Ingenio Privacy Policy

Effective: August 19, 2026 

Ingenio, LLC and its affiliates (collectively, “Ingenio,” “we,” “us,” or “our”) is committed to respecting your privacy and protecting your personal data. This Privacy Policy (the “Policy”), describes the personal data we process, how we use and protect it, and the rights and choices you may have depending on your location. This Policy applies to all personal data that is collected by Ingenio during any written, electronic, and oral communications online when you: 

• access or use our affiliated websites, including www.horoscope.com, www.astrology.com, www.keen.com, www.liveadvice.com, or any other website, application, or online service that we operate which includes a link to this Policy (collectively, “Site(s)”);

• contact us through our Customer Support page, call us, or participate in official surveys and sweepstakes (“Activities”);

• interact with social media pages we control (“Social Media Page(s)”); or 

• engage our products or services that link to this Policy (collectively, including the Sites, Activities, and Social Media Pages, the “Services”).  

By accessing, visiting, or using our Services, you agree to our Terms and Conditions, and you acknowledge that we collect and use your personal data in accordance with this Policy. If you do not feel comfortable with any part of this Policy or our Terms and Conditions, you should not use or access our Services. 

We may update this Policy from time to time to reflect changes in the law, our new service offerings, or for other reasons. When we make a change, we will provide you with notice of such updates as required by applicable law and will revise the “Last Updated” date at the top of this Policy. For material changes or new features, we may provide additional notice, such as by email, in-product notice, or other notice through the Services, and we may ask you to acknowledge such updates before using the affected feature. We encourage you to look for updates to this Policy by checking this page when you access our Services. 

Contents 

1. Personal Data We Collect
2. How We Collect Personal Data
3. Cookies and Other Tracking Technologies
4. How We Use Personal Data
5. AI Features, Call Transcripts, Chatbots, and Project Memory
6. How We Disclose Personal Data
7. Security
8. Retention of Personal Data
9. Communications and Marketing Preferences
10. Privacy Rights
11. Children’s Privacy and Adult-Only Services
12. Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland
13. International Transfers
14. Additional Disclosures
15. Notice to Québec Residents
16. Notice to Israel Residents
17. Third-Party Links
18. Contact Us 

1. Personal Data We Collect

Personal data is any information that relates to you, identifies you personally, or could be used to identify you. The definition of personal data (used interchangeably with “personal information”) depends on the applicable law based on your physical location or state residency. Only the definition that applies to your physical location or state residency will apply to you under this Policy. 

We may collect the following categories of personal data, depending on how you interact with our Services.

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal data from you: 

• Account and profile information. When you create or manage an account, we may collect information such as your name, username, email address, telephone number, mailing address, login credentials, account preferences, time zone, communication preferences, and similar information.

• Astrology, horoscope, and personalization information. To provide certain Services, we may collect information such as your date of birth, time of birth, birth location, gender, time zone, account preferences, interests, selected topics, saved preferences, and other information you choose to provide for astrology, horoscope, spiritual wellness, self-reflection, or personalization purposes.

• Transaction and payment information. When you make a purchase or use paid Services, we may collect information such as billing address, payment method, payment account information, PayPal account information, credits, subscriptions, purchase history, order history, transaction history, and related commercial information. Payment information may be processed by our payment processors on our behalf.

• Advisor, reader, chat, email, and call information. When you interact with advisors, readers, coaches, customer support, or similar features, we may collect information such as chat messages, emails, call metadata, call recordings, transcripts, summaries, notes, user and advisor identifiers, session details, and related communications. When call recording or transcript features are enabled or otherwise made available, calls between users and advisors or readers may be made available to the applicable participants in the call as described in the applicable product experience. Call recordings and transcripts may include personal data or sensitive personal data that you or the other participant choose to disclose during the call. Where required by law, we will provide notice and obtain consent before recording or transcribing telephone conversations. Certain calls, such as calls placed through designated alternative telephone numbers, may not be recorded or transcribed. 

• AI chatbot, AI output, and Memory information. If you use AI chatbot or AI-generated features, we may collect prompts, messages, responses, chat history, conversation summaries, feedback, safety signals, and related interaction data. If you enable Project Memory or similar memory functionality, we may create and store limited facts or preferences from your interactions to personalize future AI responses. Memory information may include, for example, people or relationships you mention, life events, goals or aspirations, spiritual or content preferences, preferred AI experiences, and current context you choose to share. We do not intend for Memory to save full chat histories as memory entries, and Memory should not be used for medical, mental health, legal, financial, emergency, or safety decisions.

• Customer support information. When you contact us for support, submit a request, respond to a survey, provide feedback, or otherwise communicate with us, we may collect your contact information, account information, request details, correspondence, recordings, attachments, and any other information you choose to provide.

• Promotions, surveys, and events. If you participate in promotions, surveys, contests, sweepstakes, research, user testing, or similar activities, we may collect information such as your name, contact information, responses, preferences, eligibility information, and any other information identified in the applicable promotion or survey terms.

• User-generated content. If you post reviews, comments, forum posts, blog comments, public profile information, listings, ratings, testimonials, or other content through the Services, we may collect and display that content as part of the Services. Please do not post information you do not want to be public.

• Marketing and communication preferences. We may collect your email address, phone number, consent records, opt-out choices, and preferences regarding marketing emails, calls, text messages, push notifications, and other communications.

Information We Collect Automatically. To the extent permitted under applicable law, we may automatically collect certain types of personal data about you when you use or interact with our Services, including:

• Device and usage information. When you use the Services, we may automatically collect information such as IP address, device identifiers, advertising identifiers, browser type, operating system, device type, app version, pages or screens viewed, links clicked, search queries, referring and exit pages, session duration, date and time stamps, crash logs, and other information about how you interact with the Services.

• Location information. We may infer your general location from your IP address or device information. Where permitted and with any required consent, we may collect more precise location information, such as mobile device location, to provide location-based features or improve the Services. You may disable location permissions through your browser or device settings.

Information We Collect from Third Parties. From time to time, we may obtain personal data about you from third party sources as required or permitted by law. These sources may include:

• Affiliates. We may receive information from our affiliates and related brands so that we can operate our group of Services, support users across platforms, prevent fraud, provide customer support, personalize Services, and conduct analytics and marketing, subject to applicable law.

• Advisors, readers, and service providers. We may receive information from advisors, readers, contractors, customer support providers, payment processors, identity verification vendors, fraud prevention vendors, analytics providers, AI service providers, cloud hosting providers, database providers, and similar service providers.

• Social networking services. If you connect your account to a social networking service or interact with us through social media, we may receive information permitted by your privacy settings and the applicable social media platform, such as profile information, username, email address, profile image, social media interactions, and other information.

• Third Party Partners. Unless prohibited by applicable law, we may obtain your personal data from marketing partners, analytics providers, Promotion providers, and other third-party partners to market to you, including to match custom audiences or create lookalike audiences on social media or other marketing platforms so that we can better understand which of our Services may be of interest to you, market our Services to you, and to provide us information necessary to improve our Services.

• Single Sign-on (“SSO”). SSO is an authentication method that enables you to securely authenticate your login within multiple applications and websites by using one set of credentials. If you choose to login to our Services through a third-party platform we may have access to certain information from that platform, such as your username, email address, or phone number to send you verification code. The information we receive may vary based on your privacy settings on such platform or as otherwise controlled by the provider of such platform.

Sensitive Personal Data. We request that you do not provide sensitive personal data unless it is necessary for the Services, required by law, or you choose to provide it. Please do not provide sensitive personal data through AI chatbot, advisor, reader, customer support, public posting, or other features unless you understand that we may process that information as described in this Policy. Project Memory is intended to avoid saving certain sensitive information as ordinary personalization memory, including suicide, self-harm, crisis, abuse, medical, mental health, therapy, emergency, precise location, credentials, government identification, biometric, or under-18 status information.

2. How We Collect Personal Data

We collect your personal data from a variety of sources, including directly from you, automatically when you interact with our Services, and from third parties, as described below:

• Directly from you. We collect personal data when you create an account, purchase Services, communicate with advisors or readers, use AI chatbot or Memory features, contact customer support, complete forms, participate in surveys or promotions, post content, change settings, or otherwise provide information to us.

• Automatically. We collect personal data automatically when you use the Services, including through cookies, tracking technologies, device identifiers, logs, analytics tools, security tools, and similar technologies.

• From third parties. We may receive personal data from affiliates, service providers, payment processors, identity verification providers, fraud prevention vendors, analytics providers, advertising partners, AI service providers, social networking services, advisors, readers, referral sources, and other lawful sources.

3. Cookies and Other Tracking Technologies

We and our third-party partners and service providers (such as advertisers and analytics providers) may use cookies and similar digital tracking technologies (such as pixels, web beacons, and tags) (collectively, “Tracking Technologies”) on our Sites and other online services to gather information when you interact with our Sites and Services. These Tracking Technologies help us operate our Services, understand your usage, improve functionality, and, depending on your choices and where you live, deliver and measure advertising.

Tracking Technologies can be placed on our Sites by us or by third-party partners we engage for our purposes. Third-party cookies may also be deployed on our behalf on third-party websites (e.g. to measure the effectiveness of ads). 

Types of Tracking Technologies. We may use the following types of tracking technologies on our Sites and Services:

• Strictly Necessary. These Tracking Technologies are required for the operation of Sites and Services. These Tracking Technologies do not gather information about you for marketing purposes.

• Functional. These Tracking Technologies are used to recognize you when you return to Sites and Services. They remember the choices you make (such as your username, or the region you are in) and the changes you make to text size, fonts and other features you can customize. While these Tracking Technologies can be disabled, this may result in less functionality during your use of our Sites and Services.

• Analytics. These Tracking Technologies allow us and our analytics service providers/processors to count visits and traffic sources, or test new features, so that we can measure and improve the performance of our Sites and Services, including as part of our analytics practices to improve the content offered. They help us understand how visitors use our Sites and Services, which site or page the user came from, the number of each user’s visits and how long a user stays on the Sites and Services.

• Analytics (Partner). These Tracking Technologies allow our third-party analytics partners to track information about your usage of the Sites and Services (as defined in this Policy). These third-party analytics partners may obtain information about how visitors use our Sites and Services, which site or page the user came from, the number of each user’s visits and how long a user stays on the Sites and Services. These third-party analytics partners may use the information for their own purposes.

• Targeting and Marketing. Targeting Tracking Technologies may be set through our Sites and Services (as defined in this Policy), by our advertising partners to deliver content, including ads, that are relevant to your interests across your devices, based on how you interact with our advertisements or content. They may be used by our advertising partners to build a profile of your interests and to show you relevant ads on other sites. They do not store personal data directly but are based on uniquely identifying your browser and internet device. If you do not allow these Tracking Technologies, you will experience less targeted advertising.

• Social Media. These Tracking Technologies are set by a range of social media partners that we add to the website. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.

Why We Use Tracking Technologies. We may use these Tracking Technologies for the following purposes:

• to enable basic functioning of our Sites or to fix any technical issue through gathering relevant technical data;

• for web analytics to improve our Sites (structure, features, accessibility and usability, content) or to fix any technical issue through gathering relevant technical data;

• to monitor the effectiveness of our online ads and marketing (by recording your interactions with our ads on third-party websites, our social media platforms or our marketing emails); and

• to learn more about your preferences and Internet browsing tastes to provide you with tailored advertising.

How to Manage Your Tracking Technologies Preferences.  

• Your Privacy Choices. Please refer to Section 10 below for more information about whether you have the right to opt-out of sales and targeted advertising, and if so, how to exercise that right. Please note that you may still receive generalized ads after opting out. Your opt-out choice will only apply to your use of our Sites through the current browser or device you are using and only so long as that browser’s cookies are not erased.

• Cookies Settings. If you are located in any European Countries (defined below), you may consent to or withdraw your consent to sharing your personal data via tracking technologies at any time by clicking the “Cookies Settings” link in the website footer and changing your preferences.

• Global Privacy Control. If you are a resident of Colorado, Connecticut, Montana, New Hampshire, and Texas, you may also opt-out of having your personal data shared with third parties for targeted advertising or sales via cookies or other similar tracking technologies by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we recognize. You can visit the Global Privacy Control official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Your opt-out choice will only apply to your use of our Site through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Sites to completely opt-out using this method. Please note that you may still receive generalized ads after opting out

• Browser Controls. Alternatively, you can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Sites although your access to some functionality and areas may be restricted. If you want to understand your browser’s cookie default setting, or learn to modify your browser’s cookie settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers:

• Google Chrome

• Microsoft Edge

• Microsoft Internet Explorer

• Apple Safari Mobile

• Android Browser

• Opting-out of Third-Party Analytics. We may use third-party service providers to monitor and analyze the use of our online, web-based, and mobile-based Services, such as Google Analytics. Google Analytics is an analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. To opt out of Google Analytics or to prevent your data from being collected and used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.

• Disabling Certain Interest Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA), which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info.

4. How We Use Personal Data

We may process your personal data for the following commercial and business purposes:

a)    To Operate and Administer Our Services. We may use your personal data to provide you with the Services that you request, such as creating and managing your user accounts, processing and completing purchases, and similar transactions.

b)    To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us to respond to your inquiries and to fulfill your requests. Without your personal data, we cannot respond to you or ensure your continued use and satisfaction of the Services.

c)    To Provide You with Service-Related Communications. We may send you administrative or account-related information to you, for example, privacy policy and terms updates, security updates, or confirmations of your account actions or transactions. Service-related communications are not promotional in nature. You may not be able to unsubscribe from certain service-related communications, otherwise you may miss important developments relating to your account or the Services.

d)    To Provide Marketing Communications. Subject to your marketing preferences (which may include consent to marketing under applicable law), sending you special discounts and offers, newsletters or marketing communications we believe may interest you, for our own products and services. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages. We may also collect and use your online or mobile identifiers for the purpose of marketing campaigns. Please see Cookies and Other Tracking Technologies Section for more information.

e)    To Infer Your Interest and Personalize Your Experience. We may process your personal data to personalize your experience on the Services by presenting products and offers tailored to you. We may use such information to enable you to interact with our Services more easily across devices, or to recommend more relevant content to you. For example, when you enable the social sharing functionalities of your social media account(s) by interacting with our content on or through third-party social networking websites, plug-ins and applications, we may use this information to personalize your experience on our Services and on the third-party social networking websites, plug-ins and applications.

f)      To Research and Develop Our Services. We may process your personal data and derive analytical and statistical data to better understand the way you use and interact with our Services, including by carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

g)    To Administer Promotional Events. When you participate in promotions, we may process your personal data to administer such activities (each of which may have additional rules and could contain additional information about how we process your personal data).

h)    To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

i)      To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal data when actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We may also process your personal data to investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties; recover payments due to us; and protect our and others’ rights, privacy, safety, or property.

j)      To Ensure the Security of the Services. We may process your personal data to combat spam, malware, malicious activities, or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.

k)    To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal data. For example, we process your personal data to pay our taxes, to fulfill our business obligations, or as necessary to manage risk as required under applicable law, or to respond to requests by judicial process or governmental agencies.

l)      To Enhance AI Technology. When you interact with some service features, they may be powered by artificial intelligence and machine learning technologies (collectively, “AI technology”), such as generative AI chatbots. You acknowledge that we may use your personal data and any user content, input, uploads, or feedback that you provide to us to operate, personalize, monitor, secure, test, debug, and improve the Services, but not to train or fine-tune third-party LLMs unless disclosed and permitted. 

m)   With Your Consent. For any other purpose disclosed to you prior to you providing us your personal data or which is reasonably necessary to provide the Services or other related services requested, with your permission or upon your direction.

We may also aggregate or deidentify any personal data that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you.

5. AI Features, Call Transcripts, Chatbots, and Project Memory

Some Services may include AI-powered features, including AI-generated chatbots, AI summaries, advisor or reader interaction summaries, content personalization, safety tools, and Project Memory. Ingenio may use AI tools and service providers to detect, classify, or respond to suicide, self-harm, crisis, abuse, exploitation, threats, or other safety-related content.

AI-Generated Responses. 

AI-generated responses are generated by artificial intelligence, not by a human. AI outputs may be inaccurate, incomplete, outdated, or inappropriate for your circumstances. AI features are provided for entertainment, personalization, and general informational purposes only. They are not medical, mental health, legal, financial, emergency, safety, or other professional advice.

You should not rely on AI outputs for important decisions. If you are in crisis, may harm yourself or others, or need emergency help, contact emergency services or a crisis hotline immediately.

Call Recording and Transcripts. 

Some Services may allow calls between users and advisors or readers to be recorded and transcribed so that call transcripts can be made available after a call. Where this feature is enabled or otherwise made available, we may process the call audio, transcripts, call metadata, session details, participant identifiers, and related information to provide the transcript feature, make the transcript available to the applicable participants, maintain service quality, support customer service, enforce our terms and policies, investigate misuse or safety issues, comply with legal obligations, and improve the Services.

We may provide notices about call recording and transcription through the Services, including by email, pop-up, banner, call initiation screen, call-flow notice, IVR or automated voice notice, or other in-product disclosures. Where required by law, we will provide notice and obtain consent before recording or transcribing a telephone conversation. If you do not want a call to be recorded or transcribed, you should not proceed with the call or should disable the feature where controls are available. 

Transcripts may be generated using AI-powered transcription technology and may be inaccurate, incomplete, delayed, or may misattribute, omit, or incorrectly transcribe certain words or speakers. Transcripts are provided for convenience only and should not be treated as an official, complete, or error-free record of the call. You should independently confirm any information that is important to you. 

Project Memory. 

Project Memory is designed to personalize future AI responses by saving limited facts or preferences from your interactions. For example, Memory may save information about people or relationships you mention, life events, goals or aspirations, spiritual or content preferences, preferred AI experiences, or current context you choose to share.

Memory is intended to save selected facts or preferences, not every message in your chat history. Your chats, summaries, and related information may still be processed and retained as described in this Policy. Memory data and crisis-related safety data are not used for AdTech, sale, targeted advertising, cross-context behavioral advertising, data broker activity, lookalike modeling, or unrelated monetization.

Where available, you may be able to:

• turn Memory on or off;

• view saved memories;

• correct inaccurate memories;

• delete individual memories;

• delete your full Memory profile; and

• manage how Memory is used to personalize future AI responses.

If you disable Memory, we will stop using Memory to personalize future AI responses, unless otherwise disclosed in the product. If existing memories remain stored in a disabled state, you may separately delete your Memory profile where available.

Sensitive Information and Memory.

Memory is not intended to save certain sensitive information as ordinary personalization memory. This includes suicide, self-harm, crisis, abuse, medical, mental health, therapy, emergency, precise location, children/minor status, credentials, government identification, biometric, financial vulnerability, or similar high-risk sensitive information.

If you voluntarily provide sensitive information in chats, calls, or other communications, that information may still be processed in transcripts, summaries, safety systems, logs, or other records as described in this Policy.

Human Readers and Advisors.

If you use human reader, advisor, coach, or similar services, we may process information necessary to provide that service. If selected Memory information or chat-derived profile information is made available to a human reader or advisor to personalize a user-requested experience, we will disclose that use where required and provide appropriate controls where available. 

Transcription Service Providers. 

We may use third-party service providers, including AI transcription providers, to process call audio, transcripts, and related metadata on our behalf. These providers may process personal data only as needed to provide services to us and subject to contractual restrictions. We do not permit these providers to use call audio or transcripts to train their general-purpose AI models unless we disclose that use and obtain any consent or provide any choices to you as required by law. 

6. How We Disclose Personal Data

We may disclose your personal data for business and commercial purposes as described in this Policy. We take reasonable steps to limit access to your personal data to our employees, agents, contractors, and other parties to the extent necessary for the purposes set out in this Policy. Where required, we provide you with the ability to opt out of these disclosures or first obtain your consent. We may disclose your personal data as described in categories under Section 1, in the following ways:

a)    Within Our Corporate Group. We may disclose some or all of your personal data with our subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us for the purposes described in this Privacy Policy unless otherwise prohibited by applicable law or by contractual agreement with our vendors, service providers or other third parties.

b)    To Service Providers. We may disclose personal data to vendors, service providers, contractors, professional advisors, and other entities that need this information to provide services to us, such as: managing a database of customer information; hosting the Sites; designing and/or operating the Sites’ features; tracking the Sites’ activities and analytics; enabling us to perform administrative services; operating our Customer Service; allowing you to participate in live and AI chat on the Site; and other services designed to assist us in maximizing our business potential. These service providers may have access to or process your personal data only for the purpose of providing services to us.

c)    Business Partners, Sponsors, and Other Third Parties. We may disclose your personal data to business partners, co-sponsors of promotions, and other third parties in order to provide you with Services that may interest you. For example, we may co-sponsor promotions, sweepstakes, or other events with a third party and may share your personal data in connection with these events. If you provide additional information to any of these third parties, such information provided to these third parties will be subject to each third party's privacy practices and policies.

d)    Analytics and Interest-based Advertising Partners. We use third-party analytics, advertising, and marketing providers to collect information about your use of the Sites, see the overall patterns of usage on the Sites, deliver advertisements to your social media account based on email addresses, optimize ad performance, and determine whether our advertising is effective. Where permitted by applicable law, we may share your personal data with marketing and advertising partners for targeted advertising purposes, such as matching custom audience or creating lookalike audience on social media or other marketing platforms, so that we can better understand which of our Services may be of interest to you, market our Services to you, and to provide us information necessary to improve our Services.

e)    As Necessary to Comply with Our Legal Obligations. We may also disclose personal data in order to assist with or otherwise enable our compliance with a legal or regulatory obligation, protect and defend our rights or property, protect the safety of our users or the public, and to establish or defend our legal rights.

f)      As Part of a Corporate Transaction. We reserve the right to transfer the information we maintain, including your personal data, in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal data in a manner that is consistent with this Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the recipient’s privacy practices.

g)    With Outside Professional Advisors. We may share or disclose your personal data with any of our professional advisors such as attorneys or accountants (“Outside Professionals”) to facilitate the professional advice from those Outside Professionals.

7. Security

We have implemented technical and organizational security measures intended to safeguard the personal data in our custody and control. While we endeavor to protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Please recognize that protecting your personal data is also your responsibility. We ask you to be responsible for safeguarding your password, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify us of any unauthorized use of your password.

8. Retention of Personal Data

Our retention periods for personal data are based on business needs and legal requirements. We will keep your personal data for as long as is reasonably necessary for the purposes for which it is collected, for other purposes described in this Policy, or as may be required by applicable law. If you wish to cancel your account or request that we no longer use your information to provide you Services, we may still retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Communications and Marketing Preferences

Service Communications. We may send you non-promotional communications, such as account notices, transaction confirmations, security alerts, service updates, policy updates, support messages, and other communications related to your use of the Services. You may not be able to opt out of certain service communications.

Marketing Emails. Subject to your choices and applicable law, we may send you marketing emails about our products, Services, promotions, offers, and updates. You can opt out of marketing emails by following the unsubscribe link in the email, changing your account settings where available, or contacting us at privacy@ingenio.com.

Text Messages and Calls. If you provide consent to receive text messages or calls from us, including through automated dialing systems or prerecorded messages where applicable, we may contact you at the phone number you provide. Consent to marketing calls or texts is not required to purchase or use our Services. Message and data rates may apply. You must be 18 years old or older to participate. You may opt out of text messages by replying “STOP” or following the instructions provided in the message. You may also contact us to revoke consent.

Call Recording and Transcription Choices. Where call recording and transcription features are available, we may provide notices through the Services explaining that a call will be recorded and transcribed. Depending on the feature and your account settings, you may be able to enable, disable, or manage call transcript settings before a call begins. If you do not want a call to be recorded or transcribed, you should not proceed with the call or should disable the feature where controls are available. Advisors or readers may be required to acknowledge applicable recording and transcription notices or terms before accepting or participating in calls through the Services. 

10. Privacy Rights

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal data. If any of the rights listed below are not provided to you under the law that governs the processing of your personal data, we have absolute discretion in providing you with those rights. Please refer to the table below to determine the rights you have in your jurisdiction. For individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland, please see Section 12 instead. For individuals using or accessing our Service while located in Québec see Section 15, and for individuals in Israel see Section 16. 

Your rights in relation to your personal data are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

Privacy Rights may include the following:

(a)   Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal data that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal data.

(b)  Right to Correct. You may have the right to correct any of your personal data in our records and systems. You may request us to rectify, correct or update any of your personal data held by us that is inaccurate. In addition to the methods described below, you can correct your personal data through your account settings.

(c)   Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal data that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal data, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable law.

(d)  Right to Portability. You may have the right to receive a copy of the personal data we have collected about you in a structured, commonly used and machine-readable format.

(e)  Right to Opt-Out Sale / Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt out of: (i) the sale of your personal data; and (ii) the sharing of your personal data for targeted advertising or profiling, as defined under applicable law.  We use Tracking Technologies (as described in the “Cookies and Other Tracking Technologies” Section above) and may disclose certain personal data to advertising partners. Under certain state laws, this may be considered a “sale” or “sharing” of personal data.   

(f)    Right to Opt-Out of Automated Decision-making or Profiling. In certain jurisdictions, you may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not make decisions about you based solely on automated processing (i.e., where a decision is taken about you using an electronic system without human involvement) that produces legal or similarly significant effects.

(g)   Right Against Discrimination. We do not discriminate against any customers who exercise any of their rights described in this Policy.

(h)  Right to Appeal. In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.

(i)    Right to Obtain Third-Party List. You may have the right to request a list of specific third parties to which we have disclosed personal data.

As mentioned above, depending on where you reside or are located, you may be able to assert certain rights with respect to your personal data. To determine which rights you have, please refer to the table below that references the rights as described above in the Privacy Rights Section.  

Submitting a Rights Request

If you are a resident in a state that provides the rights noted above, you can assert your privacy rights by emailing us at privacy@ingenio.com with the subject line “Privacy Rights Request” advising us which privacy rights you would like to exercise. Depending on your state of residence, applicable law may limit how many times per year you may submit a Right to Know/Access.  We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

To protect your privacy, we must be able to verify your identity to confirm that the rights request came from you. We may contact you by phone or e-mail to verify your request before we can process your request to exercise certain privacy rights. Depending on your request, we will ask for information such as your name, address, an e-mail address or a phone number you have used with us. For certain requests, we may also ask you to provide details about your most recent purchases.

Where permitted by applicable law, you may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we will require you to verify your identity with us, or have you confirm the authorized agent is authorized to act on your behalf.

Opting-out of Tracking Technologies based Sales and Targeted Advertising

You may exercise your right to opt out of sales and targeted advertising via Tracking Technologies at any time by emailing us at privacy@ingenio.com, or by clicking the “Your Privacy Choices” link in the website footer and following the directions in the Your Privacy Choices pop-up screen regarding how to opt-out of sales and targeted advertising.

Where required by applicable law, we will also honor browser-based opt-out preference signals such as the Global Privacy Control (GPC). Please note that your opt-out choice will only apply to your use of our Sites through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of targeted advertising requests on each device and browser you use to visit our Sites to completely opt-out using this method.  Please note that you may still receive generalized ads after opting out.

11. Children’s Privacy and Adult-Only Services

Our Services are not directed to, and we do not knowingly collect personal data from, children under the age of 18. If you are under 18, please do not attempt to fill out our forms or send any personal data about yourself to us. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such information from our files. If you are a parent or guardian and you believe that your child has provided us with information without your consent, please contact us at privacy@ingenio.com, and we will take reasonable steps to ensure that such information is deleted from our databases in accordance with applicable law.

AI chatbot and Memory features are intended for adults only. If we learn or reasonably determine that a user is under 18, we may restrict or disable access to certain features or take steps to delete the information, subject to applicable law and technical limitations.

12. Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time of data collection. We may ask you to identify or select which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country.

Our Relationship to You

Ingenio is a data controller with regard to any personal data collected from individuals accessing or using its Services. A data controller is an entity that determines the purposes for which and the manner in which any personal data is processed. For more information, please direct your inquiries to: 

Controller Contact:
Ingenio, LLC
182 Howard Street #826
San Francisco, California 94105 USA
privacy@ingenio.com

EU Representative:
adviqo GmbH
Max-Dohrn-Str. 8 - 10
D-10589 Berlin, Germany
privacy@adviqo.com

UK Representative:
adviqo UK Limited
Anglia House, 6 Central Avenue
St Andrews Business Park
Thorpe St. Andrew, Norwich, Norfolk, NR7 0HR, United Kingdom
privacy@adviqo.com

Your Privacy Rights

We provide you with the rights described below when we process your personal data which you can exercise via the Privacy Request Form on our Site or by emailing us at privacy@ingenio.com. We may limit your individual rights: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on another data subject’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic.

• Right to Access. You may have the right to obtain a copy of your personal data that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal data that we process, the entities to whom we disclose your personal data, etc.

• Right to Rectification. You may have the right to request us correct any of your personal data in our files

• Right to Erasure. Under certain circumstances, you may have the right to request erasure of your personal data that we hold about you. To note, this right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.

• Right to Restriction. You have the right to request that we restrict our processing of your personal data in certain circumstances. For instance, this right is available if you contest the accuracy of the personal data, or if you objected to our processing.

• Right to Object to Processing. You have the right to object to our processing of your personal data at any time and as permitted by applicable law if we process your personal data on the legal bases of consent or legitimate interests. However, we may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

• Right to Portability. Under certain circumstances, you may have the right to receive personal data we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal data to another controller.

• Right to Withdraw Consent. To the extent the processing of your personal data is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

• Right to Object to Automated Decision-Making. We do not make any decisions based solely on algorithms or other automated processing that significantly affect you.

• Right to Lodge a Complaint. You may have the right to lodge a complaint with your local data protection authority about our processing of your Personal data. Contact details for data protection authorities in the European Economic Area are available here, and contact details for the United Kingdom’s ICO are available here. The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC), available here.

Legal Bases for Processing

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the Contact Us Section below. 

13. International Transfers

When you access or use our Services, your personal data may be processed in the United States or any other country in which Ingenio, its affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Services.

We will take all the steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy and no transfer of your personal data will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws, and ensuring the security of your personal data maintained.

To the extent we transfer to another business any personal data collected from individuals while they are located in the European Countries, we transfer such data subject to appropriate safeguards and as permitted under the data protection laws, including:  (i) through the use of standard contractual clauses approved by an appropriate regulatory authority, such as the European Commission or the U.K. Information Commissioner’s Office; (ii) an Article 49 derogations in specific situations; or (iii) any other compliant transfer mechanism.  We may also rely on an adequacy decision of the appropriate regulatory authority confirming an adequate level of data protection in the jurisdiction of the party receiving the information.

14. Additional Disclosures

Shine the Light. The California Shine the Light law permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please contact us using the information below in the Contact Us Section, and indicate in your message that you are a California resident making a “Shine the Light” inquiry. This request may be made no more than once per calendar year.

Do Not Track Signals. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, since uniform standards for “DNT” signals have not been adopted, we do not disable tracking technology that may be active on the Website in response to any “do not track” requests that we receive from your browser.

15. Notice to Québec Residents

If you are a resident of Québec in Canada, this section applies to you in addition to the rest of the Policy.  If you have questions or concerns about our privacy practices, you may contact our representative at: privacy@ingenio.com. We may, at our sole discretion, ask you for information to verify you are a resident of Québec province in Canada prior to responding.

Personal Information Collection Means. We may collect the categories of personal data identified in Section 1 via electronic tracking and monitoring, video, in person interactions, interactive forms, and phone calls.

Governance Policies. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, including reasonable physical, administrative, and technical measures, we cannot guarantee the security of your personal information. Additionally, we maintain internal governance policies designed to protect your information. These governance policies include, but are not limited to, written information security protocols, incident response plans, data subject request protocols, and record destruction policies.  

Your Privacy Rights

• Right to Access. You may have the right to obtain a copy of your personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal information that we process, the third parties who may receive your personal information, etc.

• Right to Correct. You may have the right to request us correct any of your personal information in our files.

• Right to Be Informed. You may have the right to request regarding the name of third parties with which we share your personal information and whether your personal information could be shared with outside Québec.

• Right to Rectification. Under certain circumstances, you may have the right to request erasure of your personal information that we hold about you. To note, this right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.

• Right to Portability. Under circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format.

• Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

• Right to Withdraw Consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

16. Notice to Israel Residents

If you are located in Israel, our collection and use of personal data may be governed by Israel’s Protection of Privacy Law (“PPL”) and related regulations. Subject to PPL, you may have the right to access personal data held about you, request correction or deletion of inaccurate, incomplete, unclear, or outdated information, object to certain direct marketing uses, and request removal from direct marketing lists.

If we send marketing communications, each message will include a clear notice and a method to opt out where required. You may exercise your rights by contacting privacy@ingenio.com.

Providing personal data for mandatory purposes, such as creating an account, completing a purchase, or using certain Services, is voluntary, but if you do not provide required information, we may not be able to provide the relevant Services.

17. Third-Party Links and Services

Our Site may include links to third party websites and/or applications of our partners or affiliates that are not owned or operated by us. If you follow a link to any of these websites, please review the privacy policies of third-party websites before you submit any personal data to them. We do not control the privacy practices of these third-party websites or applications. 

18. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you want to exercise privacy rights, please contact us at:

Email: privacy@ingenio.com
Mailing Address: Ingenio, LLC, 182 Howard Street #826, San Francisco, CA 94105 USA