Privacy Policy

Introduction

This Privacy Policy describes how FluentData, Inc., a Delaware corporation, and its affiliates ("FluentData", "we", "us") collect, use and protect personal information when you visit dotdash.dev (the "Site") and when you use the dotDash platform (the "Service").

FluentData understands that your privacy matters. We are committed to protecting it and the personal information you provide to us.

This policy covers two distinct roles, and the difference matters:

• Where we act for ourselves. Information about you as a visitor, prospect or account holder — the contact form, marketing email, your user account. Here FluentData is the controller and this policy governs.
• Where we act on a customer's instructions. Content you or your colleagues put into a dotDash workspace — documents, conversations, database records reached through a connected integration. For that content the customer organisation is the controller and FluentData is a processor acting on its instructions. Our commitments there are set out in the Data Processing Addendum. If you are an employee of a dotDash customer and want to exercise a right over workspace content, raise it with that organisation.

If you are a resident of California, see the California Addendum at the end of this policy.

We may amend this policy from time to time. Material changes will be reflected here, with the "last updated" date above changed accordingly.

The Site may link to external sites this policy does not govern. We are not responsible for their privacy practices, and we encourage you to review them before submitting information.

Your acceptance of this policy

By browsing the Site, or by giving consent where applicable privacy laws require it, you agree to be bound by this policy. If you do not agree with it, please do not use the Site.

Information we collect

Information you give us

We collect personal information when you submit our contact form, subscribe to updates, request information about the Service, request access to an account, or otherwise correspond with us. That typically includes your name, work email address, company name, telephone number and the content of your message.

Information collected automatically

When you visit the Site or use the Service we collect technical information including IP address, approximate location derived from it, browser and device type, pages visited and referring URLs. In the Service we also keep operational records — sign-in events, actions taken, and the audit trail your administrators rely on.

Information from third parties

Where permitted by local law, we may receive information from public databases, joint marketing partners and social platforms, and from an identity provider when you choose to sign in with Google.

How we use personal information

We process personal information to:

• provide, operate, secure and improve the Site and the Service;
• create and administer your account, including authentication and multi-factor authentication;
• respond to your enquiries and manage our relationship with you;
• meter usage and bill your organisation accurately;
• send service notices, and — where you have consented or the law otherwise permits — marketing about products and services that may interest you;
• understand how the Site is used, so we can improve its content and navigation;
• detect, investigate and prevent fraud, abuse and security incidents; and
• comply with legal obligations, including tax, accounting and anti-money-laundering requirements.

Our lawful bases are, as applicable: performance of a contract with you or your organisation; our legitimate interests in operating and improving our business; your consent, which you may withdraw at any time; and compliance with legal obligations.

Generative AI and your data

The Service uses generative models to run agents, answer questions and produce dashboards. Two commitments apply:

• Your data is never used to train models. Neither FluentData nor our model providers use your content, prompts or outputs to train or fine-tune any model.
• Your content is sent to a model only to serve your own request. Prompts and the context retrieved to ground them are transmitted to the model provider solely to generate your response, and are not retained by us for any other purpose.

How we share information

We share personal information with:

• Subprocessors and service providers who process it on our behalf to run the Service and our business — hosting, database, storage, generative models, email delivery, error monitoring, billing and background job execution. The current list is in the Data Processing Addendum.
• Our affiliates and subsidiaries.
• Our professional advisors — legal, accounting and similar.
• Law enforcement or other authorities, where we are required to comply with a legal obligation or court order.
• An acquirer or successor, in connection with any reorganisation, financing, merger, sale, joint venture, assignment or transfer of all or part of our business or assets, including in any bankruptcy or similar proceeding.

We do not sell personal information, and we have not done so. We do not sell the personal information of anyone under 16.

International transfers

FluentData is based in the United States and the Service is hosted there. If you are outside the United States, information you provide will be transferred to and processed in the United States. Where we transfer personal information out of the European Economic Area, the United Kingdom or Switzerland, we rely on the European Commission's Standard Contractual Clauses together with supplementary measures where appropriate.

Retention

We retain personal information for as long as necessary to fulfil the purpose it was collected for. In deciding how long that is, we consider the length of our ongoing relationship with you and the period afterwards in which we may legitimately need to refer to the information; any legal obligation requiring us to keep records; and our legal position, including applicable limitation periods, litigation and regulatory investigations.

Customer content in a workspace is retained for the term of that organisation's subscription and deleted afterwards as described in the Data Processing Addendum.

Marketing

You can unsubscribe from our marketing email at any time using the link in every message we send. We monitor and comply with applicable data privacy laws in our marketing communications.

Cookies and similar technologies

We use cookies and similar technologies on the Site to remember your preferences — including your light or dark theme choice — to keep you signed in, and to understand how the Site is used.

Most browsers let you erase cookies, block them, or warn you before one is stored. See your browser's instructions or aboutcookies.org. Note that parts of the Site may not work if your browser refuses cookies. We do not currently respond to browser Do Not Track signals.

Security

We maintain technical and organisational measures appropriate to the risk, including encryption in transit and at rest, tenant separation enforced in the database, role-based access control, multi-factor authentication, least-privilege access for our personnel, and audit logging of privileged actions. Only authorised employees and contractors have access to data you provide, and that access is limited by need and subject to confidentiality obligations. A fuller description is in the Data Processing Addendum.

While we follow generally accepted industry standards, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Your rights

Depending on where you live, you may have the right to request access to the personal information we hold about you and details of how we use it; to have it corrected; to have it erased; to restrict or object to our processing; to receive it in a portable format; and to withdraw consent where our processing relies on it. These rights are not absolute and may not apply where another legal basis requires us to continue processing.

To make a request, contact us using the details below. We must verify your identity before we can act, and we may need to ask for additional information to do so.

You also have the right to lodge a complaint with your supervisory authority.

Children

The Site and Service are not directed at children and are not intended to attract anyone under 18. We do not knowingly collect personal information from children.

California Addendum

This Addendum supplements the above for California residents. It does not apply to job applicants, employees or contractors in relation to their role with us.

Categories we collect and disclose

In the 12 months before the date above we collected and disclosed for business purposes:

• Identifiers — name, email address, postal address, telephone number, IP address, online and unique personal identifiers.
• Commercial information — subscription, billing and usage records.
• Internet or network activity — browsing history on our Site, search history within the Service, and interactions with our online properties.
• Geolocation data — approximate location derived from IP address.
• Professional information — company name and role.
• Inferences drawn from the above, such as preferences or areas of interest.

We disclose these categories to our affiliates and subsidiaries, subprocessors and service providers, external legal and financial advisors, and legal authorities, for the operational business purposes described in this policy.

Sensitive personal information

We collect account credentials, which qualify as sensitive personal information, in order to provide the Service, authenticate you, secure your account and maintain quality and security. We do not use sensitive personal information to infer characteristics about you.

Sale and sharing

We do not sell personal information and we do not share it for cross-context behavioural advertising.

Your requests

You may request that we disclose the categories of personal information we collect about you, the sources, the business purposes, and the categories of third parties we disclose to; that inaccuracies be corrected; that your personal information be deleted; and that we provide specific pieces of your personal information in a portable format.

We will not discriminate against you for exercising these rights. To make a request, use the contact details below. We may need to verify your identity, and for a deletion request we may ask you to confirm before we act.

Authorised agents

An agent may make a request on your behalf using the same contact details. We may ask the agent for proof of their authority, and may separately ask you to verify your identity or confirm that you gave the agent permission.

Deidentified information

Where we hold or use deidentified information we will keep it deidentified and will not attempt to reidentify it.

Contact us

For any privacy question or to exercise a right, contact: