Privacy Policy

Welcome to Voices. This Privacy Policy explains how Voices.com Inc. (collectively referred to as “Voices”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal data in connection with our websites, including our website located at https://www.voices.com/, and other websites we own and operate that link to this Privacy Policy, and the related content, platform, services, products, and other functionality offered on or through our services. We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.

This Privacy Policy does not address our privacy practices relating to Voices job applicants, employees and other personnel, nor data that is not subject to applicable data protection laws (which may include deidentified, aggregated, anonymized or publicly available information). This Privacy Policy is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

Any capitalized terms not otherwise defined in this Privacy Policy have the meaning assigned to them in our Terms of Service.

Click on the links below to jump to each section:

1. Our Role in Processing Personal Data
2. Our Collection and Use of Personal Data
3. Our Disclosure of Personal Data
4. Your Privacy Choices
5. Children’s Personal Data
6. Investor Personal Data
7. Retention of Personal Data
8. Third-Party Websites and Services
9. Region-Specific Disclosures
10. Updates to This Privacy Policy
11. Contact Us
12. Additional United States Privacy Disclosures
13. Additional Canada Disclosures

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions.

This Privacy Policy describes our privacy practices where we are acting as the controller of personal data. However, this Privacy Policy does not cover or address how our Clients may process personal data when they use our services, or how we may process personal data on their behalf in accordance with their instructions where we are acting as their processor. As a result, we recommend that Talent refer to the privacy notice of the acquirer of Talent-related services (“Client”) with which Talent has a relationship for information on how they engage processors, like us, to process personal data on their behalf. In addition, we are generally not permitted to respond to individual privacy requests relating to personal data we process on behalf of our Clients, so we recommend directing any requests to the relevant Client.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you visit our website, sign up for our mailing list, register for an account, post a review, participate in an event, contest, promotion or survey, or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us:

• Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for support purposes.
• Talent Content, including any files, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to our products and services. We use this content primarily to provide you with our products and services, to facilitate your requests, to enable bookings between you and our Clients, and for security, fraud prevention and verification purposes. Your Talent Content will not be used in the creation of an AI voice model unless we receive your advanced written consent.
• Client Content, including any files, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to our products and services. We use this content primarily to provide you with our products and services, and to facilitate your requests, and to improve our products and services.
• Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). Please note that we use third-party payment providers to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy notice.
• Event, Contest, Promotion, and Survey Information, including name, contact information and other information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial. We use this information primarily to administer and facilitate our products and services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business, and facilitate the related event, content, promotion, or survey.
• Feedback and Support Information, including name, contact information and the contents of custom messages sent through the forms, chat platforms, including our online live chat or automated chat functions, email addresses, or other contact information we make available to Talent and Clients, as well as recordings of calls with us for training and quality assurance purposes, where permitted by law (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you via online chat, email, phone, text message or social media, and to improve our products and services.
• Security-Related Information, including name and contact information of visitors to our premises, video recordings of videos on our premises, and electronic login records and access details when a visitor utilizes company technology on our premises. We use this information primarily to protect the security of our premises, employees, and our company.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
• Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.
• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address.

All of the information collected automatically through these tools allows us to improve your experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, to offer communications features such as live and automated chat, and to improve the effectiveness of our products, services, offers, advertising, communications and support services. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below. For additional details about the cookies we use on our websites, please visit our “Cookie Policy”.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

• Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our products and services.
• Mobile Sign-On: We may provide you the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint, or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials. For more details, please refer to the biometric authentication guides offered by your device provider.
• Employers: If you interact with our services in connection with your employment, we may obtain personal data about you from your employer or another company for which you work. For example, we may obtain your contact information from your employer to allow us to communicate with you about your employer’s Client relationship with us.
• Other Clients and Talent: We may receive your personal data from our other Clients or Talent. For example, a Client may provide us with your contact information as a part of a referral.
• Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.
• Advertisers, Influencers, and Publishers: We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.
• Business Partners: We may receive your information from our business partners, such as our network of recording studios, Talent agents and Talent agencies. We may use your information to facilitate bookings and to provide the services.
• Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
• Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers or through transactions such as mergers and acquisitions.
• Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
• Manage our organization and its day-to-day operations;
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Facilitate the relationship we have with you and, where applicable, the company you represent;
• Request you provide us feedback about our product and service offerings;
• Address inquiries or complaints made by or about an individual in connection with our products or services;
• Create and maintain accounts for our users;
• Verify your identity;
• Register you for and provide you access to events, contests, sweepstakes, and surveys;
• Market our products and services to you, including through email, phone, text message, push notification, and social media;
• Administer and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services;
• Identify and analyze how you use our products and services;
• Infer additional information about you from your use of our products and services, such as your interests;
• Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
• Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
• Improve products and services by means that do not use algorithms or machine learning models;
• Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Use), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Voices and others;
• Facilitate business transactions and reorganizations impacting the structure of our business;
• Comply with contractual and legal obligations and requirements;
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented; and
• Create aggregated or de-identified information that cannot reasonably be used to identify you from general information that does not include Talent audio or video, which information we may use for purposes outside the scope of this Privacy Policy.

Deidentified Information: We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Our Disclosure of Personal Data

We may disclose personal data in the following ways and, where required by law, with your consent:

• To Your Employer: If you are a Client employee and you interact with our services on behalf of your employer, we may disclose personal data to your employer or another company for which you work. For example, we may provide information to your employer about your usage of our services in connection with your work for them.
• To Other Talent and Clients and the General Public: By publicly posting content on our services, you are directing us to disclose that information as broadly as possible, subject to applicable privacy settings and intended recipients.
• To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. See Your Privacy Choices

  The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you.

  Communication Preferences

  • Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our promotional email communications. Please note you cannot opt-out of service-related email communications (such as account verification, transaction confirmation, or service update emails).
  • Phone and Text Message Communication Preferences: You can stop receiving promotional phone (including text message) communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out of promotional phone calls (where available), or replying STOP to any one of our promotional text messages. Please note we may need to continue to communicate with you via phone (including text message) for certain service-related messages (such as, sending a verification code to your phone via call or text for purposes of verifying the authenticity of a log-in attempt).
  • Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.
  • Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us at [email protected]. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.

  Withdrawing Your Consent

  Where we rely on your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by adjusting your account settings (or by submitting a request through our online webform here), subject to certain legal exceptions and limitations.

  Automatic Data Collection Preferences

  Certain of our services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. For example, there is a cookie preferences manager linked in the footer of our websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).

  Where a Voices-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

  Targeted Advertising Preferences

  We engage third parties to help us facilitate targeted advertising designed to show you personalized ads on and off our websites and services based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.

  In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

  • Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.
  • Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program. Individuals in Canada can also visit the Digital Advertising Alliance of Canada, which provides similar opt-out tools.
  • Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program.
  • Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

  Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

  Modifying or Deleting Your Personal Data

  If you have any questions about reviewing, modifying, or deleting your personal data, you can manage your data through your account profile or submit a request through our online webform here. We may not be able to modify or delete your personal data in all circumstances.

  Partner-Specific Preferences

  Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide.

  The device and/or platform you use to interact with us (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to permit or prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

  Children’s Personal Data

  Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will expedite deletion of that personal data.

  Investor Personal Data

  In addition to the personal data practices outlined above, we also collect personal data from shareholders and investors of our company, including share purchasing history, number of shares held, value of the shares, and the holder of record’s name and address. We use this information primarily to manage investor relations and investments in our company, including by providing you information about our company and related investments, processing investment transactions, preparing tax returns and other investor-related documents, and managing our cap table. We may also use this information for the purposes set forth in the Additional Uses of Personal Data section above and disclose this information to third parties in furtherance of these purposes as set forth in the Our Disclosure of Personal Data section above, as permitted by law.

  Retention of Personal Data

  We will retain the personal data we collect about you for no longer than reasonably necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

  Where applicable, to determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

  Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete, deidentify (where permitted) or anonymize the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion, deidentification or anonymization is possible.

  Third-Party Websites and Services

  Our services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.

  Region-Specific Disclosures

  We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

  • United States: If you are a resident of the United States, please click here for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.
  • Canada: If you are located in Canada, please click here for additional Canadian-specific privacy disclosures.

  Updates to This Privacy Policy

  We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

  Contact Us

  If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to [email protected].

  ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

  These disclosures supplement the information contained in our Privacy Policy by providing additional information about the privacy rights available to individual residents of certain states in the United States and our personal data processing practices relating to individual residents of certain states in the United States. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Policy.

  Nevada Residents

  If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. You may submit a request to opt-out of the sale of your personal data by emailing us at [email protected].

  California, Colorado, Maryland, New Jersey, Oregon and Virginia Residents

  If you are a resident of the state of California, Colorado, Maryland, New Jersey, Oregon or Virginia in the United States, the following supplementary disclosures apply to you.

  Personal Data Disclosures, Sales and Targeted Advertising

  We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Policy. Only in cases where we receive your advanced consent pursuant to a written agreement with you will audio recording information you may provide result in a sale of such information. Otherwise, we do not sell personal data, and we do not process or otherwise share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across non-affiliated businesses or websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

  Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

  Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.

  Sensitive Personal Data

  The following personal data elements we collect may be classified as “sensitive”:

  • Government ID numbers, including social security number, driver’s license number, state identification card number, or passport number.
  • Account log-in, financial account, debit card or credit card number in combination with any required security or access code, password or credentials allowing access to an account.
  • Citizenship or immigration status
  • Trade union membership
  • Information about an individual’s sexual orientation, sex life or status as transgender or non-binary
  • Personal information collected from a known child under the age of 13.

  We only use or disclose sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal data without the purpose of inferring characteristics about the relevant individual, and we do not sell sensitive personal data or process or otherwise share sensitive personal data for the purpose of targeted advertising.

  Automated Decision-Making and Profiling

  We do not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.

  Your Additional U.S. Privacy Choices

  Depending on your state of residency and subject to certain legal limitations and exceptions, such as where there is a business need to preserve the data, you may be able to exercise some or all of the following rights:

  • Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including:
    • The categories of personal data collected;
    • The categories of sources of the personal data;
    • The purposes for which the personal data were collected;
    • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
    • The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and
    • The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.
  • Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data.
  • Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
  • Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties, including the right to opt-out of the disclosure of personal data to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.
  • Right to Deletion: The right to have us delete personal data we maintain about you, subject to legal limitations and exceptions, based on our legitimate business needs to preserve data.

  Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

  Submitting Privacy Rights Requests

  Please submit a request specifying the right you wish to exercise by:

  • Completing our online webform found here or
  • Calling our toll-free U.S. telephone number: 1-888-359-3472.

  To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, click the “Your Privacy Choices” link in the footer of the website and adjust your preferences accordingly. You can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Policy to further exercise control over automatic data collection technologies.

  Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

  Submitting Authorized Agent Requests

  In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

  Appealing Privacy Rights Decisions

  Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.

  Additional California-Specific Disclosures

  The following disclosures only apply to residents of the State of California.

  California Categories of Personal Data

  California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in the Our Collection and Use of Personal Data section of our Privacy Policy below:

  • Identifiers, such as your username and email address.
  • Customer records, such as your login credentials and phone number.
  • Protected classification characteristics, such as national origin.
  • Commercial information, such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information, such as audio and video recordings.
  • Internet / network information, such as device information, logs and analytics data.
  • Geolocation data, such as your approximate location based upon your IP address.
  • Sensory information, such as recordings of any phone calls between you and Voices.
  • Professional / employment information, such as job title, company and industry segment.
  • Sensitive personal data, such as citizenship or immigration status and union membership.
  • Other Personal Data, such as information you submit into the feedback forms and any communications between you and Voices, as well as information we receive from social networking sites.
  • Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

  ADDITIONAL CANADA DISCLOSURES

  These disclosures supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individuals who access our services or otherwise interact with us from Canada. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Policy.

  Our Privacy Governance Policies and Practices

  We are committed to protecting personal information and have implemented policies and practices that govern our treatment of personal information, including:

  • A privacy framework that defines the roles and responsibilities of our employees with respect to the treatment of personal information in our custody and control;
  • Practices pertaining to privacy training and awareness for our employees with access to personal information;
  • Policies and procedures regarding the protection of personal information, including safeguards designed to protect personal information in our custody and control against loss or theft and unauthorized access, use or disclosure; and
  • A framework governing the retention and destruction of personal information that is designed to comply with our legal and contractual obligations.

  Data Location

  We and our service providers (including affiliates) may access, store and otherwise process personal information on our behalf outside of the province in which you reside, including in the United States. For further information on our use of service providers located outside of Canada, please contact us as set out below.

  Disclosures Required by Law

  We and our U.S., Canadian, and other foreign service providers and affiliates may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable U.S., Canadian or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities.

  Children’s Personal Data

  Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 14. If an individual is under the age of 14, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 14 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 14, we will expedite deletion of that personal data.

  Submitting Privacy Rights Requests

  Please submit a request specifying the right you wish to exercise by completing Your Privacy Choices” link in the footer of the website and adjust your preferences accordingly. You may also follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Policy to further exercise control over automatic data collection technologies.

  Before processing your request to exercise certain rights, we will need to verify your identity and confirm you are a resident of Canada. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include first and last name, email address, phone number, country of residency and/or the date of your last transaction with us.

  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of Canada.

  Contact

  If you have any questions about our privacy practices, please contact our Privacy Lead at [email protected].