1. Introduction

Convergence Labs Limited (“us”, “we”, “our”, or “Convergence”) operates the website convergence.ai and related services (collectively, the “Services”). Our Services allow you to use our AI Agent as your virtual assistant, to interact with it and to instruct it to perform certain tasks on your behalf (see section 6, below, for more information).

The protection and security of your personal data are important to us. This privacy policy (“Privacy Policy”) tells you about how we use, disclose, protect and otherwise process your personal data in the context of providing our Services. It also tells you about the rights you can exercise with respect to your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in section 15 “Contact Us” below.

This Privacy Policy does not apply to personal data we process on behalf of our customers to provide services to them as a processor. For example, we may process your personal data on behalf of your employer or another organisation that has facilitated your use of our Services. In that case, such organisation will act as the controller and its privacy policy will apply to the processing of your personal data.

2. Definitions

In this Privacy Policy:

“Prompt(s)” means text commands or other instructions, queries or textual cues you provide to the AI Agent. This includes data you provided to the AI Agent for the purpose of personalising, prompting, fine-tuning or customizing the Services to a specific need or use-case.

“AI Agent” means Convergence’s AI-driven virtual assistant solution that uses artificial intelligence to perform tasks based on Prompts (defined below) for and on behalf of you.

“Output(s)” means any and all content, decisions, recommendations, interactions, actions and transactions generated or executed by the AI Agent in response to a Prompt.

3. Personal Data Collection

We collect or otherwise process the following categories of personal data. 

3.1 Personal data you provide to us

1. Account data: When you create an account to use our Services, you will provide us with your user name, first and last name, email address, phone number and password.
2. Profile information: You may provide us with profile information, to help us understand your needs and interests. For example, you may choose to tell us in what context you wish to use the Services, and what your preferences are. This will help us tailor the Services to you. 
3. Contact data and communications: If you contact us through our Services, via email, on our social media pages or otherwise, you may provide us with your name, email address, phone number, or other contact information and the content of your communications, for example your feedback.
4. Prompts. When interacting with our Services, you will provide the AI Agent with personal data, including in your Prompts and instructions for tasks or any other information you input into our Services. You have control over what personal data you provide us. This information may include personal data such as your address, name, phone number, credit card details and/or other information which you provide in your Prompts. We ask you not to provide us with sensitive personal data, such as information about your health, sex life or sexual orientation, racial or ethnic origin, religion or political beliefs.  
5. Marketing preferences: We collect information about your marketing preferencessuch as your preferences for receiving marketing emails and other communications from us and details about how you engage with our marketing.
6. Payment and Billing information: We process your payment and billing details (payment method, billing address, etc.) when you pay for our Services. We rely on a third party payment processor to do so on our behalf and we do not have direct access to your payment and billing information.
7. Job application data: When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. Throughout the recruitment process, we may supplement your personal data in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role and retain interview notes.
   1. Personal data we automatically collect

We may automatically log information about you, your computer or mobile device, and your interaction over time with the 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, 3G).
• Activity and usage data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, 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.

We collect this information using cookies and other similar technologies. For more information, please read Section 4 on “How we use cookies”.

Other third party sources. We may obtain personal data from other third parties, such as marketing and other partners, publicly-available sources and recruiters.

4. How We Use Personal Data

We use your personal data for the following purposes or as otherwise described at the time of collection:

• Providing our Services. We use personal data to operate, maintain, and provide you with our Services. In particular, we use personal data to perform our contractual obligations under our Terms of Service. This includes:

• Creating and administering your account, processing your payments and contract management;
• Allowing you to use our AI Agent to perform tasks you instruct it to perform;
• Generating Outputs based on your Prompts and displaying those Outputs to you. Our Outputs may contain personal data about you because they are based on your Prompts;
• Communicating with you about our Services. It is in our legitimate business interests to use personal data to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts and support and administrative messages.
• Personalisation. We use personal data contained in your Prompts and other interactions with the Services to help us understand your interests and to get to know you better, so we can personalize your experience with the Services, improve our Outputs and tailor them to you and your preferences.
• Training our algorithms. It is in our legitimate business interest to use personal data to develop, analyse and improve the Services including by training our models and algorithms. As part of these activities, we may create or use aggregated, de-identified or other anonymised data from personal data we collect. We may anonymize data by removing information that makes the data personally identifiable to you. We may use this anonymised data and share it with third parties for our lawful business purposes, including to analyse and improve the Services and promote our business.
• Content moderation and monitoring. We use your personal data to monitor abuse and to moderate the content of your Prompts and the AI Agent’s Outputs. We also allow you to report illicit Outputs. In that case, we may use personal data contained in such Outputs to process and address your report.
• Improving, monitoring, and protecting our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:
• Aggregating data and conducting statistical research;
• Troubleshooting and testing to keep the Services secure; and
• investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
• Enrichment. It is in our legitimate business interests to use personal data we obtain from third party data providers to enrich and to verify personal data we process on behalf of our customers to provide our Services to them.
• Marketing and advertising. We and our service providers may collect and use personal data for direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below. Except where consent is required, we undertake such marketing on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.

• Job application processing. When you apply for a job with us, we use your personal data in our legitimate interest to facilitate our recruitment activities, process employment applications and personalize candidate communication, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to take steps to enter into an employment contract and to administer the employment relationship.

• Compliance and protection. We may use personal data to comply with legal obligations, and it is in our legitimate business interests to use your personal data to defend Convergence against legal claims or disputes, including to:
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Services;
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to requests from government authorities.
  

5. How We Use Cookies

5.1 What are cookies?

Cookies are text files that we store and access on your device to uniquely identify your browser or to store information or settings in the browser to allow us distinguish you from other users of our Services, to help you navigate between pages efficiently, remember your preferences, enable functionality, to help us understand activity and patterns, and to facilitate online advertising. We also use the below similar technologies:

• Local storage technologies, like HTML5, 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, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

This Privacy Policy refers to all these technologies, and other types of tracking technologies used through our Services, collectively as “cookies.”

• How do we use cookies?

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. We use persistent cookies, for example, to record your choice of language and country location. The cookies placed through your use of our website are either set by us (first-party cookies) or by a third party at our request (third-party cookies). The maximum duration of the cookies we use is 2 years.

• What types of cookies and similar technologies do we use?

We use the following categories of cookies:

• Essential cookies: These cookies are required to enable basic website functionality. They cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Services may not work.
• Functional cookies. These cookies allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features.
• Analytics cookies. These cookies help us understand how the Services perform, how visitors interact with the Services, and whether there may be technical issues. This storage type usually doesn’t collect information that directly identifies a visitor.

How can you control the use of cookies?

You will be presented with a cookie banner or other tool to provide permissions prior to non-Essential cookies being set. We only set these non-Essential cookies with your consent.

You can also limit online tracking byblocking cookies in your browser. Most browsers let you remove or reject 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 www.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 (Mac); Safari (Mobile/iOS)
• Platform opt-outs. Some of our partners offer opt-out features that let you opt out of use of cookies. For example, for third party cookie opt-outs: Google Analytics (here).

Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly.

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 can 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.

6. Artificial Intelligence

Convergence leverages third-party AI technology provided by our service providers. This technology is trained to generate intelligent and personalized responses in conversations with you and when performing tasks on your request. Its Outputs are based on information collected through the Services, including your Prompts. For example, if you ask our AI Agent a question or if you instruct it to perform a task for you, its actions and responses will be personalised to you, based on information you previously provided through the Services.

Convergence shares your information with the AI service providers that power Convergence. They will use your personal data to respond to and action your prompts and instructions.

7. How we Share and Disclose Personal Data

We may share the categories of personal data described above with the following categories of third parties:

• Vendors, and Service Providers: To assist us in meeting business operational needs and to perform certain services and functions, we may share personal data with our vendors and service providers, including providers of AI technology, hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store personal data in the course of performing their duties for us.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively, a “Transaction”), your personal data and other information may be shared in the due diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in our good faith belief that such action is necessary, we may share personal data to: (i) comply with a legal obligation, including to meet national security or law enforcement requirements; (ii) protect and defend our rights or property; (iii) prevent fraud; (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public; or (v) protect against legal liability.
• Affiliates: We may share personal data with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with, Convergence. Our affiliates will use the personal data we share in a manner consistent with this Privacy Policy.

8. Retention of Personal Data

We generally retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. When determining the relevant retention periods for your personal data, we take into account the following factors: (a) any permissions you give us with regards to your personal data; (b) our contractual obligations and rights in relation to the personal data involved; (c) our legal obligations under relevant laws to retain data for a certain period of time; (d) our legitimate business and commercial interests; (e) whether retention is advisable in light of our legal position (such as with regard to applicable statute of limitations, investigations, litigation, and other potential and actual disputes); and (f) any guidelines issued by relevant data protection authorities.

Note, in some circumstances, we may anonymise your personal data such that it can no longer be associated with you.

9. Children

Our Services are not directed to children who are under the age of 18. We do not knowingly collect personal data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided personal data to us through our Services, please contact us and we will endeavour to delete that information from our databases.

10. Links to Other Websites

Our Services may link to other websites not operated or controlled by us, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

11. Security

We implement commercially reasonable technical, administrative, and organisational measures to protect personal data both online and offline from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via the Services or email. Please keep this in mind when disclosing any personal data to us via the internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third party websites.

12. International Transfers

We are based in the United Kingdom (“UK”). We may also share your personal data with our affiliates and service providers outside of the UK. Such countries may not have laws that provide the same level of protection for your personal data as in your country of residence. When we share your personal data, we endeavour to keep it confidential and secure. For example, where required under European Economic Area and UK data protection laws, we will implement appropriate safeguards, such as European Commission-approved standard contractual clauses and/or UK government-approved international data transfer agreements. Please contact us using the details in the “Contact Us” section below if you require further information on our international transfers.

13. Your Choices

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you.

Personal data requests. We may offer you choices that affect how we handle the personal data that we control. Where required under the laws that apply in your place of residence, you may request the following in relation to your personal data:

• Access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details.
• Data Portability: You may request to receive personal data in a structured, commonly used and machine-readable format and (if certain conditions are satisfied), transmit that personal data to a third party, if we have the technical means.
• Withdraw Consent: In circumstances where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw consent for that specific processing at any time.
• Objection/Restriction: You may also ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to us processing it. If you exercise your rights, we will respect your decision in accordance with our legal obligations.
• Correction: You may request the correction of personal data that is inaccurate or out of date.
• Deletion:You may requestion the deletion of personal data that we no longer need to provide the Services or for other lawful purposes.

To make a request, please use the contact details provided in the “Contact Us” section below.

All requests must be made by you or someone legally authorised to act on your behalf. We must be able to verify your identity and confirm that the personal data relates to you in order to respond to your request and/or provide you with personal data.

In some instances, your choices and rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Please note, if you have a concern about our privacy practices, including the way we handle your personal data, you can report it to your local data protection authority; in the UK, this is the Information Commissioner’s Office (ICO). We hope you will be able to address any concerns with us directly in the first instance.

14. Changes to the Privacy Policy

The Services and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version, unless another type of notice is required by the applicable law.

15. Contact Us

Convergence Labs Limited is the controller of your personal data. If you have any questions about our Privacy Policy or data practices, please feel free to contact us by email at data.requests@convergence.ai or by mail at 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.