Last Updated date: Sept 1, 2024

No More Screenshots, Inc. (“we,” “us,” “ours” or “Hearsay”) respects your privacy. This privacy policy (“Privacy Policy”) explains how we collect, process, store and share personal information in connection with the Hearsay software for data access and management and related services (the “Services”), the electronic systems, applications, and internet sites of Hearsay, including https://app.usehearsay.com and https://usehearsay.com and others, and through which we offer and provide the Services (the “Platform”), and our business operations. “You” or “you” refers to subscribers to our Services (“Subscribers”), users of our Services and Platform (“Users”), and other persons who provide personal information to us. If you are an individual, this Privacy Policy also provides you with important information about your personal information rights with respect to personal information that we control and how to exercise them.

This Privacy Policy does not apply to personal information that we collect in from employees of or job applicants to Hearsay in connection with their employment or potential employment at Hearsay.

By accessing or using our Services or our Platform, or by providing personal information to us, you acknowledge that you accept our privacy practices and policies outlined below, and you consent that we may collect, process, store and share personal information as described in this Privacy Policy.

1.    Notice at Collection of Personal Information

Definition of Personal Information

We collect, process, store and share information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified, or aggregated data (even if it originally comes from personal information).

Sources of Personal Information

We collect personal information from the following categories of sources:

·       Directly from you, such as when you use our Services or Platform or when you communicate or interact with us in any way, including mail, email, phone, chat, QR code, or social media

·       Indirectly from you, for example, we collect cookie data and other information from your device, browser, or activity in our Services or on our Platform

·       From Subscribers or Users, for example, our Subscribers and Users provide us with personal information in connection with the Services we provide to Subscribers   

·       From third parties or public sources, for example, from our analytics providers and social media pages

Categories of Personal Information We Collect:

The categories of personal information we collect from or about you depends on your relationship with us. For example, we collect certain categories of personal information directly from Subscribers and Users in order to provide the Services to them.  We may collect other categories of personal information because they are included in the data Subscribers and Users extract into our Services and Platform using the Hearsay Extractor.

We collect the following categories of personal information from all of the various sources of information:

• Contact information, such as full name, home or work address, email address, and phone number

• Professional or employment-related information, such as your job title, employer information, and work history

• Financial information, including bank account, wire transfer and credit card information, and insurance policy information

• Commercial information, such as the billing details we use to bill you for our Services, your billing and payment history, and any records of real or personal property that we collect in connection our Services

• Mail, email, or text message contents not directed to us, for example, through our Services, Subscribers and Users can extract, analyze, and manage text messages, WhatsApp messages, and other communications

• Audio, electronic, visual, or similar information, for example, through our Services, Subscribers and Users can extract, analyze, and manage recordings of conversations, voicemails, photos, and images

• Internet and device identifiers, activity and analytics, such as information we automatically collect through cookies and similar technologies used on our Platform and in our Services, including user activity on our Platform, browser, operating system, and device information, and IP address

• Approximate geolocation when you are using our Services or Platform

• Preference information, including preferences related to marketing, privacy, and communications

• Inferences drawn from any of the personal information we collect; for example, to create a profile of an individual’s preferences and characteristics

• Government identification, such as driver’s license, social security number, and passport

• Account access information, such as 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.

• Biometric information, such as fingerprints and voiceprints

• Medical or genetic information, such as information related to health, medical conditions, healthcare communications, health insurance matters, or genetic data

• Characteristics of protected classifications, such as, age, race, color, ancestry, ethnic origin, national origin, citizenship, immigration status, religion, creed or philosophical beliefs, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or union membership

• Criminal history, including criminal convictions and offenses

• Education information, such as any school or educational records

• Social media information, such as your connections, posts, and comments

• Other information you choose to provide to us  

  
  

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to provide certain Services or access to the Platform, verify your identity, or process transactions, we may be unable to offer certain Services or access to the Platform, or otherwise conduct business with you.

Our Business Purposes for Collecting and Sharing Personal Information

We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests, and the legitimate interests of third parties to:

• Provide the Services and the Platform, including, to permit Subscribers and Users to access and use the Services and the Platform, enable Subscribers and Users to extract, review, and manage data from mobile devices such as text messages, WhatsApp messages, photos, images, and voicemails, facilitate communication and collaboration among Users, manage our relationship with our Subscribers and Users, process transactions, and otherwise assist and respond to our Subscribers and Users

• Support our business operations, including to bill and collect payment for our Services, administer and protect our Services, Platform, and systems, verify the identity of Users, and use hosting, technology, and communication providers and other vendors that support our business operations 

• Market our Services, for example, we process and share limited categories of personal information (contact information, professional information, commercial information, internet and device information (including approximate geolocation), audio, electronic, visual, or similar information, preference information, and inferences) to send you marketing communications

• Improve the Services and the Platform, for example, we process and share limited categories of personal information (contact information, professional information, commercial information, internet and device information (including approximate geolocation), audio, electronic, visual, or similar information, preference information, and inferences) for our internal research and development purposes and to troubleshoot, test and conduct data analysis, to update and otherwise improve the Platform’s functionality, to make informed business decisions and to improve user experience

• Deidentify personal information, including aggregating and anonymizing personal information so that it is no longer personal information

• Meet legal and compliance requirements, including to perform audits, monitoring, and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property, or safety of our Subscribers, our Users, you, us, or a third party; respond to legal process (including subpoenas) and governmental, court, or law enforcement requests, investigations, or orders; and comply with and enforce applicable laws, regulations, policies, procedures, and agreements 

• Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, bankruptcy, or other transaction in which a third party invests in or acquires control of our business or assets (in whole or in part)

We do not collect or process personal information for the purposes of automated decision-making or profiling (meaning the automatic processing of your personal information to identify your preferences and interests). 

Under the laws of some jurisdictions, we must be able to describe the legal bases on which we rely to process personal information. We primarily rely on the legitimate interests, described above, to process personal information when not overridden by an individual’s data protection interests or fundamental rights and freedoms. Other legal bases for our processing of personal information include when the processing is necessary to perform a contract with you, we have a legal obligation to process the personal information or we have your consent to process the personal information.

Categories of Parties Whom We Share Your Personal Information

We share all of the categories of personal information we collect identified above (unless a limited subset of categories is indicated) with the categories of parties listed in this section.

Subscribers

• If we obtain personal information about other individuals from a Subscriber or a Subscriber’s User then we may share such personal information with such Subscriber and its Users and such Subscriber controls how we collect and process such personal information on behalf of them

  • Our Subscribers are considered “controllers” of personal information we collect and process for them under applicable privacy laws; and our Subscribers are not considered “third parties” under applicable privacy laws or this Privacy Policy with respect to personal information we collect and process for them

  • This Privacy Policy does not control how our Subscribers use personal information, which may be different from the uses described in this Privacy Policy; we have no responsibility for how our Subscribers use personal information

Third Parties

If you provide us with your personal information, we may share your personal information with the following categories of third parties for all of our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information, subject to your exercise of your privacy rights and choices. 

If you are our Subscriber, you authorize us to share the personal information of others that we process on your behalf with the following categories of third parties (except for parties for marketing purposes) for all of our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information (except for the purposes of marketing or improving our Services and Platform).  Neither the foregoing authorization, nor any other provision of this Privacy Policy, is a waiver of the attorney-client privilege or any other applicable privilege.

We share personal information with the following categories of third parties:

• Our affiliates for purposes consistent with this Privacy Policy   

• Our vendors who provide us with services and products that help us provide the Services and the Platform or operate our business, including hosting, technology, and communication providers; cyber security and other security providers; mailing and marketing providers; e-discovery and data room providers; our attorneys, advisors, auditors, and accountants; and our analytics providers

• Parties as directed by Subscribers, we may share personal information with third parties as directed by our Subscriber who is the controller for such personal information

• Parties for marketing purposes, we may share the following categories of personal information with third parties for our direct marketing purposes: contact information, professional or employment-related information (for example, job title and employer), and preference information

• Parties for legal purposes, including governmental authorities, law enforcement, courts, or other third parties in connection with any of the activities set forth in the bullet beginning with "Meet legal and compliance requirements” in the section above called, Our Business Purposes for Collecting and Sharing Personal Information

• Parties for business changes, for example, personal information that we collect may be transferred to a third party if we undergo a merger, acquisition, sale, equity or debt financing, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of the portion of our business or assets to which such personal information relates

We Do Not Sell or Share Your Personal Information for Targeted Advertising  

We do not sell personal information. For purposes of this Privacy Policy, “sell” means the disclosure of personal information to a third party in exchange for money or other valuable consideration.

We do not share personal information with third parties for cross-contextual behavioral advertising or targeted advertising.

We do not share personal information with third parties for such third parties’ direct marketing purposes.

Retention of Personal Information

We retain personal information for as long as we deem to be necessary or advisable for our business purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information (such as providing Services to Subscribers). This may include keeping your personal information after you have stopped using our Services or Platform; for example, we may retain your personal information to market our Services to you (unless you opt-out), comply with legal obligations, resolve disputes, or collect fees owed.

Our agreements with Subscribers govern our retention and deletion of personal information we process on behalf of Subscribers.

2.    Applicability of this Privacy Policy

This Privacy Policy covers how we treat personal information that we collect from you, or in connection with our Services or Platform provided to you, or in connection with our other business or interactions with you. This Privacy Policy does not apply to personal information that we collect in connection with your employment or application for employment at Hearsay. This Privacy Policy does not cover, and we are not responsible for, the policies or practices of Subscribers, Users, or third parties that you may access or be connected with through us.

Subscribers and Third-Party Links

This Privacy Policy does not cover, and we are not responsible for, the privacy policies or practices of our Subscribers or any third parties, which have their own rules for how they collect and use personal information. Please make any privacy requests directly to Subscribers or third parties with respect to personal information in their control.

Our Platform and Services may include links to third-party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share personal information. We do not endorse or control these third-party websites, plug-ins, and applications and are not responsible for their privacy practices or any information on their websites. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.   

Personal Information of Others You Share with Us

You may not disclose the personal information of someone other than yourself to us unless you have the other individual’s prior written consent or are otherwise authorized under applicable law to share their information with us. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including:

·       providing all applicable notices

·       receiving the proper authority or consent to allow us to collect, store, process and share such personal information

·       responding to data subject requests

Personal Information of Children

We do not collect any personal information directly from children under 18 years of age. As a parent or guardian, you may provide or make available personal information of your children to us, and, by doing so, you agree and consent to our collection and use of your children’s personal information.

If you are a child under the age of 18, please do not attempt to use our Platform or Services or send us any personal information. If we learn we have collected personal information directly from a child under 18 years of age, we will delete that data as quickly as possible.

To our knowledge, we do not sell, or share for cross-contextual behavioral advertising or targeted advertising purposes, the personal information of children under the age of 18.

3.    Your Privacy Rights and Choices

Notice of Your Personal Information Rights

With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to:

(1)            Know or access – request that we disclose certain information to you about our collection and use of your personal information:

●      Whether or not we are processing your personal information

●      The categories of your personal information we have collected

●      The categories of sources for your personal information we have collected

●      Our business purposes for collecting or sharing that personal information

●      The categories of third parties with whom we shared your personal information, identifying the personal information categories that each category of recipient obtained and the purposes for sharing your personal information

●      The specific pieces of personal information we collected about you and access to that personal information  

(2)            Data portability – request a copy of the personal information you provided to us in a portable, and, if feasible, readily usable format to be transferred to you or a third party

(3)            Deletion – request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law

(4)            Correction – request that we correct inaccurate or complete incomplete personal information

(5)            Limit use of sensitive information – request that we limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law

o   We do not use or disclose sensitive personal information (for example, government identifying numbers, account access information, racial or ethnic origin, religious or philosophical beliefs, union membership, content of mail, email, and text messages not directed at us, genetic data, or health, sex life, or sexual orientation information) for purposes other than purposes that would continue to be allowable after the receipt of a limitation request, including to provide the Services  

(6)            Object to processing – object to our processing of your personal information based on legitimate interests or for direct marketing purposes

(7)            Restriction of processing – request that we restrict or suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

(8)            Withdraw your consent to the processing of your personal information if our processing is based on your consent (without affecting the lawfulness of any processing prior to your withdrawal of consent)

(9)            Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law

Generally, we are the processor or service provider with respect to personal information obtained from or on behalf of our Subscribers. Please make any privacy requests directly to our Subscribers or third parties with respect to personal information in their control.

How to Exercise Your Personal Information Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via the method described below) that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may ask for information to verify your identity, such as name, phone number, email, and address. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request promptly within the timeframes required by applicable privacy law (usually between 15 to 45 days depending on the type of Valid Request, with the right for us to extend the response time as necessary). We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following method:

·       Send an email to: privacy@usehearsay.com

You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

In some instances, we may not be able to honor your request. For example, we may not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. We may not honor your request if we are not the controller of your personal information (for example, when our Subscriber is the controller and we are the processor or service provider for our Subscriber). We may not honor your request if it is technically infeasible for us to do so. For example, if you ask us to correct personal information that we store in an unalterable format, we may be unable to honor your request or we may offer to delete the personal information instead of correcting it. Additionally, we may not honor your request where not required to do so under applicable privacy laws. For example, we may deny a deletion request if the information is necessary for us to provide our Services or comply with our legal obligations. We may deny certain right to know requests made more than twice in a 12-month period or for information collected and disclosed more than 12 months ago. We will advise you in our response if we are not able to honor your request. 

You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.” Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

The Right to Lodge a Complaint with a Supervisory Authority (EU, EEA and UK)

Subject to applicable privacy law, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with your local data protection authority and/or competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the European Economic Area, you may find the contact details for your appropriate data protection authority on this website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office here: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/.

4.  Our Use of Cookies

Our Use of Cookies and Other Tracking Technology

Our Platform and Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “cookies”) to gather data about Users of our Platform and Services, analyze trends, and operate and improve our Platform and Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to access our Platform or Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices.

Do Not Track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our Platform and Services are not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.

Disable or Delete Cookies and Tracking Technology; Third-Party Cookies  

Disable or Delete Cookies from Your Browser or Device

You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser's menu.

You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Platform and Services and some of the Platform, Services, and functionalities may not work.

Third-Party Cookies and Resources to Opt-Out of Cookies and Targeted Advertising

We allow third parties to set and collect cookies through our Platform and Services. Please review such third parties’ privacy policies and other terms for information on their privacy practices and uses of personal information, including whether they use cookies to provide targeted and cross-contextual behavioral advertising and your options to opt-out.

We use the following third-party cookies (and may use others): 

• Google for Google Analytics

  • Please see Google’s policies here:  https://policies.google.com/privacy and https://policies.google.com/technologies/ads

  • If you do not wish for Google Analytics to gather information about how you interact with our website, please install the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout and employ it at the start of each session on our website. A cookie will be set on your browser that instructs this technology not to start for that session. Please note that the next time you access our website the analytics will be reactivated, so you will have to disable the technology each time. 

  • You have the option to manage Google's personalized ads by visiting the Google advertising center at https://myadcenter.google.com/?ref=privacy-policy.

To make choices about targeted advertisements from participating third parties, including to opt-out of receiving targeted advertisements from participating third parties, please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance at www.aboutads.info/choices.

To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/.

5.    Our Uses of Personal Information in the Last 12 Months

In the last 12 months, with respect to personal information in our control, we have collected and disclosed for our business purposes (as described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information), the following categories of personal information to our affiliates, our vendors, parties as directed by our Subscribers, parties for marketing purposes,* and parties for legal purposes (as described in the above section called, Categories of Parties Whom We Share Your Personal Information):

• Identifiers (such as, real name, alias, postal address, email address, IP address)

• Personal information described in Ca. Civ. Code § 1798.80(e) (for example, name, address, phone number, credit card number, and employment (employer and job title)

• Commercial information

• Internet or other electronic activity

• Geolocation data

• Audio, electronic, visual, or similar information

• Professional or employment-related information

• Inferences

• Sensitive personal information:

  • Mail, email, or text message contents not directed to us

*We have not disclosed to parties for marketing purposes: credit card numbers or sensitive personal information.

We have not sold personal information or shared personal information for cross-contextual behavioral advertising (or targeted advertising) in the last 12 months.

6.    Data Security and Processing

Security of Personal Information

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure, or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered, or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers.  We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.

International Transfer, Storage and Processing

We operate from the United States and the personal information we collect or receive is stored and processed in the United States and may be processed in other countries around the world subject to the provisions of this Privacy Policy.

If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of personal information to the United States or any other country in which we, our affiliates or vendors maintain facilities. You consent to the use and sharing of information about you as described in this Privacy Policy.

7.    Changes and Amendments to Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our Platform or in our Services with a new “Last Updated” date. Your continued use of our Platform or Services, or your provision of personal information to us following the posting of changes constitutes your acceptance of such changes. We encourage you to visit this page regularly for any changes.

8.    Contact; Disability Access

Contact Us

You may contact us with questions, concerns, complaints, or disputes related to this Privacy Policy and our privacy policies and practices.

·       Data Controller: No More Screenshots, Inc.

·       Phone: 310.220.0373

·       Email: privacy@usehearsay.com

·       Website: www.usehearsay.com

Disability Access

If you have a disability, you may access this Privacy Policy in an alternative format by contacting us at:

·       Email: privacy@usehearsay.com