Privacy Policy

nSpire AI, Inc. (“nSpire”, “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://nspire.ai and use our services.

Personal information we collect

Information you provide to us

  • Account information, such as your first and last name, phone number, and email.
  • Services information, such as your resume, image and video content, biography, and other information you may upload or provide to us in connection with your use of the Services.
  • Payment information, such as payment card numbers or other financial information used to make payments directly with us. We do not process your payment information directly and instead use a third party payment processor.
  • Biometric information, such as information we analyze to determine your facial expressions during the coaching process. We do only process this biometric information in a transient manner to categorize your facial expressions and interactions and do not store any biometric information. We do not use such information to identify you or for any other purposes other than to provide you with our Services.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Marketing information, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection

We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our services, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Tools for automatic data collection

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use personal information

To operate our services

  • Provide, operate, and improve our services and our business;
  • Communicate with you about our services, including by sending announcements, updates, security alerts, and support and administrative messages;
  • Provide support, and respond to requests, questions, and feedback.

For research and development

To analyze and improve our services and to develop new products and Services, including by studying use of our services. We will not use your biometric information for these purposes.

For direct marketing

We may from time-to-time send you direct marketing communications via email or text message as permitted by law, including, but not limited to, and notifying you of special promotions and offers. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

To comply with law

As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety

To: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To create de-identified data

To create aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve our services, conduct research, and promote our business.

Lawful basis for processing

Under the laws of certain countries, including the UK and countries in the European Economic Area (“EEA”), we may be required to have a lawful reason or justification to be able to process your personal information (this is also called a “lawful basis”). For the processing of your personal information under this Privacy Policy, we generally rely on our “Legitimate Interests” as the lawful basis for processing (this simply means processing your personal information is necessary for our commercial interests, your interests or the interests of a third party and we have carried out an assessment to ensure this is not unfair to you). However, where we send you direct marketing communications or process your personal information through the use of cookies (or similar technologies) as described above, where required under the relevant laws in your country, we rely on your “Consent” as the lawful basis for processing such personal information. We will also rely on our “Legal Obligation” as the lawful basis for processing where any laws that apply to us require that we process your personal information. Our disclosure of Google Information is described above.

How we share personal information

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our services (such as customer support, hosting, analytics, email delivery, marketing, payment processing, and database management services).

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

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

How you share personal information

With other users. You may choose to share your information with other users on the platform that you provide access to with your information. For example, if you are a student, you may decide to share access to certain information with advisors from your school.

Cross-border processing of your personal information

nSpire is headquartered in the United States. To provide and operate our Services, it is necessary for us to process your personal information in the United States. If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so.

In some cases, your personal information may be transferred to countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we transfer personal information of individuals from the European Economic Area (EEA), the UK, or Switzerland, where a safeguard is required under law for the transfer of such personal information, we currently rely on the European Commission-approved standard contractual data protection clauses (for EEA and Switzerland transfers) and the UK government approved international data transfer agreement/addendum (for UK transfers) for data transfers to the United States. Please contact us for further information on the safeguards in place.

Your choices

Access or update your information

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct information in our possession that you have previously submitted via our services.

Personal information requests

In certain circumstances (including based on where you are located), you may have the following rights in relation to your personal information:

  • The right to learn more about what personal information of yours is being processed, how and why such information is processed and the third parties who have access to such personal information. We have made this information available to you without having to request it by including it in this Privacy Policy;
  • The right to access your personal information;
  • The right to rectify/correct your personal information;
  • The right to restrict the use of your personal information where permitted under applicable law;
  • The right to request that your personal information is erased/deleted where permitted under applicable law;
  • The right to data portability (i.e. receive your personal information or have it transferred to another controller in a structured, commonly-used, machine readable format) where permitted under applicable law; and
  • The right to object to processing of your personal information or to direct us not to share your personal information with a non-affiliated third party where permitted under applicable law.

To make a request, please email us as provided in the “How to contact us” section below. We may ask for specific information from you to help us confirm your identity. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

In addition, where you have provided your consent to processing for the purposes indicated above, you may withdraw your consent at any time (or otherwise exercise your aforementioned rights in relation to your personal information) by contacting us below (see contact details below).

Please note that in some circumstances, we may not be able to fully comply with your request, for example if we are required to retain certain information about you to comply with applicable laws and regulations or if the information is necessary in order for us to provide the services you requested. We will not deny you access to our services, or provide you a lower quality of services if you exercise your rights.

You also have the right to lodge a complaint with the relevant authority (as applicable) or a supervisory authority in the UK or EU member state of your usual residence or place of work or of the place of the alleged breach, if you consider that the processing of your personal information carried out by nSpire or any of our affiliates or third-party service providers, has breached data protection laws. Individuals and data protection supervisory authorities in the EU and the UK may contact our data protection representatives according to Articles 27 EU and UK GDPR.

You may also appeal to certain courts against (A) any failure of the relevant authority to give written notice of whether the complaint is either being investigated or not being investigated and, where applicable, the progress and the outcome of the investigation or (B) a determination of the relevant authority not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.

Opt out of push notifications

If you opt-in to receive push notifications within the app, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the application, or deleting the application.

Opt out of marketing communications

You may opt out of marketing-related emails or texts by following the opt-out or unsubscribe instructions at the bottom of the marketing communication we send you, or by contacting us as specified below. Even if you opt out of marketing-related communications, you may continue to receive service-related and other non-marketing communications.

Online tracking opt-out

There are a number of ways to opt out of having your online activity and device data collected through our services, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject third-party cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.

Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari

  • Google Analytics. We use Google Analytics to help us better understand how people engage with our services by collecting information and creating reports about how users use our services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
  • Using privacy plug-ins or browsers. You can block our services from setting third-party cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

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

Other sites, mobile applications and services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party.

In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security practices

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Retention

We retain your personal information for as long as appropriate to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Children

Our services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our services.

How to contact us

Please direct any questions or comments about this Policy or privacy practices to support@nspire.ai or write to us at: 95 Third Street, 2nd Floor, San Francisco, CA 94103