Please click here for a printable PDF version of this notice.
This Privacy Policy applies to:
- Loti AI Inc. and our affiliates (“Loti,” “Company,” ” “we,” “us,” “our”).
- Loti’s website at https://lotiai.com (the “Website”).
- Loti’s products and services (the “Service”).
This Privacy Policy applies when You interact with us through our Site and Service. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Website or Service or be linked to from the Website or Service. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites, applications, or services. Please review the privacy policies of those third parties directly to understand their privacy practices.
For purposes of this Privacy Policy:
- Likeness means the Subscriber’s biometric face and voice signatures that are each abstract, non-geometric, numerical representations of the Subscriber’s face or voice that are associated with each Subscriber’s identifying information.
- Service means Loti Software as a Service (SaaS) services, including but not limited to artificial intelligence (AI) software for detecting use of Subscriber’s likeness in internet content, including unauthorized, manipulated and fabricated media such as deepfakes and AI-generated images.
- Subscriber refers to an individual who has signed and agreed to Loti’s Terms of Service and Biometric Data Privacy Policy and is an authorized user of the Service.
- You refers to the individual accessing or using the Website or Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Website or Service, as applicable.
Subscribers only: By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Please see our separate Biometric Data Policy here for information about the collection, use and disclosure of Your biometric data by the Service.
Information We Collect
We collect information from You directly, from the devices You use to interact with us, and from third parties. We may combine information from the Website and Service together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.
Information you give us
While using our Service, we may ask You to provide us with certain information that can be used to contact or identify You, such as:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Audiovisual information, such as audio recordings, photographs, and video
In order to use the Service, you must provide us with Your biometric data so we may track the unauthorized uses of Your voice and image across the internet and pursue their removal at your direction. Please see our Biometric Data Policy here.
You may also provide the following information to us directly:
- Payment information, including credit card information
- Information contained in your communications to us
- Any information or data you provide by interacting in our online forums and chatrooms, or by commenting con content posted on our Website or Service, which are also visible to other users of our Website and Service
- Your use of our Website and Service
- Any other information you submit to us
Information we collect automatically
We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device You use to interact with our Website and Service. We also create records when You make purchase or otherwise interact with the Service.
- Device information, such as Internet Protocol address (e.g. IP address), device identifiers, browser type, browser version, the pages of our Website and Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data
- Analytical information, including details about Your interaction with our Website and Service, and electronic newsletters
- Diagnostic information, including web traffic logs
- Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to You. Please note that our advertising partners may collect information about You when You visit third-party websites or use third-party apps They may use that information to better target advertisements to You on our behalf.
- Business record information, including records of your purchases of products and services and use of our Website and Service
The following is a list of partners who collect the information described above. Please follow the links to find out more information about the partner’s privacy practices.
Tracking Technologies and Cookies
We use cookies and similar tracking technologies to track the activity on our Website and Service and to store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:
- Cookies. A cookie is a small file placed on Your device. You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some parts of our Website and Service. Unless you have adjusted Your browser setting so that it will refuse cookies, our Website and Service may use cookies.
- Flash cookies. Certain features of our Website and Service may use local stored objects (or flash cookies) to collect and store information about Your preferences or Your activity on our Service. Flash cookies are not managed by the same browser settings as those used for browser cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
- Web beacons. Certain sections of our Website and Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" in duration. Persistent cookies remain on Your personal computer or mobile device when You go offline, while session cookies are deleted as soon as You close Your web browser. Cookies are also either first-party or third-party (the “provenance”). First-party cookies are put on Your device directly by us, while third-party cookies are placed on Your device by a third-party (such as an advertiser or analytics provider).
We use the following types of cookies:
Information we collect from other sources
We may collect the following information about You from other sources:
- We obtain information from service providers, such as third-party vendors engaged to monitor and analyze the use of our Service, to deliver targeted advertising to You, for payment processing, or to otherwise provide the Website and Service to You
- We receive information from online advertising companies about Your interaction with advertisements on our Website or ads that we place on third party websites
How We Use Your Information
We may use any of the information we collect for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To improve our Service: to improve and grow our Service, including to develop new products and services and understand how our Site and Service are being used, our customer base and purchasing trends, and the effectiveness of our marketing.
- To manage Your Account: to manage Your registration as a user of the Service. The information You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with us through the Service.
- To contact You: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: to attend and manage Your requests to us.
- To deliver targeted advertising to You: we may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
- For business transfers: we may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about our Service users is among the assets transferred.
- Security: to protect and secure our Site and Service, assets, network, and business operations, and to detect, investigate, and prevent theft, unauthorized use, or abuse of the Site or Service and other activities that may violate our policies or be fraudulent or illegal.
- Legal compliance: to comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal and regulatory requirements.
Notwithstanding the above, we use Your biometric data solely for purposes of providing the Service, as described in our Biometric Data Policy available here.
How We Share Your Information
We may share any of the information we collect in the following situations:
- With service providers: We may share Your information with vendors we engage to perform specific business functions on our behalf, such as to monitor and analyze the use of our Service, for payment processing, and to contact You. These vendors are obligated by contract to use information that we share only for the purpose of providing the requested service.
- With Online Advertising Partners: We may share your information with companies We partner with to assist us in advertising our Service, including partners that use cookies to collect information to personalize, retarget, and measure the effectiveness of advertising.
- For business transfers: We may share or transfer Your information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. We will provide notice before Your personal information is transferred and becomes subject to a different privacy policy.
- With affiliates: We may share Your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- With business partners: We may share Your information with our business partners to offer You certain products, services or promotions.
- To Government entities/law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- For legal purposes: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
Protect against legal liability
- With Your consent: We may disclose Your information for any other purpose with Your consent.
Notwithstanding the above, we share Your biometric data only as described in our Biometric Data Policy available here.
Other Important Information
Your Account
Please visit Your account page to update your account information.
Data Retention
We will retain Your information as long as we have a legitimate business need for it, including to the extent necessary to comply with our legal obligations (for example, if we are required to retain information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
We will retain Your biometric data as described in our Biometric Data Policy available here.
Cross-Border Data Transfer
Your information is processed at our operating offices and in any other places where the parties involved in the processing are located, including the United States and other countries. This means that Your information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Any such transfers will comply with safeguards as required by relevant law.
Data Security
The security of Your information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your information, We cannot guarantee its absolute security.
Email Marketing
We may use Your information to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Payments
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to our third-party payment processors whose use of Your personal information is governed by their privacy policy and adhere to the PCI-DSS requirements to help ensure the secure handling of payment information.
Ad Choices
You have options to limit the information that we and our partners collect for online advertising purposes. Please note that any browser-based opt-out tool, feature, or setting is specific to the browser You use. You may need to opt-out on every browser that You use.
- You may disable cookies in Your browser or mobile using their settings menus. Your mobile device may give You the option to disable advertising functionality. Because we use cookies to support Website and Service functionality, disabling cookies may also disable some elements of our online properties.
- The following industry organizations offer opt-out choices for companies that participate in them:
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform http://www.youronlinechoices.com/
- The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
- You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
- You may contact us directly.
If You exercise these options, please be aware that You may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to You.
If You delete Your cookies, You may also delete Your opt-out preferences.
EEA, Switzerland, and UK Privacy Disclosures
We process “personal data” as that term is defined in the European Union’s General Data Protection Regulation (GDPR). The controller of Your personal data for purposes of the GDPR is Loti AI Inc. at 100 N Howard St #6321, Spokane, WA 99201.
Legal Basis for Processing Personal Data
We may process personal data under the following conditions:
- Consent: You have given Your consent for processing personal data for one or more specific purposes. We process Your biometric data only with Your explicit consent, unless an exception applies. You have the right to withdraw Your consent to future processing at any time, but please note that if You withdraw Your consent, we may not be able to provide You with access to certain specific functionalities of the Website or Service.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
- Vital interests: Processing personal data is necessary in order to protect Your vital interests or of another natural person.
- Legitimate interests: Processing personal data is necessary for the purposes of the legitimate business interests pursued by us or another third party.
Your Rights Under the GDPR
If You are within the EU, Switzerland, or the U.K., you have the right to:
- Access and Portability. Request access to personal data we hold about you or request transmission of your data to a third party.
- Correction. Request that we rectify inaccurate or incomplete personal data we store about You.
- Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when You withdraw consent and no other legal basis for processing exists, or when You believe that Your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
- Object to processing. Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override Your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
- Restrict processing. Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purpose for which it was collected but is needed by You for the establishment, exercise or defense of legal claims; or if Your request to object to processing is pending evaluation.
- Transfers. Obtain information about and a copy of the safeguards we use to transfer personal data across borders.
You may exercise these rights by contacting us as described below. Please note that we may ask You to verify Your identity before responding to such requests. Whenever made possible, you can also access, update or request deletion of Your personal data directly within Your account settings section. If you are unable to perform these actions yourself, please contact us to assist You.
You also have the right to complain to a data protection authority about our collection and use of Your personal data. For more information, please contact Your local data protection authority.
California Privacy Disclosures
California “Shine the Light” Law
California residents with an established business relationship with us are entitled to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for the third parties’ direct marketing purposes in the preceding calendar year. Please contact us to obtain this information.
California Privacy Rights for Minor Users
California residents under the age of 18 who are registered users of online sites, services or applications may request and obtain removal of content or information they have publicly posted. To request removal of such data, please contact us and provide the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
California Consumer Privacy Act
The California Consumer Privacy Act (CCPA) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on Your exercise of Your CCPA rights. If we collect personal information subject to the CCPA, that information, our practices, and your rights are described below. The information provided in this section applies only to California residents and supplements the information contained in our Privacy Policy.
Notice of Collection
You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The table also summarizes the categories of “sensitive” personal information that we collect, the purpose for which such information is used, and whether we sell or share such information. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “How We Use Your Information.”
We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.
Entities to whom we “sell” or with whom we “share” information are third parties. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. Under the CCPA, a business “sells” personal information when it discloses the information to a third party for monetary or other benefit, and a business “shares” personal information when it discloses the information to a third party for purposes of cross-context behavioral advertising.
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell or share the personal information of individuals we actually know are less than 16 years of age, unless we receive affirmative authorization (“opt-in" consent) either from the individual between 13 and 16 years of age, or from the parent or guardian of an individual less than 13 years of age.
Individuals who opt-in to the sale or sharing of personal information may opt-out of future sales or sharing at any time. To exercise the right to opt out, You (or Your authorized representative) may submit a request by contacting Us.
Your Rights Under the CCPA
- The right to know and request access to and correction or deletion of personal information. You have the right to request access to personal information collected about You and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about You and to delete personal information that we have collected directly from You. Please contact us to exercise these rights as described below.
- The right to opt-out of the sale or sharing of personal information. You have the right to direct Us to not sell or share Your personal information. To exercise this right, please visit our Do Not Sell or Share My Personal Information webpage or contact us by email as described below. Your right to opt out does not apply to our disclosure of personal information to service providers.
Exercising Your CCPA Rights
In order to exercise any of Your rights under the CCPA as a California resident, You can contact Us:
- By email: support@goloti.com
- By telephone: (888) 970-5684
If You are submitting an email to exercise the right to know and access, correct, or delete, Your request to Us must:
- Provide sufficient information that allows us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
- If you are an authorized agent, provide proof that the consumer gave you signed permission to submit the request
We cannot respond to Your request to know, access, correct, or delete, or provide You with the required information if We cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will not use personal information we collect in connection with verifying or responding to Your request for any purpose other than responding to Your request.
We may have a reason under the law why we do not have to comply with Your request, or why we may comply with it in a more limited way than You anticipated. If we do, we will explain that to You in our response.
"Do Not Track" Policy
We respond to the Global Privacy Control signal for U.S. residents. However, we do not respond to “Do Not Track” signals because there is no formal “Do Not Track” standard. Please click on the link below to learn more about enabling the Global Privacy Control: https://globalprivacycontrol.org/#download.
Children’s Privacy
The Service is intended for users who are 13 years old and older. We do not knowingly collect information from children. If You are a parent or guardian and You are aware that Your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, we may require Your parent’s consent before we collect and use that information.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us by email at support@goloti.com.
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