NLPEARL PRIVACY POLICY
Last Updated: May 30th, 2024
This privacy policy (“Privacy Policy”) governs how we, Neural Wave Ltd. (together, “NLPearl” “we”, “our” or “us”) use, collect, and store Personal Data we collect or receive
from or about you (“you”) such as in the following use cases:
When you make use of, or interact with, our website,
Website : https://nlpearl.ai/
When you request a product demo
When you contact us (e.g. customer support, need help, submit a
request)
When you apply for a position
When you make use of our services
When we use the Personal Data of our customers (e.g. contact
details)
When we use the Personal Data of our service providers (e.g.
contact details)
When you interact with us on our social media profiles
Please read this Privacy Policy carefully, so you can understand our
practices and your rights in relation to personal data. “Personal Data >” or “Personal Information” means any information that can be used, alone or together with
other data, to uniquely identify any living human being and any
information deemed as Personally Identifiable Information by privacy
laws. Please note that this is a master privacy policy and some of its
provisions only apply to individuals in certain jurisdictions. For
example, the legal basis in the table below is only relevant to
GDPR-protected individuals. Important note: Nothing in this Privacy Policy is intended to limit in any way your
statutory right, including your rights to a remedy or means of
enforcement.
Table of contents:
What information we collect, why we collect it, and how it is
used
How we protect and retain your Personal Data
How we share your Personal Data
Additional information regarding transfers of Personal Data
Your privacy rights
Use by children
Interaction with third party products
Analytic tools
Specific provisions applicable under California privacy law
Contact us
This Privacy Policy can be updated from time to time and, therefore, we
ask you to check back periodically for the latest version of this Privacy
Policy. If we implement significant changes to the use of your
Personal Data in a manner different from that stated at the time of
collection, we will notify you by posting a notice on our Website or by
other means.
WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS
USED
Specific Personal Data we collect
Why is the Personal Data collected and for what purposes?
Legal basis (GDPR only, if applicable)
Consequences of not providing the Personal Data
Third Parties with whom we share your Personal Data
When you make use of, or interact with, our Website
When you Contact us </font >(e.g. customer support, need help, submit a demo request)
Full name
Email address
Phone number
Company name
Company website
Your business activity
Your need for Pearl
Your leads/ client base
Your sales/ support scripts
Your product / services information
Any other information you provide us with
To process and answer questions
To provide support
To customize a demo of Pearl for you
For our internal insights
To customize Pearl for your use
To provide the service
Processing is necessary for the performance of a contract to
which the data subject is party or in order to take steps at the
request of the data subject prior to entering into a
contract
Legitimate interest (e.g. respond to a query sent by you)
Cannot process and answer questions.
Cannot provide support.
Cannot provide a customized demo of Pearl.
Cannot provide internal insights.
Cannot customize Pearl for your use
Cannot provide the Services.
We share this information with our service providers and
partners, including, our marketing partners (as needed to provide
the services).
When you apply for a position
Full name
Email address
Phone number
CV
To process your request for a position
Processing is necessary for the performance of a contract to
which the data subject is party or in order to take steps at
the request of the data subject prior to entering into a
contract
Legitimate interest (e.g. respond to a query sent by you)
Legitimate interest (e.g. respond to a query sent by
you)
Cannot process your request for a position
We share this information as needed to process your job
application.
When you make use of our services as an individual
Email address
Full name
Phone number
Payment information
Your messages
Google calendar information
Any other information you choose to share with us
To provide our services (including, to take notes, to schedule
appointments, modify them, delete them or do any action required
by you)
To perform the applicable agreement
To communicate with you
The processing is necessary for a contract we have with you.
Consent (where applicable and required by applicable
law).
Cannot provide our services (including, to take notes, to
schedule appointments, modify them, delete them or do any action
required by you)
Cannot perform the agreement
Cannot communicate with you
We share this information with our service providers and
partners, including, our text-to-speech artificial intelligence
tool (as needed to provide the services).
When we use the Personal Data of our customers (e.g. contact
details)
Email address
Full name
Phone number
Company name
Job title
Payment information
Your messages
Google calendar information
Any other information you choose to share with us
To provide our services (including, to take notes, to schedule
appointments, modify them, delete them or do any action required
by you)
To perform the applicable agreement
To communicate with our customers
The processing is necessary for a contract we have with you.
Legitimate interest (the processing is necessary for a
contract that we have with your employer).
Consent (where applicable and required by applicable
law).
Cannot provide our services (including, to take notes, to
schedule appointments, modify them, delete them or do any action
required by you)
Cannot perform the agreement
Cannot communicate with you
We share this information with our service providers and
partners, including, our invoicing providers (as needed to
provide the services).
When we use the Personal Data of our service providers (e.g.
contact details)
Email address
Full name
Phone number
Company
Job title
Any other information you choose to share with us
To provide our services
To perform the applicable agreement
To communicate with our service providers, suppliers and
developers
The processing is necessary for a contract we have with you.
Legitimate interest (the processing is necessary for a
contract that we have with your employer).
Cannot provide our services
Cannot perform the applicable agreement
Cannot communicate with our service providers, suppliers and
developers
We share this information with our payment processing providers
and as otherwise needed to manage our relationship with you.
When you interact with us on our social media profiles (e.g., LinkedIn, YouTube, Twitter)
Full name
Company name
Phone number
Email address
Any other type of Personal Data the you decide to share with
us
To reply and/or respond to your request or question
To establish a business connection
To send marketing materials
Depending on the context, our legal basis for collecting this
information is:
legitimate interest (e.g., to establish a business
connection with you)
pre-contractual discussions
consent
Cannot reply and/or respond to your request or question
Cannot establish a business connection
cannot send marketing materials
We share this information with our marketing providers in some
cases where needed for the purposes the information was
collected for.
Finally, please note that some of the abovementioned Personal Data will
be used for detecting, taking steps to prevent, and prosecution of fraud
or other illegal activity, to identify and repair errors, to conduct
audits, and for security purposes. Personal Data may also be used to
comply with applicable laws, with investigations performed by the
relevant authorities, law enforcement purposes, and/or to exercise or
defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal
Data and further use it for internal and external purposes, including,
without limitation, to improve the services and for research purposes.
“Anonymous Information” means information which does not
enable identification of an individual user, such as aggregated
information about the use of our services. We may use Anonymous
Information and/or disclose it to third parties without restrictions (for
example, in order to improve our services and enhance your experience with
them).
HOW WE PROTECT AND RETAIN YOUR INFORMATION
Security. We have implemented appropriate technical,
organizational and security measures designed to
protect your Personal Data. However, please note that
we cannot guarantee that the information will not be
compromised as a result of unauthorized penetration to
our servers. As the security of information depends in
part on the security of the computer, device or
network you use to communicate with us and the
security you use to protect your user IDs and
passwords, please make sure to take appropriate
measures to protect this information.
Retention of your Personal Data. Your Personal Data will be stored until we delete
the record and we proactively delete it or you send a
valid deletion request, please note that in some
circumstances we may store your Personal Data for
longer periods of time, for example (i) where we are
required to do so in accordance with legal,
regulatory, tax or accounting requirements, or
(ii) for us to have an accurate record of your
dealings with us in the event of any complaints or
challenges, or (iii) if we reasonably believe there is
a prospect of litigation relating to your Personal
Data or dealings.
HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal
Data as follows:
With our service providers, business partners with whom we
jointly offer products or services (including, without limitation,
third party components which are implemented into our products and
services). We may also share Personal Data with our affiliated
companies.
To the extent necessary, with regulators, courts or competent
authorities, to comply with applicable laws, regulations and rules
(including, without limitation, federal, state or local laws), and
requests of law enforcement, regulatory and other governmental
agencies or if required to do so by court order;
If, in the future, we sell or transfer, or we consider selling or
transferring, some or all of our business, shares or assets to a
third party, we will disclose your Personal Data to such third
party (whether actual or potential) in connection with the
foregoing events;
In the event that we are acquired by, or merged with, a third
party entity, or in the event of bankruptcy or a comparable event,
we reserve the right to transfer, disclose or assign your Personal
Data in connection with the foregoing events, including, in
connection with, or during negotiations of, any merger, sale of
company assets, consolidation or restructuring, financing, or
acquisition of all or a portion of our business by or to another
company; and/or
Where you have provided your consent to us sharing or
transferring your Personal Data (e.g., where you provide
us with marketing consents or opt-in to optional
additional services or functionality).
Sharing with AI models: we also share information with our
speech-to-speech AI tools:
We share the following personal information with AI models:
contacts, emails, content of your emails, your calendar event
dates, and anything else you choose to include into our
product.
How the Personal Data is being used: We share this data in order to provide you with our services.
Categories of AI models we share your Personal Data
with: our speech to speech tools.
If you want to receive the list of the current recipients of your
Personal Data, please make your request by contacting us to info@nlpearl.ai
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
Internal transfers: Transfers within the NLPearl group will be covered by
an internal processing agreement entered into by members
of the NLPearl group (an intra-group data processing
agreement) which contractually obliged each member to
ensure that Personal Data receives an adequate and
consistent level of protection wherever it is
transferred to.
External transfers: Where we transfer your Personal Data outside of
EU/EEA (for example to third parties who provide us with
services), we will generally obtain contractual
commitments from them to protect your Personal Data.
Transfer mechanisms
When NLPearl engages transfers of personal information, it relies on
Adequacy Decisions adopted by the European Commission based on Article 45
of the GDPR (for example, when we access Personal Data from Israel),
Standard Contractual Clauses laid down by the European Commission, the
recipients certification to the EU-US Data Privacy Framework and/or the UK
Extension. or any other approved transfer mechanism. NLPearl continually
monitors the circumstances surrounding such transfers to ensure that these
maintain, in practice, a level of protection that is essentially
equivalent to the level of protection guaranteed by the GDPR.
YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
Rights: The following rights (which may be subject to
certain exemptions or derogations) shall apply to
certain individuals (some of which only apply to
individuals protected by the GDPR):
You have a right to access Personal Data held about you. Your right
of access may normally be exercised free of charge, however we reserve
the right to charge an appropriate administrative fee where permitted
by applicable law;
You have the right to request that we rectify any Personal Data we
hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your Personal
Data (e.g. from our records). Please note that there may be
circumstances in which we are required to retain your Personal Data,
for example for the establishment, exercise or defense of legal
claims;
You have the right to object, to or to request restriction, of the
processing;
You have the right to data portability. This means that you may have
the right to receive your Personal Data in a structured, commonly used
and machine-readable format, and that you have the right to transmit
that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note
that there may be circumstances in which we are entitled to continue
processing your data, in particular if the processing is required to
meet our legal and regulatory obligations. Also, please note that the
withdrawal of consent shall not affect the lawfulness of processing
based on consent before its withdrawal;
You also have a right to request certain details of the basis on
which your Personal Data is transferred outside the European
Economic Area, but data transfer agreements and/or other details may
need to be partially redacted for reasons of commercial
confidentiality;
You have a right to lodge a complaint with your local data protection
supervisory authority (i.e., your place of habitual residence,
place or work or place of alleged infringement) at any time or before
the relevant institutions in your place of residence. We ask that you
please attempt to resolve any issues with us before you contact your
local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at
info@nlpearl.ai. You may use an authorized agent to submit a request
on your behalf if you provide the authorized agent
written permission signed by you. To protect your
privacy, we may take steps to verify your identity
before fulfilling your request. Subject to legal and
other permissible considerations, we will make every
reasonable effort to honor your request promptly in
accordance with applicable law or inform you if we
require further information in order to fulfil your
request. When processing your request, we may ask you
for additional information to confirm or verify your
identity and for security purposes, before processing
and/or honoring your request. We reserve the right to
charge a fee where permitted by law, for instance if
your request is manifestly unfounded or excessive. In
the event that your request would adversely affect the
rights and freedoms of others (for example, would impact
the duty of confidentiality we owe to others) or if we
are legally entitled to deal with your request in a
different way than initial requested, we will address
your request to the maximum extent possible, all in
accordance with applicable law.
USE BY CHILDREN. We do not offer our products or services for use by
children and, therefore, we do not knowingly collect
Personal Data from, and/or about children under the age of
eighteen (18). If you are under the age of eighteen (18),
do not provide any Personal Data to us without involvement
of a parent or a guardian. For the purposes of the GDPR,
we do not intend to offer information or services directly to children. In the event that we become aware that you provide
Personal Data in violation of applicable privacy laws, we
reserve the right to delete it. If you believe that we
might have any such information, please contact us at
info@nlpearl.ai
INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites,
mobile software applications and products or services that
are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy
practices or the content of such Third Party Services.
Please be aware that Third Party Services can collect
Personal Data from you. Accordingly, we encourage you to
read the terms and conditions and privacy policies of each
Third Party Service.
ANALYTIC TOOLS
Google Analytics
The Website uses a tool called “Google Analytics” to collect information about use of the Website.
Google Analytics collects information such as how often
users visit this Website, what pages they visit when they
do so, and what other websites they used prior to coming
to this Website. We use the information we get from Google
Analytics to maintain and improve the Website and our
products. We do not combine the information collected
through the use of Google Analytics with Personal
Information we collect. Google’s ability to use and
share information collected by Google Analytics about your
visits to this Website is restricted by the Google
Analytics Terms of Service, available at
https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and
processes data specifically in connection with Google
Analytics at
http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google
Analytics by downloading and installing the Google
Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/
We reserve the right to remove or add new analytic tools.
CONTACT US
If you have any questions, concerns or complaints
regarding our compliance with this notice and the data
protection laws, or if you wish to exercise your rights,
we encourage you to first contact us at
