Twelve Labs Inc. (“Twelve Labs,” “we,” “our,” and/or “us”) values and respects your privacy. We have prepared this privacy policy (“Privacy Policy”) to explain the manner in which we collect, use, disclose, and otherwise process personal information through (a) our website, including software products and services offered by Twelve Labs on its website platform located at www.twelvelabs.io (the “Twelve Labs Website”); (b) any mobile device software provided by us to you (the “Twelve Labs Application”); (c) any application programming interfaces and accompanying documentation and materials (the “Twelve Labs APIs”); (d) any text, pictures, media, data, information and other materials or content (collectively, the “Content”) contained on or provided through the foregoing (a), (b), or (c); and (e) all other Content, products or services provided by us to you, as more particularly described on the Twelve Labs Website and the Twelve Labs Application (collectively, the “Twelve Labs Services”). As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. By using the Twelve Labs Services, you agree to the collection, use, disclosure, procedures, and other processing described in this Privacy Policy. Beyond the Privacy Policy, your use of the Twelve Labs Services is also subject to our Terms of Use.

This Privacy Policy does not apply to the extent we process personal information in the role of a processor or service provider on behalf of our customers, including where we offer to our customers the Twelve Labs Services.  In that context, our customers are the data controllers, and our processing of that personal information is governed by our applicable customer contracts.

COLLECTION AND USE OF PERSONAL INFORMATION

Personal Information Collected Through the Twelve Labs Services: 

We may collect the following types of personal information in order to provide the Twelve Labs Services to our customers: 

• We may collect image, text, videos, information, content records, files, or other materials that our customers load, receive through, transmit to, input or otherwise enter into the Twelve Labs Services, or that customers otherwise transmit to Twelve Labs in connection with the use of our Services, but excluding Account Information (“Customer Data”).

• We use Customer Data to facilitate the customer’s use of the Twelve Labs Services and improve the Twelve Labs Services.

• We may also collect the information and any results from Customer Data, including generated video captions, lists of semantic search matches, and numeric video and text vector representations (the “Output”) in order to facilitate your use of the Twelve Labs Services and to improve the Twelve Labs Services.

We rely on our customers to comply with applicable privacy laws when collecting, using, or disclosing personal information through the Twelve Labs Services, including by obtaining appropriate consent to collect, use, and disclose personal information through the tools. If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to contact the customer directly and/or review their applicable privacy policy. If you signed-up to receive marketing communications from one of our customers and now wish to unsubscribe, please contact the customer directly.

Personal Information Collected Through the Twelve Labs Website and Other Interactions With You:

We may collect personal information about you when you:

• Create an account

• Book a demo

• Sign-up to receive marketing emails such as newsletters and blog posts

• Participate in our surveys

• Join our events, online community, or interact with us on social media

• Apply for a job

• Contact us with a comment, question or complaint

• Visit the Twelve Labs Website

Requesting Access to the Twelve Labs Services: Before accessing or using the Twelve Labs Services, you may be asked to complete the Twelve Labs API Application (the “API Application”). As part of this API Application, we will collect your business contact information, information about your organization (including the type of organization and the jurisdiction in which it is located), and information about your intended use of the Twelve Labs Services (including a description of your use case, your previous experiences using similar services, and estimates of the frequency with which you will use the Twelve Labs Services).  We use this information to understand the purposes for which you are seeking to use the Twelve Labs Services, to assess whether the Twelve Labs Services are right for your organization and the intended purposes, and to customize your user experience.

Creating an Account: If your API Application is approved, you will be required to create an account in order to access and use the Twelve Labs Services. To create your account, we may collect personal information such as your first and last name, email address and a password that you create. We may also request and collect other information in order to verify your identity. Any information about you that you provide to us in connection with the creation, administration or use of your Twelve Labs account is “Account Information.” We use Account Information to create and administer your account and facilitate your access to and use of the Twelve Labs Services. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately as detailed in the Terms of Use. 

Purchases: We may collect personal information and details associated with your purchases, including payment information. Any payments made via the Twelve Labs Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through the Twelve Labs Services, but we may receive information associated with your payment card information (e.g., your billing details).

Marketing Communications: We may send you communications (including by mail and email) regarding our platform and other products and services that we believe are of interest to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us after you unsubscribe.

Business Development and Strategic Partnerships: We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance the Twelve Labs Services.

Interactive Features: We and others who use the Twelve Labs Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Twelve Labs Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

Employment: If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing, evaluating and responding to your application.

Conferences, Trade Shows, and Other Professional Events: We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings. 

Visiting the Twelve Labs Website: In general, you can visit the Twelve Labs Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to the Twelve Labs Website and other related information such as page requests, browser type, operating system and average time spent on the Twelve Labs Website. We use this information to help us understand the Twelve Labs Website activity and to monitor and improve the Twelve Labs Website.

Cookies and other Technologies: The Twelve Labs Services uses "cookies," pixel tags and other technologies (“Technologies”) to automatically collect information through your use of the Twelve Labs Services. A cookie is a tiny element of data that the Twelve Labs Services sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Twelve Labs Services, you may not be able to take advantage of all of the Twelve Labs Services features.  A pixel tag (also known as a web beacon) is a piece of code embedded in the Twelve Labs Services that collects information about engagement on the Twelve Labs Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Below is an overview of the types of cookies we and third parties may use to collect information:

• Strictly Necessary Cookies:  Some cookies are strictly necessary to make the Twelve Labs Services available to you.  We cannot provide you with the Twelve Labs Services without this type of cookies. 

• Functional Cookies:  Functional cookies are used to recognize you when you return to the Twelve Labs Services.  This enables us to adapt our content for you and remember your preferences.  For example, we use functional cookies to remember your choice of language or region. 

• Analytical and Performance Cookies: We also use cookies for website analytics purposes to operate, maintain and improve the Twelve Labs Services.  These providers may also collect information about your use of other websites, apps, and online resources.  We may use a third party such as Google Analytics, LinkedIn Analytics, Mixpanel, or any other analytics services and technologies to help us gather and analyze information about the areas visited on the Twelve Labs Services (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Twelve Labs Services. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links: https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/answer/181881?hl=en.

• Advertisement Cookies: We also use cookies for advertisement purposes to provide visitors with customized advertisements based on the pages you visited previously, and to analyze the effectiveness of the ad campaigns.

Additional Uses of Personal Information: We may also use any of the personal information we collect as permitted under applicable laws.

DISCLOSURE OF PERSONAL INFORMATION

We do not disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law. 

Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as cloud computing, data storage, publishing, and analytics. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the US, The Republic of Korea (ROK), or other foreign jurisdictions. 

AI Service Providers: We may disclose information we receive to vendors that provide artificial intelligence services that provide backend support for the Twelve Labs Services.

Business Partners: We may disclose your personal information with business partners to provide you with a product or service you have requested. We may also disclose your personal information with business partners with whom we jointly offer products or services.

Affiliates: We may disclose any information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy.

Legal and Compliance: We and our US, Republic of Korea, and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Republic of Korea , U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Advertising Partners: We may disclose your personal information with third-party advertising partners. These third-party advertising partners may set Technologies (defined below) and other tracking tools on the Twelve Labs Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Twelve Labs or as part of a corporate reorganization or other change in corporate control. 

Consent: We may also disclose your information with your permission. 

LEGAL BASES FOR PROCESSING EUROPEAN PERSONAL INFORMATION

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your personal information when we have a valid “legal basis,” including as set forth below. 

• Consent: We may process your personal information where you have consented to certain processing of your personal information.  For example, we may process your personal information to send you marketing communications or to use cookies where you have consented to such use.

• Contractual Necessity: We may process your personal information where required to provide you with the Twelve Labs Services.  For example, we may need to process your personal information to respond to your inquiries or requests.

• Compliance with a Legal Obligation: We may process your personal information where we have a legal obligation to do so. For example, we may process your personal information to comply with tax, labor and accounting obligations.

• Legitimate Interests: We may process your personal information where we or a third party have a legitimate interest in processing your personal information. Specifically, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Twelve Labs Services.  We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.

YOUR PRIVACY CHOICES AND RIGHTS 

Your Privacy Choices: The privacy choices you may have about your personal information are determined by applicable law and are described below. 

• Email Communications: You can unsubscribe from our promotional emails using the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Twelve Labs Services you have requested. We may also send you certain non-promotional communications regarding us and the Twelve Labs Services, and you will not be able to opt out of those communications (e.g., communications regarding the Twelve Labs Services or updates to our Terms of Use or this Privacy Policy).

• Text Messages: You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

• Do Not Track: “Do Not Track” (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Personalized Advertising: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Twelve Labs Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your European Privacy Rights: If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the personal information we maintain about you, update, and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have your personal information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal information to another company. 

• You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you believe our processing of your personal information violates applicable law, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. 

• EEA Data Protection Authorities (DPAs)

• Swiss Federal Data Protection and Information Commissioner (FDPIC)

• UK Information Commissioner’s Office (ICO)

THIRD PARTY LINKS

The Twelve Labs Website may contain links to other websites that Twelve Labs does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

RETENTION

We have record retention processes designed to retain personal information for as long as you use the Twelve Labs Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Twelve Labs Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

SECURITY

We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain.  However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information. 

INTERNATIONAL VISITORS

The Twelve Labs Services are hosted in the United States. If you choose to use the Twelve Labs Services from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may transfer personal information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Twelve Labs Services. By providing any information, including personal information, on or to the Twelve Labs Services, you consent to such transfer, storage, and processing. For more information about the tools that we use to transfer personal information, or to obtain a copy of the contractual safeguards we use for such transfers (if applicable), you can contact us as described below.

CHILDREN’S INFORMATION

The Twelve Labs Services are not directed to children under 18 and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

UPDATES TO THE PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Twelve Labs Services after the new Privacy Policy takes effect.

CONTACT US

Twelve Labs is the data controller and is responsible for processing your personal information. If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers treat your personal information, or to request access to our collection of your personal information, please contact us at: