Privacy Policy

Last Updated: April, 2023

This privacy policy (“Privacy Policy”) governs how we, AI21 Labs Ltd. (“A21” “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:

1. When you make use of, access to, our website: www.humanornot.ai (“Website”)
2. When you play with our game “Human or Not?” (“Game”)
3. When we store your Game score 

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” 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. 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. 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 appropriate means as decided by AI21.

Table of contents:      

(i) When you make use of, access to, interact or play with our Website:

• When you interact with our Website, we and our partners use cookies and other tracking technologies such as cookies, pixel tags, web beacons to recognize you as a user, customize your experiences, including to perform analytics. To learn how to opt-out of this kind of tracking technology, visit About Ads, Your Online Choices and AboutCookies.org.
  

(ii) When you play with our Game:

• Personal Data we collect – IP Address, the information that you input to the chat (to the extent considered Personal Data) and your usage pattern of the Game.
• Why is the Personal Data collected and for what purposes? To allow you to play with the Game, to allow you to chat with other participants in the context of the game, to answer your questions, to understand your actions in the Game, to customize your experience with the Game, and to show you statistics about your performance in the Game.
• Legal basis (GDPR only) – Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract and/or legitimate interest.
• Consequences of not providing the Personal Data – Cannot allow you to play with the Game, cannot allow you to chat with other participants in the context of the game, cannot provide you support, and cannot customize your experience with the Game.
  

(iii) When we store your Game score:

• Personal Data we collect – Email address (optional) and any other content or Personal Data you decide to provide/supply with us. We will collect your email address to send you a magic link for you to store your score in the Game. 
• Why is the Personal Data collected and for what purposes? To allow you to register and store your score of the Game and to send you updates, technical support and other Game-related communications.
• Legal basis (GDPR only) – Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract and/or legitimate interest.
• Consequences of not providing the Personal Data - Cannot allow you to register and store your score of the Game.
  

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 Game, our services and products (including through the use of artificial intelligence), to create and publish benchmarks and/or to share the Anonymous Information with academic and research entities and organizations. “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, with academic institution and universities) for research purposes, in order to improve our services and enhance your experience and/or to develop new product features and improve existing offerings. 

1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the Personal Data will not be compromised as a result of unauthorized penetration to our servers. As the security of Personal Data 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 Personal Data.
2. Retention of your Personal Data. Your Personal Data will be stored until we delete our records, and we proactively delete it, or if 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, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. 

In addition to the recipients described above, we may share your Personal Data as follows:

1. We may also share Personal Data with our affiliated companies and business partners (including, without limitation, academic institution and universities). 
2. We may use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation: 

• With cloud service providers for hosting purposes;
• With websites and web content creation platforms in order to help us manage our Game and the Website; and
• With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy (including, survey tools).     

3. 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;
4. 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;
5. 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.

1. We store the Personal Data with the following storing companies: Google Cloud with the servers located in the US.
2. In order to run our business and provide our Game and services to you, we transfer Personal Data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your Personal Data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your Personal Data by implementing at least one of the following safeguards:

• making sure the destination country has been deemed to provide an adequate level of protection for Personal Data; and/or
• by executing implement data onward transfer instruments such as data processing and protection agreements.

1. 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 specific laws):

• 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; and/or
• 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.

2. You can exercise your rights by contacting us at info@ai21.com. 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 Personal Data in order to fulfil your request. When processing your request, we may ask you for additional Personal Data 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. 

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 18. If you are under the age of 18, do not provide any Personal Data to us without the involvement of a parent or a guardian. 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@ai21.com.

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 information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

1. Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website  and the Game. Google Analytics collects information such as how often users visit the Website, what pages they visit when they do so, and what other websites they used prior to coming to the Website  and the Game. We use the information we get from Google Analytics to maintain and improve the Website and the Game and our products. We do not combine the information collected through the use of Google Analytics with Personal Data we collect. Google’s ability to use and share information collected by Google Analytics about your visits to the 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 https://policies.google.com/privacy. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://policies.google.com/technologies/partner-sites. 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/.
2. Amplitude Analytics
3. Google BigQuery
4. We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

• Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.

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 info@ai21.com.

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