Accolade.AI Privacy Policy

Last Modified: October 5th, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

We at Accolade and our affiliates are committed to protecting your privacy. This Privacy Policy applies to the personal information and data collected by Accolade when you interact with our websites, product and services, and any other sites or services that link to this Privacy Policy.

This includes when you:

• interact with us on our websites or through other channels (for example, by communicating with us);
  
• use our product and services (including subscribing to the Accolade Newsletter); and
  
• when you use any other websites or services that link to this Privacy Policy.

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. This Privacy Policy also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. For the purposes of this Privacy Policy "Personal Data" means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our websites, product and services, or any other sites or services that link to this Privacy Policy.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification. Terms not otherwise defined in this Privacy Policy will have the meaning as set forth in the Accolade Terms of Use.

If you have any questions about this Privacy Policy or to exercise the privacy rights and choices we offer please [contact us using this form.](https://accolade.ai/contact/)

1. Summary of the Privacy Policy

2. How We Use Personal Data

3. How We Share Personal Data

4. How We Transfer Personal Data Internationally

5. How We Store and Secure Personal Data

6. Cookies and Similar Technologies

7. Your Privacy Rights and Choices

8. California Privacy Rights

9. Data Protection Officer

10. Other Important Privacy Information

1. What Information We Collect and Process

a. Information You Provide to HubSpot

When you interact with us via our websites or any sites or services that link to this Privacy Policy (including Accolade.AI) or use the Subscription Service, we may collect Personal Data and other information from you, as further described below.

Summary of the Privacy Policy

- Accolade collects limited information about visitors, including the domain name, access date and time, and the referring website address. - Personal information sent via electronic message or email will only be used to respond to the message; - For website security and availability, Accolade monitors network traffic and collects non-personally-identifying information for statistical purposes. - California residents have the right to request a list of third parties to whom their personal information has been disclosed for direct marketing purposes. - The Site may use third-party ad networks to serve advertisements and traffic measurement services to analyze traffic on the Site. - This Privacy Policy does not protect information shared on public forums like chat rooms, message boards, or bulletin boards. Accolade is not responsible for information distribution in these forums. - Reasonable security measures are in place to protect against loss, misuse, and alteration of information, but security cannot be guaranteed. - Accolade is not responsible for the privacy practices of third-party websites linked to or from the Site. - Contact information is provided for questions, comments, corrections, or opting out of commercial correspondence, sharing personal information, or withdrawing consent.

We collect Personal Data from you when you submit web forms or interact with our websites, for example by subscribing to an Accolade email newsletter, signing up for a webinar, subscribing to one of our services or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself. For site security and availability, Accolade monitors network traffic and collects non-personally-identifying information for statistical purposes.

Event Information

When you register for an Accolade event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and in some cases facilitate your registration. Additionally, we may share your registration data with service providers in order to provide event information and improve your experience at or in future events.

Account and User Information

We collect Personal Data when you sign-up for an Accolade account, create or modify user information, set preferences, or provide any other related information to access or utilize our Subscription Service.

Payment Information

We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Accolade account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy.

You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials

We may post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer's consent via email or through other agreements between customers and Accolade prior to posting the customer's name and testimonial.

b. Information We Process on Behalf of Customers When They Use the Subscription Service
When customers use the Subscription Service, Accolade and other third party providers may collect Personal Data such as first and last name, email address, physical address, phone number, or other information. We call the information that our customers submit or collect via the product ‘Customer Data’ under our Accolade Terms of Use.

We store our customers' information on our service providers' servers but process it as a processor under our customers’ instructions and in accordance with our Terms of Use, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Accolade for processing purposes.

c. Information We Collect and Process When You Use the Subscription Service
Usage Data
We collect usage data when you or your users in your Accolade account interact with the Subscription Service. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account. We engage third party providers to collect usage data. For more information about how we protect your information with these service providers, please see Section 3 "How We Share Personal Data."

Mobile
When you access or use the Subscription Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifiers.

Third Party Integrations
You may connect third party integrations to your Accolade account, which may ask for certain permissions to access data or send information to your Accolade account. It is your responsibility to review any third party integrations you authorize. We may collect information about what types of integrations you use in your Accolade account.

Any permission(s) granted by you, grants these third parties access to your data, which may include (but is not limited to) granting third party applications access to view, store, and modify your Accolade account data. We are not responsible for the practices of third party integrations, so please carefully review the permissions you grant to third party applications.

Gmail Integration
If you use the Gmail integration or choose to integrate any other Google Workspace application with Accolade, you will be asked to give us access to information from your Gmail or Google account. You can learn more about how we access this data in the in-app notice when you connect to Gmail.

By using the Gmail integration with the Subscription Service you will grant the Subscription Service access to information associated with your account, including contacts, emails, calendar, distribution lists, subject lines, and URLs of tracked links from your email, if you use the email tracking functionality. In addition, the Subscription Service will be able to read, modify, create, and send emails from your connected Gmail account. The Subscription Service will scan the content of your emails to identify which emails you have elected to track in order to provide you with the notifications feature. The Subscription Service will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and email bodies. Your email may contain sensitive information, such as names of your contacts, your private communications, or financial or medical information. You understand that the correspondences you track will be visible to other users on your Subscription team.

If you connect your Gmail account via IMAP (or Generic Inbox Connection), the Subscription Service will have access only to email address, password, server information, email metadata, and message bodies. Additionally, connecting your Gmail account via IMAP does not require you to connect any other Google Workspace applications.

Additional Limits on Use of Your Google User Data
Accolade's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Google Calendar Integration
The Subscription Service will have access to both your Google Calendar and any other calendar you access via Google in order to power our Meetings tool, and allow you to associate events with contacts in your AccoladeAI account. The Subscription Service will have the ability to: create or change your calendars, and update individual calendar events.

Google Drive Integration
As part of connecting your Google Drive, the Subscription Service will be able to: see your files, upload and download your files, and store file contents and titles.

Google Search Console
You can integrate your Google Search Console with our Content Management System (CMS). As part of this integration, the Subscription Service will be able to view, manage and store properties which include the list of sites and domains you control and the Search Console data for your connected properties.

d. Information We Collect From Other Sources
AccoladeAI Partners
We may receive information about you or other users of your AccoladeAI account from our global network of partners. We may receive this data from our deal and lead registration process through our partners.
We may also collect information about you through our partner co-marketing partnerships. For example, you may sign up to a webinar or download a white paper published by AccoladeAI and an AccoladeAI co-marketing partner.

Third Parties
We may receive information from third party service providers, from related companies, and from our business and solution partners.

Personal Data from Different Sources
We may combine the personal information we collect from you with personal information we receive from other sources, such as third party providers of business information and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our records, identify new customers, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications and promote events. The collection of your Personal Data by these other third party providers is governed by the provider’s privacy policy.

Log Files
Like most websites and technology services delivered over the Internet, we automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our customer’s websites (if those websites are hosted on Accolade e.g. HTML pages or, graphics etc), your operating system, access times and referring website addresses.

When you use the Subscription Service, we collect and store the categories of information listed above in logs in the following instances, subject to the customer’s implementation settings:

• When an AccoladeAI user logs into their account and accesses tools in the AccoladeAI Platform;
• When an individual visits a customer’s website, if the website is hosted by an AccoladeAI product; or
• When an individual visits a customer’s website, if the customer’s website is self-hosted, if the customer uses our plug-ins, and the customer uses AccoladeAI scripts and content (such as embedded forms).
  
  Buttons, tools, and content from other companies
  Our websites may include features and widgets (such as the share and/or “like” button or interactive mini-programs) that run on our websites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. These features and widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
  
  We have implemented Google reCAPTCHA Enterprise on certain products and services to prevent malicious software from engaging in abusive activities on our websites. You can learn more about data collected by Google and what this data is used for in Google’s Privacy Policy. Additional information on Google services and products is available in Google’s Terms of Service.
  
  Other AccoladeAI Companies
  We may receive information about you from other companies that are owned or operated by AccoladeAI.
  
  

2. How We Use Personal Data
   a. To Communicate with You About the Product and Services
   We use the account information you provide to AccoladeAI when signing up for the Subscription Service to send you transactional emails or in-app notification about billing, account management, and other administrative matters. We may also send you updates regarding our Customer Terms of Service or other legal agreements, and may also communicate with you about security incidents via email or in-app notification.
   
   We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.
   
   If you use the AccoladeAI mobile application, we may send you push notifications from time to time in order to update you about events and promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
   
   b. To Provide the Subscription Service
   We use your account information and Customer Data to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Subscription Service. We also use this information to authenticate you when you log in and to provide customer support.
   
   c. To Improve and Develop Our Product and Services
   We collect usage data about how you or your users interact with our product and services. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.
   
   We use Customer Data for machine learning that supports certain products and development of features and functionality with the Subscription Service and similar products and services. For example, machine learning helps power the business card scanner tool if you use our mobile apps and allows for easier imports of data into your AccoladeAI account. You may opt-out of having your Customer Data used for machine learning by messaging us.
   
   We may publish data about how our product and services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual users or customers. For example, we may publish featured posts on trends or insights into how users are interacting with our product.
   
   d. To Secure and Protect our Product and AccoladeAI Users
   We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts, new product sign-ups, and to detect and prevent product abuse. This includes enforcing our Acceptable Use Policy.
   
   We use log files to provide general statistics regarding use of the websites by you, including how you use our websites, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your IP addresses are also collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we do link this automatically-collected data to other personal data provided by you such as name, email address, address, and phone number.
   
   e. To Market and Promote the Subscription Service
   We use the information you provide to AccoladeAI to market and promote the products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or AccoladeAI content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business.
   
   You may opt out of receiving this promotional content by following the instructions contained in each communication that we send to you or by contacting us. If you unsubscribe from our marketing lists, we will continue to contact you regarding administrative matters, and to respond to your requests.
   
   We may also reach out to you via telephone to ask about other AccoladeAI products or services you may be interested in. If you have a call scheduled with an AccoladeAI representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.
   
   Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests. We receive information from third party service providers and other sources such as third party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Subscription Service, like personalized communications, event promotion, and tailoring the websites or product to improve user experience.
   
   f. Other Purposes if We Obtain Your Consent
   We share your data with third parties when you give us consent to do so.
   
   
3. How We Share Personal Data
   a. Service Providers
   We may share Personal Data with our third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, application development, marketing, sales support and customer support. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third party service providers to acknowledge and adhere to our privacy and data protection policies and standards.
   
   b. Partners
   We may share data with trusted AccoladeAI partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.
   
   We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies.
   
   c. Corporate Events
   If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by AccoladeAI on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
   
   d. Public Forums Our websites may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the account you use to post the information) it may be read, collected and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section 7 “Your Privacy Rights and Choices” below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
   
   e. Compelled Disclosure
   We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Subscription Service, Customer Data is considered Confidential Information and you should review the Confidentiality terms in the Terms of Service for more information.
   
   
4. How We Transfer Personal Data Internationally
   a. International Transfers within the AccoladeAI Group
   To facilitate our global operations, we may transfer information to other AccoladeAI Affiliates where we have operations for the purposes described in this policy.
   This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) within and among AccoladeAI’s Affiliates, we rely upon the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required, as well as additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect customer data at rest and in transit, TLS for AccoladeAI hosted sites, web application firewall protection, and other appropriate contractual and organizational measures), as described more in detail here.
   
   b. International Transfers to Third Parties
   Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the UK Addendum. For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, AccoladeAI is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. Please contact us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and UK.
   
   c. Data Privacy Framework Notice
   AccoladeAI complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce (collectively “the Data Privacy Framework”).
   
   Accolade adheres to the EU-US DPF Principles with regard to the processing of Personal Data received from the European Union, and the United Kingdom (and Gibraltar) and to the Swiss-US DPF Principles with regard to the processing of Personal Data received from Switzerland. If there is any conflict between this Privacy Policy and the DPF Principles, the DPF Principles will govern. To learn more about the Data Privacy Framework, please visit https://www.dataprivacyframework.gov/.
   
   If you are located in the EU, UK or Switzerland, you have the right to request access to the Personal Data that we hold about you and request that we correct, amend or delete your Personal Data if it is inaccurate or processed in violation of the DPF Principles. We will give you an opportunity to opt out where Personal Data we control about you is to be disclosed to an independent third party or used for a purpose that is materially different from those set out in this Privacy Policy. If you would like to exercise any of your rights, please contact us via the details provided below.
   
   In compliance with the DPF Principles, Accolade commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. We will investigate and attempt to resolve any DPF Principles-related complaints within 45 days. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF Principles should first contact Accolade here.
   
   In compliance with the Data Privacy Framework, AccoladeAI commits to refer unresolved complaints concerning our handling of personal data received in reliance on the Data Privacy Framework to an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe Dispute Resolution, are provided at no cost to you.
   
   Under certain conditions, more fully described on the DPF website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. The Federal Trade Commission has jurisdiction over AccoladeAI’s compliance with the DPF Principles.
   
   Please note that under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
   
   
5. How We Store and Secure Personal Data
   a. Data Storage and Security
   We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.
   
   b. Retention of Personal Data
   How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
   
   We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
   
   When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section “Privacy Rights and Choices” below. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your AccoladeAI account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
   
   The data our customers process in connection with the Subscription Service is retained according to the AccoladeAI Terms of Service
   
   
6. Cookies and Similar Technologies
   a. Cookies
   When you visit our websites, sign up for an AccoladeAI account, attend an AccoladeAI virtual event, or request more information about AccoladeAI, we collect information automatically using tracking technologies, like cookies and tracking pixels.
   
   AccoladeAI and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole.
   
   b. Advertising
   We partner with third party ad networks to display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising you will continue to receive generic ads.
   
   
7. Your Privacy Rights and Choices
   a. Personal Data Requests
   You have the following data protection rights:
   

• Access, Correction or Deletion. You can request access, correction, updates or deletion of your Personal Data.
  
• Objection. You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
  
• Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  
• Complaint. You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA are available here.
  
  We do not sell personal information.
  
  To exercise any of these rights, please use this form;
  
  Please note that to protect personal information, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. 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.
  
  We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your 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.
  
  If you are a customer, prospect, or otherwise interact with an Accoladeai customer that uses our Subscription Service and would like to access, correct, amend or delete your data controlled by the customer, please contact the relevant customer directly. AccoladeAI acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.
  
  b. Anti-Spam Policy
  Our Acceptable Use Policy applies to us and to our customers and, among other things, prohibits use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an “opt-out” mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.
  
  c. To Unsubscribe From Our Communications
  You may unsubscribe from our marketing communications through one of the following methods:
• by clicking on the “unsubscribe” link located on the bottom of our e-mails;
  
• updating your communication preferences;
  
• for all AccoladeAI brands by contacting us here; or
  
• for all Accolade brands write to us by mail at Accolade AI, Inc., 211 E 43rd Street 7FL#420, NY, NY 10017 USA, Attn: Privacy and Data Protection Officer.
  
  Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
  
  d. To Unsubscribe From Our Customers’ Communications
  Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. Individuals who interact with an AccoladeAI customer can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
  
  

8. California Privacy Rights
   a. Applicability
   This section applies only to California consumers. For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. Accolade is a business, and does not sell Personal Information. We may share Personal Information with authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information.
   
   If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.
   
   b. How We Collect, Use, and Share your Personal Information
   We have collected the following statutory categories of Personal Information in the past twelve (12) months:
   

• Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
  
• Commercial information, such as subscription records. We collect this information directly from you.
  
• Internet or network information, such as browsing and search history. We collect this information directly from your device.
  
• Geolocation data, such as IP address. We collect this information from your device.
  
• Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
  
• Inferences.
  
• Other Personal Information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.
  The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we “disclose” this information for a business purpose are described in Section 3 of this Privacy Policy. The period of time for which we retain this information is described in Section 5 of this Privacy Policy.
  
  c. Your California Rights
  You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
  
  The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
  
  The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
  
  The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
  
  The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
  
  Accolade does not sell or share Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
  
  d. How to Exercise your California Rights
  You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information. Please use the contact details below, or see Section 7 “Your Privacy Rights and Choices” above, if you would like to:
  
• Access this policy in an alternative format;
  
• Exercise your rights;
  
• Learn more about your rights or our privacy practices; or
  
• Designate an authorized agent to make a request on your behalf.
  
  

9. Data Protection Officer
   If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us.
   

10. Other Important Privacy Information
    a. We Never Sell Personal Data
    We will never sell your Personal Data to any third party.
    b. Information About Children
    The websites, product and services are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us here, so that we may delete the information.
    
    c. Third Party Dispute Resolution
    If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.