Privacy Policy

Effective as of 20th February 2023.


This Privacy Policy describes how Work with Dots, Inc. d/b/a Async  ("Async," "we", “us” or "our") handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.  

We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal information before you use our Services. 

If you are located in the European Economic Area or the United Kingdom, please consult the notice to European users below. 


Index

Personal information we collect


Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes: Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Marketing partners, such as joint marketing partners and event co-sponsors.
- Third-party services, such as social media or other services, that you use to log into or otherwise link to your Service account. This data may include your username, profile picture, first and last name, email address, address book information, and other information associated with your account on that third-party service that is made available to us based on your account settings or other permissions on that service.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:


How we use your personal information

Service delivery. We may use your personal information to:

Research and development.  We may use your personal information (excluding contents of your Audio information) for research and development purposes, including to analyze and improve the Service and our business.  We may analyze and conduct research on the duration of your voice notes.

Marketing and advertising.  We, our service providers, and our third-party advertising partners may collect and use your personal information (excluding any Audio information) for marketing and advertising purposes:Direct marketing.  We may send you direct marketing communications.  Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to [email protected].

Compliance and protection.  We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- maintain appropriate business records;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect (excluding contents of your Audio information).  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.


How we share your personal information

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
* Google: https://adssettings.google.com/
* Facebook: https://www.facebook.com/about/ads
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
* Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
* Digital Advertising Alliance: optout.aboutads.info.
* AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

How long do we keep your personal information

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.

To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security
We employ a number of technical, organizational and physical safeguards designed to protect and maintain the security of our Services and the personal information we collect in preventing the unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.   However, security risk is inherent in all internet and information technologies and the transmission of personal information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service.

International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children
The Service is not intended for use by anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.


How to contact us
Notice to European users

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Work with Dots, Inc. d/b/a Async  is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

EU Representative:
EU Business Partners, 10 Ashe Street, Clonakilty, Co. Cork P85 E403, Ireland
Point of contact: Flor McCarthy - [email protected]

UK Representative:
UK GDPR Representatives Limited, 7 Bell Yard, London, WC2A 2JR, United Kingdom
Point of contact: Flor McCarthy - [email protected]

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background or trade union membership) through the Service or otherwise. We encourage you not to share such sensitive personal information with us.

Your rights. Under applicable EU and UK data protection laws, you have the following rights in respect of your personal information:

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us and we may be required to no longer process your personal information. Moreover, if your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.

When you request us to provide the personal information we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, however, we invite you to contact us first. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

Cross-border data transfer. Your personal information may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the EEA, UK or Switzerland, you should be aware that your personal information may be shared with, and transferred to, Async affiliates and third-party service providers who are located outside the EEA, UK or Switzerland. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.

To this end:
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
1. Information on how we use cookies
2. What are cookies?
3. Key concepts
4. Changing your cookie settings
5. Your consent
6. Can I withdraw my consent?
7. What types of cookie do we use and why?
8. Retention
9. Keeping our cookie policy up to date

Personal information we collect
Information you provide to us.
Personal information you may provide to us through the Service or otherwise includes:

- Contact data, such as your first and last name, salutation, email address, professional title and company name, and phone number.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, profile URL, photograph, links to your profiles on social networks, interests, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.  
- Audio Information collected when you record or orally respond to a voice memo through the Services. We may also create a transcript of your Audio Information.
- Address book information, when you give us permission to access information in your address book or other contacts, including from third party sites.
- Payment data needed to complete transactions, including payment card information or bank account number.
- Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
- Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content, such as files, profile pictures, photos, images, music, videos, comments, questions, messages, reactions, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.  Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited.  Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information services and data licensors that provide demographic and other information. 
- Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
- Marketing partners, such as joint marketing partners and event co-sponsors.
- Third-party services, such as social media or other services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture, first and last name, email address, address book information, and other information associated with your account on that third-party service that is made available to us based on your account settings or other permissions on that service.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.


How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery.  We may use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service;
- facilitate your invitations to friends who you want to invite to join the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information (excluding contents of your Audio information) for research and development purposes, including to analyze and improve the Service and our business.  We may analyze and conduct research on the duration of your voice notes.

Marketing and advertising.  We, our service providers, and our third-party advertising partners may collect and use your personal information (excluding any Audio information) for marketing and advertising purposes:
- Direct marketing.  We may send you direct marketing communications.  Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to [email protected].
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

Compliance and protection.  We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- maintain appropriate business records; 
- enforce the terms and conditions that govern the Service; and 
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect (excluding contents of your Audio Information).  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
- Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.


How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information (e.g., affiliates and service providers that have access to your personal information) provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Affiliates.  Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe.  Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Transcription providers.  We may share your Audio Information with Rev AI to provide a transcript of your voice note to the intended recipients of your voice memo. Rev AI may use your Audio Information in accordance with its privacy policy.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.  We do not share your Audio information with such partners.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information (excluding Audio information) with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors.  Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Async or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other users and the public.  Your profile data is visible to the public. Additionally, your user-generated content and audio information may be visible to other users of the Service.  For example, other users of the Service will have access to your audio information or user-generated content if you choose to make such information available to them through the Service, such as when you send them a voice note or a file.   Any information made available to others can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.


Your Choices

In this section, we describe the rights and choices available to all users. Users who are located in the United Kingdom, Switzerland, and the European Economic Area can find additional information about their rights in the Notice to European Users section below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites: Google: https://adssettings.google.com/ , Facebook: https://www.facebook.com/about/ads 
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: 
* Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
* Digital Advertising Alliance: optout.aboutads.info.
* AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. 
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.


Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.


How long do we keep your personal information

How to contact us


Email: [email protected] 
Mail: 12 E 33rd St FL 12- New York, NY 10016

Notice to European users

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (hereafter collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

Controller. Async is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. 

EU and UK Representative.

EU representative:
EU Business Partners, 10 Ashe Street, Clonakilty, Co. Cork P85 E403, Ireland
Point of contact: Flor McCarthy - [email protected]

UK representative:
UK GDPR Representatives Limited, 7 Bell Yard, London, WC2A 2JR, United Kingdom
Point of contact: Flor McCarthy - [email protected]

Async’s data protection officer can be contacted at [email protected]

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Effective as of 20th February 2023.


This Privacy Policy describes how Work with Dots, Inc. d/b/a Async  ("Async," "we", “us” or "our") handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.  

We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal information before you use our Services. 

If you are located in the European Economic Area or the United Kingdom, please consult the notice to European users below. 


Index

Personal information we collect


Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes: Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Marketing partners, such as joint marketing partners and event co-sponsors.
- Third-party services, such as social media or other services, that you use to log into or otherwise link to your Service account. This data may include your username, profile picture, first and last name, email address, address book information, and other information associated with your account on that third-party service that is made available to us based on your account settings or other permissions on that service.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:


How we use your personal information

Service delivery. We may use your personal information to:

Research and development.  We may use your personal information (excluding contents of your Audio information) for research and development purposes, including to analyze and improve the Service and our business.  We may analyze and conduct research on the duration of your voice notes.

Marketing and advertising.  We, our service providers, and our third-party advertising partners may collect and use your personal information (excluding any Audio information) for marketing and advertising purposes:Direct marketing.  We may send you direct marketing communications.  Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to [email protected].

Compliance and protection.  We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- maintain appropriate business records;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect (excluding contents of your Audio information).  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.


How we share your personal information

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
* Google: https://adssettings.google.com/
* Facebook: https://www.facebook.com/about/ads
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
* Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
* Digital Advertising Alliance: optout.aboutads.info.
* AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

How long do we keep your personal information

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.

To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security
We employ a number of technical, organizational and physical safeguards designed to protect and maintain the security of our Services and the personal information we collect in preventing the unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.   However, security risk is inherent in all internet and information technologies and the transmission of personal information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service.

International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children
The Service is not intended for use by anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.


How to contact us
Notice to European users

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Work with Dots, Inc. d/b/a Async  is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

EU Representative:
EU Business Partners, 10 Ashe Street, Clonakilty, Co. Cork P85 E403, Ireland
Point of contact: Flor McCarthy - [email protected]

UK Representative:
UK GDPR Representatives Limited, 7 Bell Yard, London, WC2A 2JR, United Kingdom
Point of contact: Flor McCarthy - [email protected]

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background or trade union membership) through the Service or otherwise. We encourage you not to share such sensitive personal information with us.

Your rights. Under applicable EU and UK data protection laws, you have the following rights in respect of your personal information:

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us and we may be required to no longer process your personal information. Moreover, if your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.

When you request us to provide the personal information we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, however, we invite you to contact us first. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

Cross-border data transfer. Your personal information may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the EEA, UK or Switzerland, you should be aware that your personal information may be shared with, and transferred to, Async affiliates and third-party service providers who are located outside the EEA, UK or Switzerland. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.

To this end:
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
1. Information on how we use cookies
2. What are cookies?
3. Key concepts
4. Changing your cookie settings
5. Your consent
6. Can I withdraw my consent?
7. What types of cookie do we use and why?
8. Retention
9. Keeping our cookie policy up to date

Personal information we collect
Information you provide to us.
Personal information you may provide to us through the Service or otherwise includes:

- Contact data, such as your first and last name, salutation, email address, professional title and company name, and phone number.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, profile URL, photograph, links to your profiles on social networks, interests, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.  
- Audio Information collected when you record or orally respond to a voice memo through the Services. We may also create a transcript of your Audio Information.
- Address book information, when you give us permission to access information in your address book or other contacts, including from third party sites.
- Payment data needed to complete transactions, including payment card information or bank account number.
- Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
- Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content, such as files, profile pictures, photos, images, music, videos, comments, questions, messages, reactions, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.  Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited.  Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information services and data licensors that provide demographic and other information. 
- Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
- Marketing partners, such as joint marketing partners and event co-sponsors.
- Third-party services, such as social media or other services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture, first and last name, email address, address book information, and other information associated with your account on that third-party service that is made available to us based on your account settings or other permissions on that service.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.


How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery.  We may use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service;
- facilitate your invitations to friends who you want to invite to join the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information (excluding contents of your Audio information) for research and development purposes, including to analyze and improve the Service and our business.  We may analyze and conduct research on the duration of your voice notes.

Marketing and advertising.  We, our service providers, and our third-party advertising partners may collect and use your personal information (excluding any Audio information) for marketing and advertising purposes:
- Direct marketing.  We may send you direct marketing communications.  Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to [email protected].
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

Compliance and protection.  We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- maintain appropriate business records; 
- enforce the terms and conditions that govern the Service; and 
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect (excluding contents of your Audio Information).  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
- Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.


How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information (e.g., affiliates and service providers that have access to your personal information) provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Affiliates.  Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe.  Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Transcription providers.  We may share your Audio Information with Rev AI to provide a transcript of your voice note to the intended recipients of your voice memo. Rev AI may use your Audio Information in accordance with its privacy policy.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.  We do not share your Audio information with such partners.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information (excluding Audio information) with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors.  Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Async or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other users and the public.  Your profile data is visible to the public. Additionally, your user-generated content and audio information may be visible to other users of the Service.  For example, other users of the Service will have access to your audio information or user-generated content if you choose to make such information available to them through the Service, such as when you send them a voice note or a file.   Any information made available to others can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.


Your Choices

In this section, we describe the rights and choices available to all users. Users who are located in the United Kingdom, Switzerland, and the European Economic Area can find additional information about their rights in the Notice to European Users section below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites: Google: https://adssettings.google.com/ , Facebook: https://www.facebook.com/about/ads 
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: 
* Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
* Digital Advertising Alliance: optout.aboutads.info.
* AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. 
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.


Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.


How long do we keep your personal information

How to contact us


Email: [email protected] 
Mail: 12 E 33rd St FL 12- New York, NY 10016

Notice to European users

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (hereafter collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

Controller. Async is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. 

EU and UK Representative.

EU representative:
EU Business Partners, 10 Ashe Street, Clonakilty, Co. Cork P85 E403, Ireland
Point of contact: Flor McCarthy - [email protected]

UK representative:
UK GDPR Representatives Limited, 7 Bell Yard, London, WC2A 2JR, United Kingdom
Point of contact: Flor McCarthy - [email protected]

Async’s data protection officer can be contacted at [email protected]

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purposes
We need to process your personal information operate our Services, including managing your account or transactions, responding to your requests or inquiries, providing you with access to content or information you requested, etc. 

We may need to process your personal information for additional purposes, such as:
- Research and development purposes
- To ensure access and maintenance of our Services, and to ensure their proper functioning
- For marketing purposesFor compliance, fraud prevention and safety
- For sharing your personal information with third parties as described in this Privacy Policy
- To disclose your personal information to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets.
- To protect our interests as a company, for different purposes, such as:
- enforcement of the Terms of Service assess claims that any content violates the rights of third-parties:
- establishing or exercising our legal rights or defending against legal claims

Legal basis
The processing of your personal information is necessary to perform the contract governing the provision of our Services or to take the necessary steps prior to signing up for the Services. 

We rely on our legitimate interests to process your personal information when performing these processing activities. We do not use your personal information for these purposes where our interests are overridden by the impact on you.We are subject to certain legal obligations that may oblige us to disclose your personal information to courts, law enforcement or regulatory authorities.

The processing of your personal information is necessary to comply with our legal obligations.You may allow third party ad partners and advertisers to use tracking technologies while you use our Website or Services.We may invite you to participate on a voluntary basis to our surveys about our Services.We may process your personal information for any other purposes for which we will seek your consent.In these scenarios, the processing of the personal information you voluntarily provide to us is based on your consent. Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent to the processing.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background or trade union membership) through the Service or otherwise. We encourage you not to share such sensitive personal information with us.

Your rights. Under applicable EU and UK data protection laws, you have the following rights in respect of your personal information:
a. to obtain information about how and on what basis your personal information is processed and to obtain a copy;
b. to rectify inaccurate personal information;
c. to erase your personal information in limited circumstances where (i) you believe that it is no longer necessary for us to hold your personal information; (ii) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (ii) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (iv) where you believe the personal information we hold about you is being unlawfully processed by us;
d. to restrict processing of your personal information where: (i) the accuracy of the personal information is contested; (ii) the processing is unlawful but you object to the erasure of the personal information; (iii) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim; or (iv) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
e. to object to decisions which are based solely on automated processing or profiling;
f. where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
g. to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us and we may be required to no longer process your personal information. Moreover, if your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.

When you request us to provide the personal information we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, however, we invite you to contact us first. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

Cross-border data transfer. Your personal information may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the EEA, UK or Switzerland, you should be aware that your personal information may be shared with, and transferred to, Async affiliates and third-party service providers who are located outside the EEA, UK or Switzerland. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.  To this end:

a. we will ensure that transfers within Async and its affiliates will be covered by an agreement entered into by members of Async (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Async group;
b. where we transfer your personal information outside Async or to third parties who help provide our Services, we will obtain contractual commitments from them to protect your personal information; and
c. where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal information is disclosed.You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Cookie Notice

Notice last updated: 1st July 2022.

1. Information on how we use cookies
Our Async website (“Website”) uses various cookies which allow us to distinguish you from other users of our Website, which helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

We use cookies to provide the content and functionality of our Website (strictly necessary cookies) and, with your permission, to personalize the content and advertisements that appear when you visit our Website and to analyze the traffic on the Website. In addition, we share information about your use of our Website with our advertising partners and analysts, who may combine this information with other data that you provide to them or that they have collected when you use their services. You have the right to withdraw your consent at any time.

You do not need to allow cookies to visit most of the Website. However, enabling cookies may allow for a more tailored browsing experience and is required for certain parts of the Website to work. In the majority of cases, a cookie does not provide us with any of your personal information.For further information about this cookie policy, please contact us at [email protected]. You can change the cookie settings that will be placed when you visit our Website by changing the settings on your browser.

2. What are cookies? 
Cookies are small data files containing a unique identifier that are placed on your computer or mobile device when you visit a website. Cookies and similar technologies enable operators or websites to recognize your device and collect information from it when you interact with them and serve different purposes, like helping us understand how our Website is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experiences. 

3. Key concepts
First-party cookies are those set by a website that is being visited by the user at the time.

Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

Persistent cookies are cookies that remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

4. Changing your cookie settings
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our Website.

Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the 'Help' option in your internet browser for more details:
Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari

5. Your consent
Strictly necessary cookies do not require your consent.

For performance, functional and targeting cookies, we request your consent before placing them on your device. You can give your consent by clicking on the appropriate button on the cookie banner displayed to you.

6. Can I withdraw my consent?
If you do not wish to give consent or wish to withdraw your consent to any performance, functionality, targeting or social cookies at any time, you will need to delete, and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling these cookies will affect the functionality of the website and may prevent you from being able to access certain features on the website.

7. What types of cookie do we use and why?
We use are "necessary" and "performance" and "functional" and "targeting" cookies:
Strictly Necessary cookies:
These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Website will not work as they should. These cookies do not store any personal information.
Performance cookies:
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website and gather information on error messages. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Website, and will not be able to monitor its performance.
Functional cookies:
These cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting cookies:
These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

8. Retention
A cookie or similar technology will exist for different periods of time depending on the purpose of the cookie. For example, a session cookie which enables the Website to operate will only exist on your device whilst you browse our Website but other cookies will remain on your device for longer such as some functionality cookies which need to stay on your device so that the Website can recognise you when you return.

9. Keeping our cookie policy up to date
We may need to update our cookie policy from time to time if we decide to use cookies differently. Any changes will be updated here.

For more information about how we process personal information collected from cookies please refer to our website privacy policy.
If you have any questions or would like more information about the ways we use cookies please contact us at [email protected].  We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law. 

To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.   

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.  

Security
We employ a number of technical, organizational and physical safeguards designed to protect and maintain the security of our Services and the personal information we collect in preventing the unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.   However, security risk is inherent in all internet and information technologies and the transmission of personal information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service. 

International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Users in the United Kingdom, Switzerland, and the European Economic Area should read the important information provided in the notice to European users section below about transfer of personal information outside of the EEA, Switzerland and the UK, as applicable

Children
The Service is not intended for use by anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes. 

How to contact us
Email: [email protected]
Mail: 12 E 33RD ST FL 12 NEW YORK, NY 10016.

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