We, at Corti Inc., Corti America Inc., Corti AI UK Limited and Corti ApS (“Corti,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. 

This Privacy Policy relates to the information collection and use practices in connection with our website located at https://www.corti.ai/ (the “Website”), our proprietary software as a service (SaaS) platform (the “Platform”) which is made available as a web application via our Website, and when you otherwise interact with us in any way. 

This Privacy Policy applies to visitors to the Website, who view only publicly-available content (“Visitors”), customers who have signed up to access and use the Platform (the “Customers”), and Customer’s employees and contractors authorized by Customer to access and use the Platform (“Authorized Users”). 

By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. 

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Description of Users and Acceptance of Terms 

By accessing and/or using the Platform, each Customer and Authorized User is agreeing to the terms of this Privacy Policy and the accompanying Platform Terms of use. 

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use. 

Definitions 

• Website is the http://corti.ai/ website operated by Corti. 
• Platform: our proprietary software as a service (SaaS) platform, which is made available as a web application via our Website. 
• Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data is data collected automatically, either generated by the use of the Website and the Platform or from the Website and the Platform infrastructure itself (for example, the duration of a page visit). 
• Cookies are small pieces of data stored on your device (computer or mobile device). 
• Data Controller is the natural or legal person who (either alone or jointly, or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, Corti is a Data Controller of your Personal Data. 
• Data Processor (or Website Provider) is any natural or legal person who processes the data on behalf of the Data Controller. Corti may use the services of various Website Providers in order to process your data more effectively. 
• Data Subject (or User) is any living individual who is using our Website and is the subject of Personal Data. 

Information collection and use 

In the course of operating the Website and the Platform, and/or interacting with you, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information. 

Types of data collected 

Personal data 

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information (PII) may include, but is not limited to: 

● Email Address 

● First Name and Last Name 

● Cookies and Usage Data 

We may use your Personal Data to contact you with newsletters, marketing, promotional materials, or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us directly. 

Usage data 

We may also collect information on how the Website and the Platform is accessed and used (“Usage Data”). This Usage Data may include information, such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

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Cookies policy 

We use the following cookies if you accepted them: 

● Adobe Analytics - analytics 

● CloudFlare - functionality. 

● DoubleClick - marketing 

● Google Ads - marketing. 

● Google Analytics - analytics. 

● HubSpot - analytics 

● LinkedIn Ads - marketing. 

● Mixpanel - analytics. 

● Intercom - personalization. 

Tracking & cookies data 

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. 

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies could be beacons, tags, and scripts to collect and track information and to improve and analyze our Website. 

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies or other Tracking Technologies, the Website and the Platform may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

Examples of Cookies we use: 

• Session Cookies. We use Session Cookies to operate our Website. 
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings. 
• Security Cookies. We use Security Cookies for security purposes. 

Use of data 

Corti uses the collected data for various purposes: 

• To provide and maintain our Website and the Platform. 
• To notify you about changes to our Website and the Platform.
• To allow you to participate in interactive features of our Website and the Platform, when you choose to do so. 
• To provide customer support. 
• To gather analyses or valuable information, so that we can improve our Website and the Platform. 
• To monitor the usage of our Website and the Platform. 
• To detect, prevent, and address technical issues. 
• To provide you with news, special offers, and general information about other goods, services, and events, which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information. 

Legal basis for processing personal data 

If you are from the European Economic Area (EEA), UK and Switzerland Corti's legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. 

Corti may process your Personal Data because: 

● We need to perform a contract with you. 

● You have given us your permission/consent to do so. 

● The processing is in our legitimate interests and not overridden by your rights. ● To comply with the applicable law. 

Retention of data 

Corti will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

Corti will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods. 

Transfer of data 

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Denmark and choose to provide information to us, please note that we may transfer the data, including Personal Data, to Denmark and process it there. 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 

Corti will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. 

Compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF 

Corti Inc. and Corti America Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Corti Inc, has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. [INSERT your organization name] has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the U.S. Department of Commerce’s Data Privacy Framework website. 

Important Notices to U.S. Residents 

Notice to California Residents 

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at: privacy@corti.ai. 

Notice to Nevada Residents 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at support@Scribecare

with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. 

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Disclosure of data 

Corti, acting as data controller, will only disclose personal information to third parties performing tasks on behalf of and under our instructions. These third parties may include service providers such as IT support, cloud storage and data analytics. Data is shared strictly for purposes such as delivering and improving our services and ensuring compliance and security. Corti ensures that a contractual agreement is in place with such third parties to protect the subject’s personal data and require them to comply with the Data Privacy Framework Principles. Additionally, we implement safeguards such as data minimization and regular audits to ensure your personal information is handled securely, including during any cross-border transfers in compliance with applicable laws. 

Business transaction 

If Corti is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. 

Disclosure for law enforcement 

Under certain circumstances, Corti may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). 

Investigation and Enforcement Powers 

As part of our compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF),  we acknowledge that Corti may be subject to investigatory and enforcement powers by the Federal Trade Commission (FTC), which is responsible for overseeing compliance with privacy commitments under the framework. 

Legal requirements 

Corti may disclose your Personal Data in the good faith belief that such action is necessary to: 

● To comply with a legal obligation. 

● To protect and defend the rights or property of Corti. 

● To prevent or investigate possible wrongdoing in connection with the Website. 

● To protect the personal safety of users of the Website and the Platform or the public. ● To protect against legal liability.

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Security of data 

We take commercially reasonable security measures to ensure that your information is treated securely and is protected from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. In particular, e-mail sent to or from the Website and/or the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other electronic means. We do not accept liability for unintentional disclosure of your information. 

Your data protection rights 

If you are a resident of the European Economic Area (EEA), UK or Switzerland you have certain data protection rights. Corti aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. 

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. 

In certain circumstances, you have the following data protection rights: 

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. 
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. 
• The right to object. You have the right to object to our processing of your Personal Data. 
• The right of restriction. You have the right to request that we restrict the processing of your personal information. 
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format. 
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Corti relied on your consent to process your personal information. 

Please note that we may ask you to verify your identity before responding to such requests. 

Notification of Data Protection Authority Cooperation for Data Complaints 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA), UK and Switzerland.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Corti Inc. and Corti America Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. 

Opt-Out Rights 

Corti allows individuals to opt out of disclosing personal information to third parties or using it for different purposes. Clear mechanisms for exercising this choice should be provided.However, choice is not required when disclosing data to third-party agents acting on behalf of Corti, provided a contract is in place. For sensitive information, explicit consent (opt-in) is needed before sharing with third parties or using it for new purposes. Sensitive data includes health conditions, racial or ethnic origin, political opinions, and more. 

Binding Arbitration 

Under certain conditions, individuals have the right to invoke binding arbitration regarding unresolved claims related to their personal data as covered by the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF. This option applies only to residual claims regarding personal data covered by the EU-U.S. DPF. This process is outlined in Annex I of the DPF Principles, which can be accessed here. 

Right to Lodge Complaints 

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Corti Inc. and Corti America Inc. commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact Mirel Stelian and/or Sonia Moula at:at: privacy@corti.ai. 

Website Providers 

We may employ third party companies and individuals to facilitate our Website and the Platform (“Website Providers”), to provide the service on our behalf, to perform Website-related services or to assist us in analyzing how our Website and the Platform is used. 

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. 

Liability for Onward Transfers

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In cases where Corti, acting as a data controller, transfers personal information to a third party, Corti will adhere to the Notice and Choice Principles. Corti retains responsibility for the processing of personal information received under the DPF Principles and subsequently transferred to a third party acting as data processor. If such a third party processes personal information in a manner inconsistent with the DPF Principles, Corti will remain liable under the DPF Principles, unless Corti can demonstrate that is not responsible for the event that caused the damage. 

Analytics 

We may use third-party Website Providers to monitor and analyze the use of our Website. 

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. 

Links to other sites 

The Website and Platform may contain links to external third-party websites (“External Sites”). Corti has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Sites. 

Information Collected by or Through Third-Party Advertising Companies 

We may share information about you with third parties that we have selected and approved for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data. You can limit this type of tracking through the Do Not Track functionality (see further below) in your web browser and a “Limit Ad Tracking” setting on iOS devices or a setting to “Opt out of Interest-Based Ads” on Android.

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Do Not Track 

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Website and the Platform. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals. 

Children’s privacy 

We do not knowingly collect personal information from children under the age of 18 through the Website and the Platform. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Website and the Platform without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases. 

Changes to this Privacy Policy 

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change and/or update our Privacy Policy with or without notice to you. Any such changes will be posted on the Website and the Platform. By visiting the Website and/or accessing and/or using the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Privacy Policy in effect at the time we collect the information. 

Please refer back to this Privacy Policy on a regular basis. 

Contact us 

If you have any questions or concerns about this Privacy Policy or you wish to report a privacy issue, please contact us at: privacy@corti.ai. 

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