Last Updated: 05 Nov. 2023
ICOM AI (“ICOM”, “we,” “us,” or “our”) is committed to respecting your privacy, protecting your personal information, and being transparent about its treatment of your personal information.
This Privacy Policy covers the information practices of ICOM AI as they relate to personal information collected through www.icom.ai, including its subdomains (the “Site”), our marketing activities, and in other settings where we post this Privacy Policy. The Site is hosted in the United States. If you submit your personal information on the Site, it will be transferred to the United States. By visiting this website, you are accepting and consenting to the practices described in this policy.
Please note that this Privacy Policy does not apply to the personal information we collect and process on behalf of our Clients through or in connection with the services we provide to them. Our Clients have their own policies regarding the collection, use and disclosure of your personal information in connection with our services. To learn about how a particular Client handles your personal information, we encourage you to read the Client’s privacy policy. Our use of personal data provided by our Clients for use with our services is subject to the written agreement between ICOM AI and Client.
As further discussed in the Cross-Border Data Transfers and Privacy Shield Notice section below, we participate in and adhere to the Privacy Shield frameworks.
California residents using this Site should be sure to read the information below under Additional Information for California residents.
Site users from the European Union should be sure to read the information provided below under Additional Information for European Union Users.
ICOM AI provides conversational AI solutions that help our customers’ (“Clients”) enterprise revenue teams attract, acquire and grow their customers across the customer lifecycle over Email, SMS, and Website Chat. These solutions and the software as a service platform with which they are delivered are collectively referred to as the “Service”. To be clear, as further discussed under the “Welcome” section above, this Privacy Policy does not apply to the Service.
While operating the Site, we may collect the following types of information (collectively, the “Information”).
Your first name, last name, user name or similar identifier, title, and date of birth.
Your business postal address, email address and telephone number.
Your credit card or other payment and billing details.
Information you provide in survey responses, when you participate in market research, report a problem, receive customer support or otherwise correspond with us.
Information about how you use the Service and interact with us.
Your preferences for receiving marketing communications and details about how you engage with them.
We may automatically record certain information about how you use our Site (we refer to this information as “Activity Data“), including both Clients and casual visitors.
These may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our site that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
ICOM AI and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.
Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.
If you send or disclose any sensitive personal information to us (such as when you submit user generated content to the Site), you are consenting to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not provide it.
We may obtain additional information about you from third party sources to enrich your experience on the Site and provide you with more relevant information related to our service offerings.
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your organization’s relationship with us by updating your account information or emailing your customer success manager
If you have an ICOM AI account, we use your personal information:
If you request information from us, register for the Service or participate in our surveys, promotions, or events, we may send you ICOM AI-related marketing communications if permitted by law, but will provide you with the ability to opt out.
We use your personal information, as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information or you opt into third party marketing communications.
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:
ICOM AI account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. ICOM AI account holders may also contact us at privacy@icom.ai to accomplish the foregoing or if you have additional requests or questions.
ICOM AI has no direct relationship with the individuals whose personal information is contained within the Client User Data processed by our Service. An individual who seeks access, or who seeks to correct, amend, or delete personal information provided by our Clients should direct their request to the Client. You may also contact us at privacy@icom.ai if you have additional questions or concerns.
You may opt out of marketing-related emails by logging in and changing your account settings or by clicking on a link at the bottom of each such email. You may continue to receive Service-related and other non-marketing emails.
If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us.
We may allow service providers and other third parties to use cookies and other tracking technologies to track your browsing activity over time and across our Site and third party websites. We may also partner with a third-party ad network to either display advertising on our Site, to manage our advertising on other sites, or to provide you targeted advertisements based upon your interests on our Site or on third party sites. Other companies’ use of their tracking technologies is subject to their own privacy policies. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. In some of our communications, we use tracking means, such as a “click-through URL” linked to content on the Site. We track this data to help us measure the effectiveness of our customer communications.
Where we need to collect your personal information by law, or to be able to provide the Service to you and you do not provide that information when requested (or you later ask to delete it), we may not be able to provide you with the Service and may need to close your account. We will tell you what information you must provide to receive the Service by designating it as required in the Service or through other appropriate means.
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
ICOM AI is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. European Union users should read the important information provided further below under the “Cross Border Transfer” Section about transfer of personal information outside of the European Economic Area.
The Service may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Our Site may include social media features. These features may collect your personal information and track your use of the Site. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing such functionality.
We may make available on our Site, or link to, features that allow you to share information with third parties online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use; storage or dissemination of such publicly disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.
ICOM AI does not knowingly acquire or receive personal information from children under 13. If we later learn that any user of our Service is under the age of 13, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via email (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Site – or a specific announcement on this page or on our blog). Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
If you have any questions about this Policy, please contact our Data Protection Officer by emailing privacy@icom.ai or by writing to us at the following address: ICOM AI, 211 Highland Cross Dr, Suite 285, TX 77073, USA, Attention: Data Protection Officer.
This Privacy Notice for California Residents supplements the information contained in ICOM AI Privacy Policy and applies solely to all Site users who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“). In particular, our website has collected data within the following categories of personal information from its consumers within the last twelve (12) months:
You request a demo of Bearer
We call you
You use Bearer
You receive emails from us
You chat with us for customer support
You opt-in to marketing messages
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, physical characteristics or description, address, telephone number, education, employment, and employment history. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(website only)
E. Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
(no movements)
G. Geolocation data
Physical location or movements
H. Sensory data
Audio and video information.
I. Professional or employment-related information.
Current or past job history.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use or disclose the personal information we collect for one or more of the business purposes described in our Privacy Policy under the heading How We Use Your Personal Information.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following category of third parties: Service providers.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Please note that during 2021 under a “business to business” exception, access, portability, and deletion rights will not apply to personal information reflecting a written or verbal communication or a transaction between ICOM AI and you, if you are a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with ICOM AI occur solely within the context of the your business conducting due diligence regarding, or providing or receiving a product or service to or from ICOM AI.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us an email at privacy@icom.ai or a letter at our mailing address provided elsewhere in our Privacy Policy. Please include your email address in the letter if you choose to contact us by letter. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not sell your personal information to any party as the word sell or sale is used in the context of the CCPA.
We will not discriminate against you (or your employer) for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
We do not share or sell information to third parties for their direct marketing purposes.
References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@icom.ai.
You request a demo of Bearer
We call you
You use Bearer
You receive emails from us
You chat with us for customer support
You opt-in to marketing messages
To provide you with requested information, provide personalized content on the Site, and communicate with you about the Service.
Legitimate interests in conducting our business.
To enter into Service agreements with you, establish your business account and Service account, and to provide you with technical support and other Service support and communicate with you
Processing is necessary for performance of our contract with your organization.
Fraud prevention and data protection
Processing is necessary to comply with our legal obligations or required for performance of our contract with your organization.
To comply with law
Processing is necessary to comply with our legal obligations.
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at privacy@icom.ai.
We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including contact, identity, financial and transaction information) for six years after they cease being customers for tax purposes. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to privacy@icom.ai or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at privacy@icom.ai or submit a complaint to the data protection regulator in your jurisdiction.
ICOM AI complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. ICOM AI has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, ICOM AI is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Individuals in the EEA, the UK, and Switzerland have rights to access personal data about them, and to limit use and disclosure of their personal da ta. With our Privacy Shield self-certification, we have committed to respect those rights. We process service data only on behalf of our Clients in accordance with their instructions. This means that if you wish to access your personal data we have processed on behalf of a Client and request that we correct, amend, or delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that Client with your request we will then help them to fulfill that request in accordance with their instructions.
If we have processed your personal data as a data controller, you can request access to that data and request that we correct amend or delete it if it is inaccurate or processed in violation of Privacy Shield by emailing your request to privacy@icom.ai. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your personal data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@icom.ai.
ICOM AI's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. ICOM AI remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless ICOM AI proves that it is not responsible for the event giving rise to the damage.
In certain situations, ICOM AI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, ICOM AI commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact ICOM AI at privacy@icom.ai. ICOM AI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov.
For purposes of this Policy, the following definitions shall apply: “Personal information” means any information or set of information that identifies or could be used by or on behalf of ICOM AI to identify an individual. Personal information does not include information that is anonymized or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, ICOM AI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
ICOM AI is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Should an EU or Swiss individual be unable to resolve a complaint through the Council of Better Business Bureau’s complaint process, they may contact the FTC at the following address: Federal Trade Commission Attn: Consumer Response Center 600 Pennsylvania Avenue NW Washington, DC 20580. www.ftc.gov.
