PRIVACY POLICY

Valid from: 15.06.2023

This privacy policy (‘Privacy Policy’) explains how information about you is collected, used, and shared by Paladin Max, Inc. and its affiliated companies (‘innochat,’ the ‘Company,’ ‘we,’ ‘our,’ or ‘us’). This Privacy Policy applies to information we collect when you use our websites https://www.innoChat.ch (the ‘Website’) and other online products and services (collectively, the ‘Services’).

By downloading, accessing, using and/or interacting with our services, you expressly consent to and agree to the collection, use and disclosure of the information you provide in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Use at https://www.innoChat.ch/terms (our ‘Terms of Use’) and is subject to the provisions of the Terms of Use. Capitalised terms used in this Privacy Policy but not defined herein shall have the meanings assigned to them in our Terms of Use. If you have concerns about providing information to us or the use of that information as described in this Privacy Policy, you should not use our Services.

Modifications

As we are constantly looking for new and innovative ways to help you achieve your goals in relation to the use of our services, this privacy policy may change over time. Therefore, please review it regularly. The effective date above indicates when this Privacy Policy was last changed. If we change the terms of this Privacy Policy, we will notify you via push notification and/or by posting a notice on our website thirty (30) days prior to the changes taking effect. If we are required by applicable data protection laws to provide you with more detailed information about such changes or to obtain your consent, we will do so. You can see when this policy was last updated by checking the ‘last updated’ date at the top of this policy. Any revised privacy policy supersedes all previous privacy policies.

Contact

If you have any questions about this privacy policy, please contact us by email at hello@innochat.ch or write to us at:

Paladin Max, Inc.

712 Bancroft Road #925

Walnut Creek, CA 94598

E-Mail: hello@innochat.ch

Table of contents

  • Personal data we collect
  • How we collect data
  • How and why we use your personal data
  • Ways in which you may share your personal data through our services
  • Where your personal data is stored
  • How long your personal data will be stored
  • Your rights regarding your personal data
  • How your imported data is used
  • How you can exercise your rights
  • Your control options
  • consents
  • How we respond to ‘Do Not Track’ signals
  • Our policies regarding children
  • Submission of a complaint
  • Further
  1. Personal data we collect

    We may collect and use the following personal data that identifies, relates to, describes, can be reasonably associated with, or can be reasonably linked, directly or indirectly, to a particular consumer, household, or natural person:

    Categories of personal data
    Specific species collected

    identifiers

    Real name, username, internet protocol address, email address, account password

    Internet or other similar network activity

    Information about a consumer's interaction with a website, application, or advertisement

    Professional or employment-related information

    Current activity

    Conclusions derived from personal data

    Profiles that reflect a person's behavior and attitudes

    User-generated profiles and content

    user profiles, avatars, or text information.

    device information

    Unique device identifiers and country of access

    Software information

    Operating system and version

    user information

    User browser type, timestamp, time zone setting and location, browser plug-in types and versions, user content data, user activity, user interactions, and pages visited

    cookies

    Small data files that are stored on your hard drive or in your device's memory to help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about cookies and how to disable them, see Section 9 (Your Control Options) below.

    Web Beacons

    Also known as “tracking pixels,” are electronic images that can be used in our services or emails to deliver cookies, count visits, understand campaign usage and effectiveness, and determine whether an email has been opened and acted upon.

    Different tracking technologies

    These include local shared objects (also known as “Flash cookies”) and HTML5 local storage, which are stored on your device in a similar way to cookies and can be used to store certain information about your activities and preferences across different services and sessions.

    Publicly available information

    User information from websites such as LinkedIn, Google Scholar, or arXiv

  2. How we collect data

    We collect information that you provide to us voluntarily, such as when you create an account, manage your user profile, use interactive features of our Services, request customer support, or otherwise communicate with us. In some cases, information may be collected automatically when you interact with our website or services. We only collect personal information that is necessary to provide our products and services, in accordance with the principles of lawfulness, necessity, and good faith.

    In particular, we have collected the following categories of personal information in the last twelve (12) months:

    Categories of personal data
    How we collect data

    identifiers

    Direct from you When a user signs in with Google Automatically from you when you request support

    Internet or other similar network activity

    Automatically from you when you use our services

    Professional or employment-related information

    Straight from you

    Conclusions derived from personal data

    Automatically from you when you use our services

    User-generated profiles and content

    Straight from you

    device information

    Automatically from you when you use our services or request support from our third parties

    Software information

    Automatically from you when you use our services
    From our third party providers

    user information

    Automatically from you when you use our services
    From our third party providers

    cookies

    Automatically from you when you use our services. For more information about cookies and how to disable them, see Section 9 (Your Control Options) below.

    web beacons

    Automatically from you when you use our services

    Different tracking technologies

    Automatically from you when you use our services. Information on how to disable or delete information contained in Flash cookies can be found here.

    Publicly available information

    Straight from you
    From publicly available sources

  3. How and why we use your personal information

    We use your personal data exclusively for the purposes set out in this privacy statement. Before we use your personal information beyond the purposes set out in this privacy statement, we will provide you with timely and appropriate notice and:

    • Get your consent

    • Explain why we want to use your personal information

    We only use your personal information when we have a valid reason to do so, such as:

    • When you have given us your consent

    • To fulfill our contract with you or to take action at your request prior to the conclusion of the contract, including:

      • To provide you with our services

      • To update and improve our customer data

    • For our legitimate interests or those of a third party, including:

      • To prevent and detect fraud

      • To prevent unauthorized access to and modification of systems

      • To update and improve our records

      • To ensure compliance with our business policies (such as security and Internet usage)

      • Ensuring safe work practices, personnel management and evaluation

      • For operational reasons, such as improving efficiency, training, and quality control

      • For statistical analyses that help us run our business, such as in terms of customer base, product range, or other efficiency measures

      • To carry out external audits and quality controls

    • To comply with our legal and regulatory obligations, including:

      • Update and improve our records

      • Submission of declarations required by law

      • Carrying out external audits and quality controls

    As we continuously improve our products and services, we may introduce optimization features from time to time that may expand or change the scope, purpose, and/or method of collecting and using your personal information. Should optimization features expand or change the scope, purpose, and/or method of collecting and using your personal data, we will clearly explain this to you by updating this privacy policy, a pop-up window, or a notice on the website and give you the opportunity to agree. You have the right to withhold your consent. However, if we are not allowed to use the personal information necessary to perform the updated services or features, we may not be able to provide you with the updated services and/or features or achieve the effect of the updated services. The basic functions of our services are not affected by the introduction of optimization functions.

  4. Ways you can share your personal information through our services

    Social network sharing features. Our Services may offer social sharing features and other built-in tools that allow you to share your activity on our Services with other media and vice versa. Using such features allows you to share information with your friends or the public, depending on the settings you have set with the social network sharing feature provider. For more information about the purpose and scope of data collection and processing in connection with social network sharing features, please see the privacy policies of the providers of these features.

  5. Where your personal data is stored

    We store information about users on servers located primarily in Oregon, USA. If you are accessing our Services from outside the United States of America, please note that the personal information you submit may be transferred to and stored on servers in the United States of America. The data protection and other laws of the United States of America and/or other countries may not be as comprehensive as those in your country. By submitting your information and/or using our services, you agree that your information may be transferred to, stored and processed in the United States of America.

  6. How long will your personal data be stored

    We generally store your personal data as long as you have an account with us or we provide you with services. We will then store your personal data for as long as is necessary to respond to your questions, complaints or claims, or as required by law. We do not store your personal data longer than is necessary for the purposes set out in this policy. How your personal data is protected

    How your personal data is protected:

    We have taken appropriate security measures to prevent personal information from being accidentally lost or used or accessed without authorization. We restrict access to your personal information to those who need that information for business purposes. The persons who process your data only do so in an authorized manner and are subject to confidentiality obligations. We are continuously testing our systems and are in the process of obtaining SOC II and ISO 27001 certifications, which means we comply with the highest industry standards for information security. We use appropriate security measures to protect your personal information in accordance with the Center for Internet Security's Critical Security Controls (The 18 CIS Critical Security Controls). We use encryption technologies to protect your personal data. We have established specific administrative rules, procedures, and organizations to ensure the security of personal information we collect. We conduct security and privacy training to make our employees aware of the importance of protecting personal data. In the event of an incident involving the security of personal data, we will initiate the emergency plan for security incidents, report the incident immediately to the relevant authorities, inform you of the basic situation of the security incident, the measures and remedies we have taken or will take, and our recommendations for you via announcements, push notifications, or emails. If it's difficult to inform all users, we'll issue the alert through public announcements. Notwithstanding the security measures taken and the implemented legal requirements, we cannot guarantee the security of your personal data when communicating via unsecure channels. You should therefore also take steps yourself to ensure the security of your personal data, for example by regularly changing your account password. We will notify you and all relevant regulatory authorities of a suspected data security breach where we are required to do so by law.

  7. Your rights with regard to your personal data

    We may change the terms from time to time. The most recent version of these terms is available at https://www.innoChat.com/terms. You understand and agree that your access to or use of the Services is subject to the terms in effect at the time you access or use the Services. If we make material changes to these terms, we will notify you at least thirty (30) days before the changes take effect via push notification and/or by posting a notice on the website. If we are required by applicable data protection laws to provide you with more detailed information about such changes or obtain your consent, we will do so. You can see when the terms of use were last updated by checking the “last updated” date at the top of these terms of use. All revised terms of use replace all previous terms of use.

  8. How your imported data is being used

    You have certain rights with respect to your personal information, which are described in this section. You, or an authorized representative acting on your behalf, may exercise your rights with respect to your personal information by making a verifiable request (see Section 8 (Exercising Your Rights) below). If an authorized representative makes a request to disclose or delete your personal information, we need the following from you:

    • Give your authorized representative a signed power of attorney to exercise your rights and decisions.

    • Verify your identity directly with us.

    • Confirm directly with us that your authorized representative is authorized to make the request.

    Because we don't optimize or operate our own large language models (LLMs), we DON'T use any data we collect from you to train LLMs. Our services use retrieval augmented generation (RAG) technology, which does not retrain or modify the LLMs themselves in any way. We use LLMs from OpenAI via their publicly available API. OpenAI has specifically stated that it does not use the data submitted via the API to train LLMs. For details, see OpenAI's privacy policy for companies at: https://openai.com/enterprise-privacy. 9. How you can exercise your rights of access, data portability, rectification, and deletion

    We use LLMs from OpenAI via their publicly available API. OpenAI has specifically stated that it does not use the data submitted via the API to train LLMs. For details, see OpenAI's Enterprise Privacy Policy at: https://openai.com/enterprise-privacy

  9. How you can exercise your rights

    To exercise the rights of access, data portability, rectification, and deletion described above, please email us a verifiable request at hello@innochat.ch.

    Only you or someone legally authorized to represent you can make a verifiable request regarding your personal information. You can only submit a verifiable request regarding access or data portability twice within a period of twelve (12) months. The verifiable request must:

    • Use the email address you used to register with us so we can verify that you are the person we collected personal information about.

    • Describe your request in sufficient detail so that we can understand, evaluate, and answer it correctly.

    We cannot respond to your request or provide you with personal information if we are unable to verify your identity or eligibility to make the request and confirm that the personal information concerns you.

    We aim to respond to all verifiable requests within forty-five (45) days of receipt. Should we need more time, we will inform you in writing of the reason and the required extension period. We will send you a confirmation of receipt of your verifiable request within ten (10) business days of receipt.

    If you have an account with us, we'll send you our written response to that account. If you don't have an account with us, we'll send you our written response the way you made your request. If you have an account with us, we'll send you our written response to that account. If you don't have an account with us, we'll send you our written response the way you made your request.

    If we are unable to comply with a verifiable request, we may provide you with our reasons in writing. For data portability inquiries, we choose a format for providing your personal data that is easy to use and should allow you to transfer the data from one location to another without hindrance.

    You usually don't have to pay a fee to access your personal information or exercise your data protection rights. However, except for withdrawing your consent, we may charge a reasonable fee if your request is manifestly baseless, repetitive, or excessive. If we determine that the request warrants a fee, we'll tell you the reasons for this decision and provide you with a cost estimate before we process the request. In such circumstances, we may also decline your request.

    We may decline your request in the following circumstances and in accordance with applicable laws and regulations:

    • When this is related to our legal and/or regulatory obligations

    • When this is related to national security and defense

    • When this is related to public safety, public health, and important public interests

    • When this is related to criminal investigations, prosecutions and legal proceedings

    • When there is sufficient evidence that you are showing subjective malice or abuse of rights

    • If responding to your request would seriously affect the legitimate rights and interests of you or other people and organizations

    • When trade secrets are affected

    • Other conditions set by law or regulatory authorities

  10. Your control options

    We give you control over the use and collection of your personal information. In this section, we describe your control options.

    We will not discriminate against you if you exercise your control rights or rights over your personal data. Unless otherwise permitted, when you exercise your control rights or rights over your personal information, we will refrain from:

    • Deny you services

    • Charge you different prices or rates for services, including through discounts or other benefits, or by imposing penalties

    • provide you with a different level or quality of service

    • Suggest to you that you may receive a different price or rate for services, or a different level or quality of service

  11. Consentsc

    In order to provide you with convenient and high-quality services, we may need some permissions for your device. When you use the appropriate feature, you'll see a pop-up reminder asking for your permission to access specific device features. You can disable some or all permissions in the client or device settings. The methods for granting or withdrawing permissions may vary from device to device.

    permission
    Services and features

    Camera permission

    You can use the camera to take and upload videos and pictures.

    Mic permission

    You can send voice messages, perform live videos, interact live, and complete recording and publishing audio and video content.

  12. How we respond to “Do Not Track” signals

    Because consumers are often unaware that their “Do Not Track” beacons are active, “Do Not Track” often does not reflect the actual preferences of our users. We do not currently respond to “Do Not Track” signals. In the meantime, you can opt out of certain types of tracking, including certain analytics and tailored advertising, by changing your cookie settings.

  13. Our policies regarding children

    As described in our terms of use (available at https://www.innochat.ch/terms), you must be at least 18 years of age or have the necessary authority and authority to access and/or use our services. If you are still a minor (i.e. under 18 years of age), you must obtain consent from your parent or guardian to use our services.

    If you are the legal guardian of a minor, please ensure that the minor only uses our services with your permission and consent and only then provides their personal information. If you have any questions about the personal information of the minor in your care, please contact hello@innochat.ch or write to the address provided at the beginning of this policy.

    Our Services are not intended for children under thirteen (13) years of age or under the minimum age in the relevant territory who is older than thirteen (13) years of age (the “Children” or “Child”), and we do not knowingly collect any personal information from such children. Children should not use or attempt to use our services. If you are a child, please do not attempt to use our services or send information about yourself to the company.

    If we learn that we have inadvertently collected personal information from a child, we will take reasonable steps to delete that information from our records. Parents who believe we may have collected information from or about a child can send a request to delete that information to hello@innochat.ch or write to our address provided at the beginning of this policy.

  14. Submitting a complaint

    InnoChat strives to store only the data necessary to effectively carry out its business activities and perform its tasks. The need for data storage depends on the type of data and the purpose for which it was collected. innoChat ensures that data is only stored for as long as is necessary to fulfill the purpose of collection and is deleted when it is no longer needed. This policy describes InnoChat's data retention policies, which are applied consistently across the organization.

    scope

    This policy applies to all data collected by InnoChat and stored on systems and media owned by InnoChat or rented by InnoChat, regardless of location. It applies both to data collected and stored electronically (including photographs, video and audio recordings) and to data collected and stored in the form of printouts or paper files. Retention of certain information may be required by federal or state laws, federal regulations, legitimate business purposes1, and the EU General Data Protection Regulation (GDPR).

    Reasons for data storage

    InnoChat only stores data that is necessary to effectively carry out its business activities, perform its tasks and comply with applicable laws and regulations. Reasons for data storage include:

    • Provision of ongoing services to data subjects (e.g. sending newsletters, publications, program updates, ongoing training, participation in InnoChat programs, processing employee salaries and benefits)

    • Compliance with applicable laws and regulations related to InnoChat's financial and program reporting to its funding agencies and donors

    • Compliance with applicable labor, tax, and immigration laws

    • Other regulatory requirements

    • Investigations into security incidents or other incidents

    • Protection of intellectual property

    • litigation

    data duplication

    InnoChat strives to avoid data duplication whenever possible, but it may be necessary to store data in multiple locations for programming or business reasons. This policy applies to all data held by InnoChat, including duplicates.

    Retention requirements

    InnoChat has established the following guidelines for the storage of all personal data in accordance with the Institute's privacy policy:

    • The data of website visitors is stored for as long as is necessary to provide the service requested/initiated via the INNOCHAT website.

    data destruction

    Data destruction ensures that InnoChat manages and processes controlled data responsibly and efficiently. After the retention period has expired or at the express request of the user, InnoChat actively destroys the data collected by this policy. If an individual believes that there is a legitimate business reason that precludes data destruction after the retention period has elapsed, they should report that data to their manager and provide a justification. Exceptions to this policy require approval by InnoChat's Data Protection Officer in consultation with a legal advisor. In rare cases, the legal advisor may impose a storage obligation for certain documents, which prohibits their destruction. The storage obligation remains in place until repealed by the legal advisor and prohibits the destruction of the data affected by the storage obligation.

  15. More

    We hope we can resolve any questions or concerns you may have about our use of your personal information. If you would like to make a complaint about our privacy practices, please contact hello@innochat.ch.