Last updated: June 14, 2021
This policy applies to all products built and maintained by The AI Responsibility Lab PBC ("AIRL"), including AirOS.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for a AIRL product, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data may be tied to your IP address and user account if applicable and you are signed into our Services.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write AIRL with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested: We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. No AIRL human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring.
To help you troubleshoot or squash a software bug, with your permission: If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses: Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
When required under applicable law.
The AI Responsibility Lab PBC is a US company and all data infrastructure are located in the US.
If US law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside the US approaches AIRL with a request, our default stance is to refuse unless the US government compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
Similarly, if AIRL receives a request to preserve data, we refuse unless compelled by either the US Federal Stored Communications Act, 18 U.S.C. Section 2703(f) or a properly served US subpoena for civil matters. In both of these situations, we have to comply. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so. We do not share preserved data unless absolutely required under the Stored Communications Act or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so directly by contacting us at firstname.lastname@example.org.
If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed such as billing addresses and tax exemption information.
Finally, if The AI Responsibility Lab PBC is acquired by or merged with another company.
Your rights with respect to your information
At AIRL, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. AIRL recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
Right to Correction. You have the right to request correction of your personal information.
Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using AIRL services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at email@example.com. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.
Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
Location of site and data
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
When transferring personal data from the EU
The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement. That is why since GDPR went into effect, AIRL has offered a data processing addendum and voluntarily participated in the EU-US Privacy Shield Framework as well as the Swiss-US Privacy Shield Framework.
We have incorporated a Data Processing Addendum to our Terms of Service that is in effect when the GDPR applies to your use of AIRL Services to process Customer Data as defined in the DPA. You can find the DPA linked within clause 7 of the Uptime, Security and Privacy section. The DPA includes the European Commission’s Standard Contractual Clauses (both controller-processor and controller-controller) to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed. The DPA is extensive so to aid our customers, we have provided both a summary of what they mean and how AIRL, LLC upholds our responsibilities in our Privacy Regulation Reference. If you prefer to have an executed copy of the Data Processing Addendum, you may sign a copy online. Regardless of whether you execute or not, we protect and secure your data to the high standards set out in the addendum.
There are also a few ad-hoc cases where EU personal data may be transferred to the US related to The AI Responsibility Lab PBC operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions or buys swag on our company shop. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.
EU-US and Swiss-US Privacy Shield policy
The EU-US Privacy Shield is an agreement between certain European jurisdictions and the United States that up until July 16, 2020, allowed for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary. The Swiss-US Privacy Shield is a similar program for data transferred to the US from Switzerland that was in effect until September 8, 2020.
We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States
AIRL is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.
The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:
Individuals have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Individuals also have the right to request erasure of personal information that has been processed in violation of the principles. Individuals wishing to exercise these rights may do so by by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org.
We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
We do not sell personal data nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-out or opt-in choice as appropriate.
We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
We commit to resolving all complaints
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our company blog.