Privacy Policy

PRIVACY POLICY

Last updated February 1, 2024

This privacy notice for Hona AI Inc. (“Hona,” "Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you: - Visit our website athttps://www.hona.ai, or any website of ours that links to this privacy notice - Engage with us in other related ways, including any sales, marketing, or events.

‍Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, or if you'd like to submit inquiries, complaints, or disputes about any privacy issues, please contact us at tech@hona.ai.

‍SUMMARY OF KEY POINTS ‍This summary provides key points from our privacy notice, but you can find out more details about any of these topics by finding the relevant section below.

‍‍What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Hona and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us in Section 1.

‍Do we process any sensitive personal information? When you visit, use, or navigate our Services, we may process sensitive personal information depending on how you interact with Hona and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us in Section 1.

‍Do we receive any information from third parties? We may receive information from third parties.

‍How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information in Section 2.

‍In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information in Section 3.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe in Section 7. ‍

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights in Section 9.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://console.hona.ai, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what Hona AI Inc. does with any information we collect? Review the privacy notice in full.

‍TABLE OF CONTENTS

‍1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. HOW DO WE HANDLE YOUR THIRD-PARTY LOGINS?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

‍1. WHAT INFORMATION DO WE COLLECT?‍

‍Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or ourproducts and Services, when you participate in activities on the Services, or otherwise when you contact us.

‍Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

- Names

- Email addresses

- Job Titles

- Usernames

- Passwords

- Contact or authentication data

- Billing addresses

- Debit/credit card numbers

Sensitive Information. Given that our Services include processing medical records and medical histories, we may process sensitive personal information depending on how you interact with Hona and the Services, the choices you make, and the products and features you use. This information, however, is not collected or stored in the way account information is. Health information is handled more transiently, in that we retrieve it, process it, and return it to your healthcare provider in a secure manner. Your health data may be briefly held, but only to carry out the purposes of the Services and for no other reason.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

Third-Party Login Data. We may provide you with the option to register with us using your existing third-party account details, like your Google account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR THIRD-PARTY LOGINS?" below. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

‍Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.‍

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.

‍2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.‍

‍We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

- To fulfill and manage your orders. We may process your information to fulfill and manage your orders and payments made through the Services.

- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

- To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

‍3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

‍In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products and/or services. In order to provide our Services to you, we have partnered with the following groups:

- Google

- Microsoft

- Amazon

- OpenAI

- Particle Health

‍4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

‍In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

‍5. HOW DO WE HANDLE YOUR THIRD-PARTY LOGINS?

‍In Short: If you choose to register or log in to our Services using a third-party account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party account details (like your Google login). Where you choose to do this, we will receive certain profile information about you from your third-party provider. The profile information we receive may vary depending on the third-party provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a platform.

Healthcare providers may also log in through their electronic health record (EHR) system. In this case, providers are granting Hona access to patient files stored in this system. These files are used only for the purposes of the Services and for no other reason.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

‍6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. Customer data is retained for as long as the account is active and for a brief period if expired.

Customer data is retained for as long as the account is in active status. Data enters an “expired” state when the account is voluntarily closed. Expired account data will be retained for 30 days. After this period, the account and related data will be removed. Customers that wish to voluntarily close their account should download their data manually or via the API prior to closing their account.

If a customer account is involuntarily suspended, then there is a 10-day grace period during which the account will be inaccessible but can be reopened if the customer meets their payment obligations and resolves any terms of service violations.

If a customer wishes to manually backup their data in a suspended account, then they must ensure that their account is brought back to good standing so that the user interface will be available for their use. After 15 days, the suspended account will be closed and the data will enter the “expired” state. It will be permanently removed 30 days thereafter (except when required by law to retain).

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

‍In Short: We aim to protect your personal information through a system of organizational and technical security measures.

‍We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

‍8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We may process data from children under 18 years of age but only on behalf of their healthcare provider.

Healthcare providers using our Services may have pediatric patients. In this case, our Services may require the processing of data from children under 18 years of age. This processing, however, will only occur on behalf of their healthcare provider and only for the purposes of the Services.

9. WHAT ARE YOUR PRIVACY RIGHTS?

‍In Short: You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your MemberState data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.‍

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

‍Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

- Log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at tech@hona.ai.

10. CONTROLS FOR DO-NOT-TRACK FEATURES‍

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

‍11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

‍CCPA Privacy Notice ‍The California Code of Regulations defines a "resident" as:

1. every individual who is in the State of California for other than a temporary or transitory purpose and

2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

‍What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers

Ex: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

Collected: YES

B. Personal information categories listed in the California Customer Records statue

Ex: Name, contact information, education, employment, employment history, and financial information

Collected: YES

C. Protected classification characteristics under California or federal law

Ex: Gender and date of birth

Collected: NO

D. Commercial information

Ex: Transaction information, purchase history, financial details, and payment

Collected: NO

E. Biometric information

Ex: Fingerprints and voiceprints

Collected: NO

F. Internet or other similar network activity

Ex: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

Collected: YES

G. Geolocation data

Ex: Device location

Collected: NO

H. Audio, electronic, visual, thermal, olfactory, or similar information

Ex: Images and audio, video or call recordings created in connection with our business activities

Collected: NO

I. Professional or employment-related information

Ex: Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

Collected: YES

J. Education information

Ex: Student records and directory information

Collected: NO

K. Inferences drawn from other personal information

Ex: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Collected: NO

L. Sensitive personal information

Collected: Only if provided and/or granted permission in order to provide the Services

We will use and retain the collected personal information as needed to provide the Services or for:

- Category A - As long as the user has an account with us and for 30 days if expired

- Category B - As long as the user has an account with us and for 30 days if expired

- Category F - As long as the user has an account with us and for 30 days if expired

- Category I - As long as the user has an account with us and for 30 days if expired

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

- Receiving help through our customer support channels;

- Participation in customer surveys or contests; and

- Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at tech@hona.ai, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else? ‍We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. Hona has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Hona will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We only process sensitive personal information if provided or granted permission for the purposes of the Services.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

- You may object to the processing of your personal information.

- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at tech@hona.ai, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.‍

Virginia CDPA Privacy Notice

‍Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Hona and our Services. To find out more, please visit the following sections:

- Personal data we collect

- How we use your personal data

- When and with whom we share your personal data

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Hona has not sold any personal data to third parties for business or commercial purposes. Hona will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at tech@hona.ai, by visiting https://www.hona.ai, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at tech@hona.ai. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

‍13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

‍14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Adam Steinle, by email at adam@hona.ai, by phone at (847) 751-0045, or contact us by post at:

Hona AI Inc.

Adam Steinle

447 Sutter Street

Suite 405 PMB 449

San Francisco, CA 94108

United States

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact tech@hona.ai for assistance.

Cookie Policy

COOKIE POLICY
Last updated August 15, 2023

‍This Cookie Policy explains how Hona AI Inc. (“Hona,” "Company," "we," "us," and "our") uses cookies and similar technologies to recognize you when you visit our website at https://www.hona.ai ("Website"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

‍What are cookies?
‍Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Hona AI Inc.) are called "first-party cookies." Cookies set by parties other than the website owner are called "third- party cookies." Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

‍Why do we use cookies?
‍We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Website for analytics and other purposes. This is described in more detail below.

‍How can I control cookies?
‍You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our website. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies.The specific types of first- and third-party cookies served through our Website and the purposes they perform are described in the table below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

‍Essential website cookies:
‍These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas.

Name: __cf_bm
Purpose: Cloudflare places the cookie on end-user devices that access customer sites protected by Bot Management or Bot Fight Mode.
Provider: .vimeo.com
Service: Cloudflare (View Service Privacy Policy)
Country: __________
Type: http_cookie
Expires in: 29 minutes

‍Analytics and customization cookies:
‍These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

Name: vuid
Purpose: Used by Vimeo player to check if certain features or preferences have been selected by the user on websites with embedded videos from Vimeo.
Provider: .vimeo.com
Service: Vimeo (View Service Privacy Policy)
Country: __________
Type: http_cookie
Expires in: 1 year 1 month 4 days

‍How can I control cookies on my browser?
‍As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information. The following is information about how to manage cookies on the most popular browsers:
Chrome
Internet Explorer
Firefox
Safari
Edge
Opera
‍
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit:
Digital Advertising Alliance
Digital Advertising Alliance of Canada
European Interactive Digital Advertising Alliance
‍
‍What about other tracking technologies, like web beacons?
‍Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

‍Do you use Flash cookies or Local Shared Objects?
‍Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention, and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Pane and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

‍Do you serve targeted advertising?
‍We do not serve targeted advertising on our Website. Third parties do not serve cookies on your computer or mobile device, and they do not serve advertising through our Website.

‍How often will you update this Cookie Policy?
‍We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

‍Where can I get further information?
‍If you have any questions about our use of cookies or other technologies, please email us at dani@hona.aor by post to:

Hona AI Inc.
447 Sutter StreetSuite 405 PMB 449
San Francisco, CA 94108
United States
‍
Phone: (847) 751-0045

We will use and retain the collected personal information as needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category F - As long as the user has an account with us
- Category I - As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.

‍How do we use and share your personal information?More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at dani@hona.ai, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

‍Will your information be shared with anyone else?
‍We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

Hona has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Hona will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

‍Your rights with respect to your personal data

‍Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know
Depending on the circumstances, you have a right to know:whether we collect and use your personal information;the categories of personal information that we collect;the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.

Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at dani@hona.a, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

‍12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
‍In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.‍

‍Virginia CDPA Privacy Notice
‍Under the Virginia Consumer Data Protection Act (CDPA):

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Hona and our Services. To find out more, please visit the following sections:
- Personal data we collect
- How we use your personal data
- When and with whom we share your personal data

Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Hona has not sold any personal data to third parties for business or commercial purposes. Hona will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at dani@hona.ai, by visiting https://www.hona.ai, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at dani@hona.ai. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

‍13. DO WE MAKE UPDATES TO THIS NOTICE?
‍In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

‍14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Adam Steinle, by email at adam@hona.ai, by phone at (847) 751-0045, or contact us by post at:

Hona AI Inc.
Adam Steinle
447 Sutter Street
Suite 405 PMB 449
San Francisco, CA 94108
United States

‍15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
‍Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit:
https://www.console.hona.ai