We take your privacy very seriously. Below you will find our policy.
Effective Date: May 24 2018
Last Updated Date: August 13 2018
Qloo is a Cultural AI company focused on building deep data science about culture and entertainment domains such as music, movies, TV, dining, hospitality, fashion and more. We help our Customers in many ways, from driving greater personalization and enhanced features within digital consumer products and mobile apps to providing retail analytics and other insights, to name a few. Our business is based on providing services to our Customers related to two major categories of data: (a) entity attribute data and, (b) cultural inferences data. Entity attribute data pertains to the metadata surrounding any cultural entity, for instance, the genres of a particular music artist or the geo-coordinates of a hotel. Cultural inferences data provides anonymized probabilistic correlations regarding tastes and preferences given input signal, (“Input Signal”). Input signal is generally defined as a single instance or collection of entities, in order to get correlation data in return. For instance, for a particular music artist and restaurants (as input signal), here are the most correlated hotels.
“Customers” means anyone who uses Qloo’s API and Services and includes tech companies, fortune-500 brands, websites, and individual developers.
“Partners” are third-parties (e.g., publishers, third-party app developers) who provide data to Qloo to power the Services used by Qloo’s Customers, and includes parties that use Qloo’s application programming interface (API) to collect information; some of our Partners are also Customers of Qloo;
Depending on your relationship with Qloo, you may fall into more than one of the above categories.
Here are some basic definitions used within:
“Access Keys” means the confidential security keys provided by Qloo to Company for Company’s use of the Qloo API.
“Company Application” means the software application(s), website(s) or other interface(s) developed, owned or operated by Company to interact with the Qloo API.
“Company Trademark(s)” means all names, trade names, trademarks, service marks, domain names and logos owned by Company and used by Company in connection with Company’s products and services.
“End Vertex” means individual collections of input signals passed via Qloo’s API from Company applications to retrieve Qloo’s AI inferences.
“Input Signal” means any single input signal data which is passed from the Company Application(s) to Qloo databases via the Qloo API routes. Input signal types include individual cultural entities (i.e. a Movie, Music Artist or Restaurant)
“Qloo API” means Qloo’s application program interface(s) and any associated documentation.
“Qloo Output” means all of the correlative inferences and entity level data stored in and/or retrieved from Qloo databases, including personalized recommendations for End Vertices
“Qloo Software” means Qloo’s personal recommendation service, as provided through Qloo’s website(s), mobile application(s), and API, and any modified versions, upgrades, and associated documentation.
“Qloo Trademark(s)” means all names, trade names, trademarks, service marks, domain names, and logos owned by Qloo.
As a Data Processor Qloo Inc. is required to process data in strict accordance with the instructions provided by the Data Controller, the Company (“Controller). Our use of the data is strictly limited and our role is to act only as directed by the Controller. Qloo processes no Personally Identifiable Information (PII) from customers, and does not accept PII through Qloo’s API calls and data requests. Qloo further requests that all customers sending Input Data through the API should be pre-anonymized as prescribed by Article 6 of the GDPR such that Qloo has no ability to connect such identifiers back to any of the personal data held by our customer about that individual. Thus, when our customers transmit an anonymous identifier to the Qloo Inc. personalization service, it is doing so in a manner that prevents Qloo Inc. from having any ability to know who the user is.
Therefore the only class of data that Qloo receives is entity based and general attribute based data. For instance, an array of restaurants and music artists as input signal, or order to receive Qloo output.
Qloo uses various categories of Input Data as described below to power our Services:
Entity Arrays: When a request is made through Qloo’s API that passes an entity array through in order to receive Qloo output, Qloo reserves the right to learn from the associations between the entities. For instance, if a request is made that passes along 5 music artists (A,B,C,D,E), 2 restaurants,(F,G) a hotel (H) and a movie (I), Qloo will incorporate these anonymized vertices into our machine learning models in order to draw associations between A,B,C,D,E,F,G,H,I and further refine future Qloo Output.
Metadata: When Qloo procures data related to entity metadata, for instance the genre and director of a film, or the class and location attributes of a hotel, this content-based data is used to refine Qloo’s association between entities and help inform future output.
Qloo does not collect PII, and thus only processes anonymized entity arrays and attribute metadata. Qloo does not share individual arrays or clusters or share customer level information with any other customers, Qloo only provides Qloo Output which is generalized probabilistic inferences based on the sum total of Qloo’s AI efforts.
However, Qloo will disclose such anonymized arrays if it believes that such action is necessary to comply with applicable laws or regulatory investigations, or to respond to a court order, judicial or other government subpoena, warrant, or law.
If Qloo is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third-party entity, in any partial or total sale of assets including in the event of bankruptcy, or in any other corporate change, Qloo may transfer or assign the Customer Data as part of that actual or potential merger, acquisition, sale, or other change of control (or in connection with related due diligence).
If you provide your email address to Qloo and opt-in to receiving messages from us, we may use the email address to communicate with you. If you no longer want to receive promotional emails, please follow the unsubscribe instructions within the email.
Qloo collects User information when Users visit our Site(s) or use Qloo’s apps, and the information collected varies depending on the information relevant consent(s) provided by the User to Qloo. This is distinct from the “Input Signal” provided for by sanctioned API relationships and customers (though “Users” may also fall into the customer class).
If a User registers for a Qloo User Account, Qloo collects contact information including name and email address for account maintenance purposes.
If a User contacts Qloo via the Site’s contact page, Qloo collects contact information including name and email address so that we may respond to the User’s inquiry.
Qloo may use email addresses for marketing (if the User has opted-in to receive marketing), notifying Users of major Site and Services updates, customer service communications, copyright infringement- or defamation-related communications, or to contact Users regarding any content that they have submitted to or downloaded from the Site or Services. If you do not want to receive marketing emails, please follow the unsubscribe instructions
If a User utilizes our Services via a Qloo User Account, Qloo also collects billing information as needed to collect payment from the User.
Qloo’s server logs also automatically collect User information such as Users’ IP addresses, pages on the Site accessed by Users, browser type and language, and the date and time of visits, which helps Qloo track use of the Site and understand trends.
Qloo also works with third-party service providers, such as Google Analytics, which collect information about which site the User came from and Users’ use of the Site and our Services. Data collected via Google Analytics may be connected to other data that Qloo has about its Users. These third-party service providers may use tools such as Cookies to provide their services. These technologies may be used to assist Qloo in offering the Site, such as managing the content on the Site and understanding how Users interact with the Site. To learn more about how Google Analytics collects and processes data and the choices Users may have to control these activities, please visit http://www.google.com/intl/en/policies/privacy/partners
*To review or update your contact or billing information maintained by Qloo, you can contact us via our contact form.
Qloo may retain the User information as follows:
Contact and billing information for: (a) non-marketing business relationship management related purposes for up to 18 months after the User’s last contact with us; (b) marketing purposes for as long as the User is opted-in to marketing messages; or, (c) for other business purposes (such as legal, accounting, or auditing) for such period as Qloo considers reasonably necessary. Analytics information: up to 26 months after User’s visit is logged for analytic purposes as described in the section
However, Qloo may retain User information beyond these time periods if required by law.
Qloo may disclose User information collected on the Site(s) in limited circumstances as described below:
Qloo will disclose personal information if it believes that such action is necessary to comply with applicable laws or regulatory investigations, or to respond to a court order, judicial or other government subpoena, warrant, or law enforcement request.
Qloo may share personal information with service providers that help it operate or improve the Services.
In the event that Qloo is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third-party entity, in any partial or total sale of assets including in the event of bankruptcy, or in any other corporate change, Qloo may transfer or assign the personal information as part of that actual or potential merger, acquisition, sale, or other change of control (including during due diligence of any such transaction).
Qloo may also disclose personal information: (a) with your consent; or (b) if it believes it will help to protect Qloo, its Customers, or any other person or third party, or to enforce any legal rights.
Users are not required to provide User information to Qloo; however, Users may not be able to use all features available on the Site(s) without providing some User information. For example, in order to create a Qloo User Account, we require Users to register.
Qloo uses reasonable physical, managerial, and technical safeguards to preserve the integrity and security of any and all personal information stored by Qloo, including but not limited to advanced encryption, co-location, and regular physical as well as cloud-based backups.
Qloo does not knowingly collect personal information from children under 13 years old or from websites or online services directed to children under 13 years old. Users should not create Qloo accounts unless they are legally old enough to form a binding contract and in any case are 13 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 13 who has registered with the Site or Services, please contact Qloo to have your child’s personal information deleted.
For international Users visiting the Site, please note that any information submitted on the Site will be processed in the United States for use by Qloo and its affiliates for any of the purposes described herein. In addition, because Qloo operates globally, it may make information it gathers available to worldwide business units and affiliates. As a result, your personal information may be subject to privacy laws that differ from those in your country of residence which may provide you with fewer legal rights in relation to your personal information.
By providing and/or using any data on the Site or through Qloo’s Services, individuals hereby expressly consent to such transfers of data to the United States or other countries.
If you are an international User from the European Economic Area (“EEA”) or Switzerland, please read the remainder of this section on International visitors for more information.
a. E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield.
Qloo complies with the E.U.-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries and Switzerland. Qloo has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
If you are a resident of the EEA or Switzerland, you have the right to access the personal data that Qloo maintains about you, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please contact us at the email or address provided at Qloo contact information.
Qloo is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. In particular, Qloo is responsible under the Privacy Shield Principles if third-party controllers to whom it transfers information or third-party processors it engages to process this information on its behalf do so in a manner inconsistent with the Principles.
Qloo is subject to the investigatory and enforcement powers of the United States Federal Trade Commission,
b. What is the legal basis on which Qloo relies to process User information?
On most occasions, Qloo may process User information with the individual’s consent (e.g., when a User agrees that Qloo may place Cookies or process information that the User submits on our Site(s) for specified purposes).
On other occasions, Qloo may process User information when Qloo needs to do this to fulfil a contract (for example, for billing purposes) or where Qloo is required to do this by law.
If necessary, Qloo may also process a User’s information when it is in Qloo’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights.
c. Who is responsible for User information?
Qloo, Inc. is the data controller of personal data submitted on our Site(s).
If you have any questions or comments please contact Qloo at the contact details set out in Qloo contact information.
e. Your rights.
You may ask Qloo for a copy of your information to correct it, erase it, and to transfer it to other organizations at your request. You also have rights to object to some processing and, where Qloo has asked for your consent to process your data, to withdraw this consent. Qloo will only send marketing to you if you have indicated that you wish to receive marketing information from us. In addition, you have rights to object to direct marketing at any time. Where Qloo processes your data because Qloo has a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where Qloo can demonstrate that it has a legal requirement to process your data.
Qloo’s Site may include links to other websites, apps, and services whose privacy practices may differ from Qloo’s practices. Information collected by those companies is governed by their own privacy policies or statements.
Qloo’s Site may offer a publicly accessible blog and/or a support forum. Any information provided in any such areas may be read, collected, and used by others including the general public.
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