Effective Date: February 26, 2022
Coqui.ai Corp. ("Coqui," "Controller," "we," or "us") respects your privacy and is committed to protecting it through compliance with this policy. This policy describes the information we may collect when you use our website, coqui.ai (the "Website"), or our products or services, or when you provide information to us, and our practices for handling that information.
This policy does not apply to information collected by any third party, including through any third-party mobile application or website or any content (including advertising) that may link to or be accessible from the Website.
1. Name and Contact Details of the Controller
Responsible for the processing of your data is:
Telephone: +49 (0)716 2476 3160
2. Collection and Processing of Personal Data, Purposes of Processing, Relevant Legal Basis and Storage Period
2.1. Informative use of our Website
We may collect any personal information that you voluntarily provide to us, either on our Website or in any other communications with us. Voice or audio data: For example, if you use the "Speaking in Tongues" demo on our Website, we will collect your voice or whatever audio you provide into that function. We will retain that voice or audio only as long as necessary to satisfy the initial purpose for which you provided that voice or audio. By using that function, you consent to our collection and use of your voice and other audio provided for that purpose and to our disclosure of that information to any service provider we use to fulfill that purpose.
During the visit on our Website, i.e. if you do not register or otherwise transfer information to us, we only collect data that your browser transmits to our server (so-called server log files), however, processing only occurs to the technically necessary extent. The following information is collected:
- IP address of the requesting device
- date and time of access
- name and URL of the accessed file
- website from which the access comes (referrer URL)
- the browser you use and, if applicable, the operating system of your device as well as the name of the access provider.
The legal basis for the collection of this data is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest in collecting this data results from the following purposes:
- ensuring optimal use of our Website,
- ensuring a trouble free connection,
- evaluation of system security and stability.
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for making the website available to you, this is the case when the respective session has ended. In the case of storage of data in log files, the data is deleted after 6 weeks at the latest.
If you give us your explicit consent, we will send you information about our services and offers by email. For this purpose, we process your email address. When you register for our newsletter, we use the double opt-in procedure. This means that after you have registered with your email address, we will send you an email to the specified email address in which we ask you to confirm that you actually wish to receive the newsletter.
The legal basis for sending our information is Art. 6 para. 1 lit. a) GDPR. Your consent to receive our newsletter is voluntary. You can withdraw it at any time with effect for the future. You can withdraw by clicking on the "Unsubscribe" link in the respective email newsletter or by sending an informal message to the contact details mentioned in section 1.
2.3. Contacting us by email
When you contact us by email, the data you provide (e.g. your email address, name and telephone number, if applicable) will be processed by us in order to answer your questions.
We use your data exclusively for the purpose of answering your inquiry. The legal basis for this is Art. 6 para. 1 lit. f) GDPR (legitimate interest of processing inquiries and other requests). Your data will be deleted after processing your request, unless further storage is necessary to properly respond to your inquiry.
2.4. Optimization of Website
The setting of the aforementioned cookies is necessary for the proper functioning of the Website. We therefore have a legitimate interest in their use. The legal basis for the related data processing is therefore Art. 6 para. 1 lit. f) GDPR.
On the other hand, we use - in each case on the basis of Art. 6 para. 1 lit. a) GDPR - analytical cookies to statistically record the use of the Website and to optimize our offer, as well as marketing cookies to display information and personalized content tailored specifically to you. These cookies are only set if you have expressly consented to them. You can declare your withdrawal at any time by adjusting the cookie settings in your browser.
You can also configure your browser so that no cookies are stored on your device or a notice always appears before a new cookie is set. However, the complete deactivation of cookies can cause that you cannot use all the functions of our Website.
The storage period of cookies depends on their purpose and is therefore variable. In any case, cookies are automatically deleted after a defined period of time. Below you will find more detailed information on the analytical cookies and marketing cookies used on our Website.
(b) Google Analytics
We use Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountainview, CA 94043, USA ("Google"), to design our services and Website and to optimize them on an ongoing basis.
In this context, pseudonymised usage profiles are created and cookies are used. The information generated by the cookie about your use of our Website, such as browser type/version, operating system used, referrer URL (the previously visited page), host name of the accessing computer (IP address), time of server request, is transmitted to a Google server in the USA and stored there. The transfer of data to the USA is varied out on the basis of the European Standard Contractual Clauses. The information is used to evaluate the use of the Website, to compile reports on advertising activities and to provide other services associated with the use of the Website and the Internet for the purposes of market research and the design of the Website. Your IP address is anonymised so that an assignment is not possible (so-called IP masking).
Data processing in connection with Google Analytics is based on your explicit consent pursuant to Art. 6 para. 1 lit. a) GDPR.
You may reject the setting of cookies by selecting the appropriate settings in your browser. However, we would like to point out that in this case you may not be able to use all functions of the Website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information on data protection with regard to Google Analytics, please visit the website of Google.
2.5 Storage period
If no other storage periods are specified in the preceding sections, we store and process your personal data as long as is necessary for the aforementioned purposes. If your data is not needed any longer, we will delete the data except when we are obliged by applicable law to not to delete the data.
3. Third-party privacy policies and other tracking technologies
We do not control the privacy practices of third parties. For example, we do not control whether or how third parties may use your information or may use tracking technologies with respect to your information. If you have any questions about a third party’s privacy practices or about an advertisement or other targeted content or how any third party may collect or use your information, you should contact the responsible third party directly.
4. Recipients or categories of recipients of your personal data
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- Email newsletter providers
- IT service providers
For sending the emails, we use the third-party provider MailChimp, a newsletter platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. Email addresses of our newsletter recipients are stored on MailChimp's servers in the USA. MailChimp uses this information to send and evaluate the newsletters on our behalf. For this reason, we have concluded a data processing agreement with MailChimp.
The data processing agreement contains a reference to the European Standard Contractual Clauses, which provide a guarantee for the transfer of your personal data to the USA. Furthermore, according to its own information, MailChimp may use the data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and presentation of the newsletters or for commercial purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to contact them or to pass the data on to third parties.
You can read the privacy statement of MailChimp at https://mailchimp.com/legal/privacy/.
- Our employees, contractors, service providers, software providers, professional advisers, insurers, agents, and other third parties we use to support our business.
- Any party to fulfill the purpose for which you provided the information.
- Any party to fulfill any other purpose disclosed by us when you provided the information.
- Any party with your consent.
- Any party to comply with or respond to any court order, subpoena, civil investigative demand, legal process, law, regulation, or any government or regulatory request.
- Any party to enforce or perform any contracts, agreements, or obligations, including, for example, for billing and collection purposes.
- A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
- Any party if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Coqui, our employees, our customers, or others. This includes, without limitation, exchanging information with other parties for the purpose of fraud protection and credit risk reduction.
5. Data Security
We have implemented safeguards designed to secure your information, including personal information, from accidental loss and unauthorized access, use, alteration, and disclosure.
Unfortunately, no website, software, system, or database is completely secure or "hacker proof." Although we try to protect your information, we cannot guarantee the security of your information. Any transmission of information, including personal information, is at your own risk. You are also responsible for taking reasonable steps to protect your information, including personal information, such as, for example, the password to your email account, against unauthorized disclosure or misuse.
6. Your California Privacy Rights
While it is not our practice to disclose your personal information to third parties for their direct marketing purposes, California Civil Code Section § 1798.83 may permit certain users of our Website who are California residents to request certain information regarding our disclosures, if any, of personal information to third parties for their direct marketing purposes. If you are a California resident with an established business relationship with us and would like to request information from us about whether we have shared your information to third parties for their direct marketing purposes during the preceding calendar year, you may direct the request to us in writing at the mailing or email address stated below (see Contact Information, below).
California law may require us to inform you how we respond to do-not-track (DNT) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party websites or online services. Because there is no industry or legal standard for recognizing or honoring DNT signals or other such mechanisms, we don't respond to them at this time.
7. Nevada Consumers
Nevada law gives Nevada consumers the right to request that a company that operates a website for commercial purposes not sell their personal information for monetary consideration to another party for the other party to license or sell the information to additional parties. This right may apply even if personal information is not currently being sold.
We do not sell personal information. However, if you are a Nevada consumer who wishes to exercise a right to request us not to sell your personal information, please direct your request to the email address identified above. We reserve the right to take reasonable measures to verify the authenticity of the request and the identity of the consumer making the request.
8. Reviewing and Requesting Changes to Your Information
If you would like to review and request any changes to your personal information on file with us, you may direct the request to us in writing at the address or email address stated above. We may not accommodate such a request if we believe compliance with the request would violate any law, regulation, contract, or other legal obligation or cause the information to be incorrect. We reserve the right to deny, in our sole discretion and for any reason, any request to review, change, delete, or otherwise access any information in our records. However, if your information is subject to the European Union’s General Data Protection Regulation, you may have additional rights, as set forth in the "Your GDPR Rights" section below.
9. Your GDPR Rights
If we are subject to the requirements of the European Union’s General Data Protection Regulation with respect to your personal data, you are entitled to the following rights:
9.1. Right to Information pursuant to Art. 15 GDPR
You have the right to receive information from us about whether and which data we process about you. This includes information on how long and for what purpose we process the data, the source of the data and the recipients or categories of recipients to whom we pass on the data. We can also provide you with a copy of this data.
9.2. Right to Rectification pursuant to Art. 16 GDPR
You have the right to request that we rectify information about you that is not or no longer accurate without delay. In addition, you can request that we complete your incomplete personal data. If required by law, we will also inform third parties of this rectification if we have disclosed your personal data to them.
9.3. Right to Deletion pursuant to Art. 17 GDPR
You have the right to request that we delete your personal data without delay if one of the following cases applies:
- your data is no longer necessary for the purposes for which it was collected or otherwise processed or the purpose has been achieved;
- you withdraw your consent and there is no other legal basis for the processing;
- you object to the processing and there are no prevailing legitimate grounds for the processing; in the case of the use of personal data for direct marketing, a mere objection by you to the processing is sufficient;
- your personal data has been processed unlawfully;
- the deletion of your personal data is necessary to comply with a legal obligation under European Union law or the law of a member state to which we are subject.
Your right to deletion may be restricted on the basis of statutory provisions. This includes in particular the restrictions listed in Article 17 GDPR and Section 35 BDSG.
9.4. Right to the Restriction of Processing pursuant to Art. 18 GDPR
You have the right to request us to restrict the processing of your personal data if one of the following reasons apply:
- you dispute the correctness of your personal data for a period of time that allows us to verify the correctness of the personal data;
- the processing is unlawful and you object to the deletion of the personal data and request instead the restriction of the use of your personal data;
- we no longer need your personal data for the purposes of processing; however, you need them for the assertion, exercise or defence of legal claims, or
- you have objected to the processing as long as it has not yet been determined whether our legitimate reasons outweigh yours.
- If you have obtained a restriction on processing under the above list, we will inform you before the restriction is withdrawn.
9.5. Right to Data Portability pursuant to Art. 20 GDPR
You have the right to obtain personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit this data to others. The exercise of this right does not affect your right to deletion.
9.6. Right to Object pursuant to Art. 21 GDPR
According to Art. 21 GDPR, you have in particular the right to object to the processing of your data at any time on the grounds of your particular situation, if we base this processing on legitimate interests on Art. 6 para. 1 lit. f) GDPR. If you object, we will no longer process your personal data, except in two cases:
- we can prove that there are compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms; or
- the processing serves the assertion, exertion or defence of legal claims.
In particular, if we process your personal data for direct marketing, you have the right to object at any time to the processing of your data for the purpose of such marketing. If you object to the processing of your data for direct marketing purposes, we will no longer use your personal data for this purpose.
9.7. Right of Withdrawal of Consent pursuant to Art. 7 GDPR
You can withdraw your consent given to us at any time with effect for the future. This withdrawal can be made in the form of an informal notification to the above-mentioned contact addresses. If you withdraw your consent, the legitimacy of the data processing carried out up to that point will not be affected.
9.8. Right to file a Complaint with the Supervisory Authority
If you believe that the processing of your data by us violates applicable data protection law, you have the right to file a complaint with one of the competent supervisory authorities. The supervisory authority responsible for us is:
Berlin Commissioner for Data Security and Freedom of Information
("Berliner Beauftragte für Datenschutz und Informationsfreiheit")
("Berliner Beauftragte für Datenschutz und Informationsfreiheit")
Telephone: +49 (0)30 1388 9-0
Fax: +49 (0)30 2155 050
Fax: +49 (0)30 2155 050
10. Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our Website or provide any information about yourself to us, including without limitation your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us in writing at the mailing or email address stated above.