDPR.  It has effective policies and procedures in place.  If you have questions regarding the processing of your Personal Data, you may contact us at privacy@d3x.ai

 

Data Protection Officer.  The Company is not formally required to designate a Data Protection Officer (“DPO”) because it is not: (1) a public authority; (2) an organization that carries out regular and systematic monitoring of individuals on a large scale; or (3) an organization that carries out large scale processing of special categories of data, such as health information or information about criminal convictions. You may contact Company CEO, Jason Noronha at privacy@d3x.ai who is responsible for data protection compliance and can answer any questions you may have about your Personal Information. 


Breach.  The Company has reasonable internal policies and procedures in place to effectively detect, report, and investigate a data breach.  The GDPR defines a Personal Information breach as “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information.”  Pursuant to the GDPR, the Company will notify you of a Personal Information breach where the Personal Information breaches are likely to present a risk to data subjects to data protection authorities (“DPAs”) without undue delay, and within 72 hours if feasible, after becoming aware of the breach; and communicate high-risk breaches to affected data subjects without undue delay.  In the unfortunate event of breach, the Company shall provide you with: (i) contact details of the DPO or other contact person for the Company, (ii) a description of the nature of the breach, (iii) likely consequences of the breach, (iv) measures the Company has taken or proposes to take to address the breach, and (v) advice on steps data subjects can take to protect themselves.

V.  General Data Protection Regulations

The Company’s processing of the Personal Information, such as the name, address, email address, or telephone number of an EU data subject (hereinafter, “Personal Information” or “Personal Data”) that is voluntarily supplied by the individual, or supplied by an authorized third party, shall always be in line with the General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to the Company.  

 

By means of this Privacy Policy, our Company would like to inform any EU data subjects of the nature, scope, and purpose of the Personal Information we collect, use and process, as defined herein.  Specifically, if you are an EU data subject visiting our Website or using our Services, you are hereby informed, by means of this section of our Privacy Policy, of the rights to which you are entitled, and the recourse you may seek if you have any questions regarding the collection, use, and processing of Personal Information by the Company. You may email us with requests at privacy@d3x.ai.
 

Your Privacy Rights under the GDPR.   The GDPR includes the following rights for you, as an EU data subject, if you provide Personal Information to the Company in connection with accessing the Services or visiting our Website:

  • The right to be informed about how we store, use, or share your data;

  • The right to access your data;

  • The right to rectify your data;

  • The right to have us erase your data;

  • The right to prevent us from processing your data;

  • The right to request copies of your data from us in a commonly-used and machine-readable format, free of charge, for the purposes of transfer to a third party, where technically feasible;

  • The right to object to use or sharing of your data; and

  • The right not to be subject to automated decision-making, including profiling

 

Note: Data Protection Impact Assessment (DPIA).   The Company is not required to undergo a DPIA because the Company’s data processing is not likely to result in a high risk to data subjects, such as in cases where: (1) new technology is being deployed; (2) profiling operations may significantly affect individuals; or (3) processing is on a large scale and involves special categories of data.  If you have any questions regarding DPIA compliance by the Company, you may contact us at privacy@d3x.ai

 

Complaints.  Without prejudice to any other administrative or judicial remedy, every EU data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement of the data subject considers that the processing of Personal Information relating to him or her infringes this Regulation.

 

III. Use, Processing, and Sharing of Personal Information  

 

Collection of Personal Information

The Company collects the following information that could be used to identify you (“Personal Information”): 

 

  • User Account Information: Information provided by you to create an account with us, including your name, email address, postal address, phone number, account credentials, payment card information, and transaction history. 

  • User Content: Information collected by the Company in your use of our Website or Services, including but not limited to user input, feedback, and document uploads.

  • Company Communications: Information provided by you as part of your communications with the Company, including your name and contact information.

  • User Interaction Data: Information automatically received by us when you use our Website or Services, including your internet protocol address, device information, and location information collected as part of your browser log data and user engagement and analytics data. 

  • Third Party Information: We may obtain your Personal Information from third parties, such as third parties with whom we affiliate in providing the Company’s services.  If you provide the Company with Personal Information about third parties, you warrant to the Company that any Personal Information that you provide to the Company about any third party individuals was obtained by you with full consent, that you have the legal authority to provide us with such information, and that the individual has not communicated to you that they wish to opt out of receiving communications from the Company or having the Company collect information about him or her.

 

Use of Personal Information

The following information applies to anyone who shares with us his, her, or a third-party’s Personal Information.  We may use, process, and/or share Personal Information:

 

  • To respond to your inquiries and your requests regarding our Website or Services.

  • To send you information regarding our services and changes to our terms, conditions, and policies. 

  • To complete your account registration, process your payments, and communicate with you regarding your purchase of our Services.

  • To send you marketing communication and newsletters about our Services.

  • To personalize your experience on our Website or in relation to our Services.

  • To inform you and allow you to participate in our Company’s promotions.  

  • To facilitate social sharing functionality.

  • To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.

  • In connection with our business purposes, as described above, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc. 

  • To comply with our legal obligations (e.g., in response to a subpoena), investigate claims, or comply with a government request.

  • To protect the privacy, safety, or property of you, the Company, and/or third parties, investigate fraud.  

  • To allow us to pursue available remedies or limit the damages that we may sustain.

  • To enforce our user agreements, including this Privacy Policy and our Terms of Service.

 

We will not use and/or share your Personal Information:

 

  • With anyone except for our Company’s authorized service providers, business affiliates, and business partners, including but not limited to the entities mentioned above and herein, and strictly for business purposes; or unless we specifically inform you, and give you an opportunity to opt out of sharing your Personal Information.  

  • To run interest-based advertising campaigns that collect Personal Information such as email addresses, telephone numbers, and credit card numbers.

  • To use or associate Personal Information with remarketing lists, cookies, data feeds, or other anonymous identifiers.

  • To use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page.

  • To share any Personal Information with third party companies through our remarketing tag or any product data feeds which might be associated with our ads.

 

Protected Health Information (“PHI”) and HIPAA. The Federal Health Insurance Portability and Accountability Act (“HIPAA”) provides specific protections for the privacy and security of Protected Health Information (“PHI”) and restricts how PHI is used and disclosed by Covered Entities and its Business Associates.

 

COMPANY IS NOT A COVERED ENTITY OR A BUSINESS ASSOCIATE AND DOES NOT INTEND TO OPERATE AS A COVERED ENTITY OR BUSINESS ASSOCIATE AS SUCH TERMS ARE DEFINED UNDER HIPAA. ANY PERSONAL INFORMATION THAT YOU PROVIDE TO THE COMPANY IS NOT CONSIDERED PHI UNDER HIPAA.

 

The Company's Website and Services are not intended to be used to communicate protected health information in accordance with our Terms of Service. Should you decide to share information regarding your past, present, or future physical or mental health conditions, we cannot guarantee that your information sent through this Website or transmitted to us via any other platforms we use to offer you Services will be kept secure and protected.  If you share any such information through the Website or via any other avenue we use to provide you with Services, you herein agree that you do so at your own risk.

VI.  Children

The Children’s Online Privacy Protection Act of 1998 (COPPA) and its accompanying FTC regulation protects the privacy of American children aged 13 and under, who are using the Internet.  The GDPR sets the age at which an EU child can give their own consent in order to process their Personal Data at 16 years of age.  

 

The Website and our related Services are not intended for anyone under 16, and we do not knowingly collect information from anyone under the age of 16.  Anyone aged 16 or under should not submit any Personal Information without the permission of their parents or guardians.  Parents or guardians may, on behalf of their children, submit their children’s Personal Information.  By using the Website and our related Services, you are representing that you are at least 16 years old and that you have the relevant legal authority to submit your Personal Information or that of a third-party minor, to the Company or on the Company’s Website.

VII.  Links to Other Websites

Our Website may display links to other third-party websites such as Google, Meta, and/or Cloudbeds.  This Privacy Policy does not address, and we are not responsible for the privacy, information or other practices of any third parties.  This Privacy Policy applies only to this Website and the Company’s Services.  It does not apply to any third-party sites, and the inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

 

We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as or any other app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, when you share your information, including any Personal Information, with those organizations through or in connection with use of the Website or Company’s Services.

VIII.  Security

We maintain reasonable and appropriate, although not infallible, security precautions.  However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts.  You should note that in using the Website, app, and/or our related Services, your information will travel through third-party infrastructures which are not under our control. We are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.  Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to privacy@d3x.ai.

IX.  Do Not Track 

Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites you visit.  The Company’s Website does not respond to "Do Not Track" signals or other mechanisms from a visitor's browser.  If, in the future, we create a program or protocol to respond to such web browser "Do Not Track" signals, we will inform you of the details of that protocol in this Privacy Policy.  To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

XI.  Analytics

FullStory. The Company may collect certain information automatically relating its user’s Website activity (for example, page clicks, scrolls, and transitions), which occur while visiting our Website and share the information with FullStory to analyze and improve the user experience. The information collected by FullStory may include any or all of the following: Website usage details, device information, location information, user contact information, profile and subscription information, survey information, biographical information, and user content. 
 

You herein agree to the FullStory Privacy Policy (https://www.fullstory.com/legal/privacy-policy/) as references in its Terms of Service (https://www.fullstory.com/legal/terms-and-conditions/) both of which are incorporated herein by reference. The operator of FullStory is FullStory,1745 Peachtree Street NE, Atlanta, GA 30312. 
 

Please note, Fullstory allows optout and you may do so by visiting https://www.fullstory.com/optout/.
 

Matomo Analytics. The Company uses Matomo Analytics, an open source web analytics platform used by Company to measure, collect, analyze, and report visitor data for purposes of understanding and optimizing Company’s Website.  The information collected by Matomo may include any or all of the following: user IP address, cookies, user ID, order ID, date and time of the request, page title, page URL, referrer URL page, screen resolution used.

You herein agree to the Matomo Analytics Privacy Policy (https://matomo.org/privacy/), which is incorporated herein by reference.  The data privacy representative of Matomo Analytics is ePrivacy Holding GmbH, Große Bleichen 21, 20354 Hamburg, Germany.

XII.  Open ID Providers/OAuth Login Flows

You may log into your account on our Website and/or access our Services using sign-in services such as Google or any comparable open ID provider (“OpenID Provider”).  These services will authenticate your identity and provide you the option to share certain Personal Information with us, such as your name and email address to pre-populate our registration form.  OpenID Provider services, like Google, give you the option to post information about your activities on this Website to your Google profile page to share with others within your network if you so choose.
 

A subset of supported AI Agent channels will use OAuth login flows whereby Users grant us access to their business accounts so the Company can respond on their behalf.  Currently, these include Google (for email) and Meta (for Facebook Pages, Instagram, Whatsapp) only.

XIII.  Public Forum on our Website

Our Website offers publicly accessible message boards, blogs, and community forums to which you may contribute.  You may submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), such as on profiles, blogs and message boards, and choose to share the User Content via email or on through your accounts in various social media platforms.  We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed), and may or may not attribute it to you.  
 

Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that the Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.  Our promises regarding handling of your Personal Information under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the Website.
 

To request removal of your Personal Information from our blog or community forum, contact us at privacy@d3x.ai.  In some cases, we may not be able to remove your Personal Information, especially if it was already re-posted by another user.  If this is the case, we will let you know if we are unable to do so and why in response to your request.

XIV.  Referrals

If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and inform them of our Services.  We will only store your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at privacy@d3x.ai to request that we remove this information from our database at any time.

 

If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

XV.  Testimonials and Reviews

If you submit testimonials or reviews of the Services directly on our Website or otherwise to us via email, you authorize any Personal Information you include with your testimonial or review to be displayed on the Website or our social media channels.  We may also partner with third-party service providers to collect and display testimonials and review content on our Website or the Company’s social media channels.  If you provide our third-party service providers with your Personal Information in the process of submitting your testimonials and reviews, the content and Personal Information collected by a third party will be posted on our Website and/or social media channels, absent your express instruction not to do so.  If you want your testimonial or review removed from our Website or systems at any time, please contact us at privacy@d3x.ai.

XVI.  Changes

This Privacy Policy may be updated from time to time for any reason, at our sole discretion.  We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website, and emailing you a copy of the revised Privacy Policy or a link to it.  You are advised to consult our Website regularly for any changes.

XVII.  Incorporation into Terms of Service

By using or accessing the Website, App, or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.  If you have an existing separate contract with the Company and any terms differ or deviate from this Privacy Policy or the Company’s Terms of Service, the provisions in this Privacy Policy and the Company’s Terms of Service shall govern.

XVIII.  Opt-Out Policy

If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at privacy@d3x.ai.

XIX.  Contact Us 

If you have any questions or concerns relating to our use of your Personal Information, please email privacy@d3x.ai. Additionally, you may reach us by postal mail at:

 

Akin Labs, Inc.

440 N Barranca Ave #2546 

Covina, CA, 91723.

EXHIBIT A

Additional Disclosures

AI Model Response Accuracy

AI models are not 100% accurate. There is always the possibility of inaccurate information or a response that the recipient might find objectionable.  You herein agree that if you use our Services or Website, that the Company shall not be liable for any damages resulting from or related to the provision of inaccurate information, or a response that the recipient might find objectionable.
 

Sensitive Information

We are not responsible for any loss, misuse, or fraud related to provision of any data or Personal Information that the Users of our Company’s Website or Services willingly share with us through the AI Agent channels that we support (e.g. Facebook Pages, Instagram, Whatsapp, Email, etc.), pursuant to the Company’s Limitation of Liability clauses articulated in the Company’s Terms of Service, included fully by reference herein.  
 

Third Party Provider Considerations
 

Google add-on

We developed a Google add-on to draft email responses to customer support email requests. As part of our using the Company’s Google Workspace platform, Google requires the Company to have a Limited Use requirement fully displayed in our Privacy Policy.  We are providing that disclosure here.
 

Limited Use

This Privacy Policy and use of Google user data obtained via Restricted and Sensitive Scopes does in fact comply with the Limited Use Policy, since our Website is requesting access to sensitive information.  Our Privacy Policy clearly calls out herein that the Website and Services comply with the Google API Services User Data Policy, including the Limited Use requirements.  This is located via link here: Google API Services User Data PolicyIf you use our Website or Services, you herein agree to the terms linked above and herein.
 

Google Chrome Extension

We developed a Chrome Extension designed to assist hospitality businesses in generating AI draft replies for their guests on various online travel agency (OTA) platform support channels. By incorporating the Google Chrome Extension platform into our services, we are required to adhere to certain stipulations regarding the use of user data. The details of these requirements are disclosed below.
 

Limited Use

Our Privacy Policy and the processing of user data through the Chrome Extension align with Google's expectations for "Limited Use." When interacting with and leveraging our Chrome Extension, user data such as booking reference numbers, guest names, and guest contact details are accessed. This access is solely for the purpose of facilitating and enhancing the service offered to our customers and is not used for any other unrelated objectives.

Our commitment is to ensure that the data processed through the Chrome Extension complies with Google's Chrome Web Store Developer Program Policies. This is located via link here: Chrome Web Store Policy Requirements. If you use our Website or Services, you herein agree to the terms linked above and herein.
 

Microsoft Office add-in

We developed a Microsoft Office add-in called “akin AI agent” to draft email responses to customer support email requests. As part of our using the Office add-in platform, Microsoft requires the Company to explicitly mention that it is covered by our Privacy Policy.  We are providing that disclosure here.

1 Process. “Processing” covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
2 Authorized service providers are companies that perform certain services including, but not limited to, cloud services, fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analyses, supporting the functionality of the Services, and supporting contests, sweepstakes, surveys and other features we offer, on our behalf.  These service providers may have access to your Personal Information, but to the extent necessary to perform or fulfill their business purpose.  We do not permit them to share or use any of your Personal Information for any other purpose.
3 Affiliate businesses are those businesses with whom we may affiliate to sell our products or Services.  We may share information we collect, including Personal Information, with affiliated businesses in accordance with the terms of this Privacy Policy.  Sharing such information with our affiliates enables us to provide you with information about a variety of products and Services that might interest you.  We instruct all affiliated businesses to comply with applicable privacy and security laws and, at a minimum, in any commercial email they send to you, to give you the opportunity to choose not to receive such email messages in the future.
Business partners are typically merchants offering the products, services, promotions, contests and/or sweepstakes in connection with or somehow related to our own products and Services, but also may include Company’s professional service providers, including but not limited to Company’s lawyers, accountants, insurers, claims adjusters, and/or finance partners.  We will not share your Personal Information with business partners unless you choose to participate in their offer or program.  When you choose to engage in a particular offer or program, you authorize us to share your email address and other Personal Information with the relevant business partner.
5 Processing.   “Processing” covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.  See Article 4(2) and (6) of the GDPR.

6 Personal Information.   “Personal Information” may include, but is not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc.  The Company does not collect any Personal Information from visitors to its website that is not voluntarily provided.  The Company only collects your Personal Information if you register for an account with the Company’s Website, when you use the Company’s Services, and when you send the Company communications in connection with your use of the Services.
7 Third Party Personal Information.   We may obtain your Personal Information from third parties, such as third parties with whom we affiliate in providing the Company’s services.  If you provide the Company with Personal Information about third parties, you warrant to the Company that any Personal Information that you provide to the Company about any third party individuals was obtained by you with full consent, that you have the legal authority to provide us with such information, and that the individual has not communicated to you that they wish to opt out of receiving communications from the Company or having the Company collect information about him or her.
8 Personal Information. “Personal Information” may include, but is not limited to, information relating to a natural person who can be identified (directly or indirectly) by reference to a particular identifier, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

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